In the Due Diligence Section, the company's statement highlights certain areas of high risk:
Risk Mapping Tier 1 Supplier Program Risk Assessment: Hershey used the Risk Segmentation tool developed in partnership with Verité to assess all our Tier 1 raw material and packaging suppliers as well as co-manufacturers, co-packers, licensees and labor service providers. We assessed more than 1,300 suppliers and 100% of spend in the aforementioned areas through this tool to develop a prioritized list for due diligence. Our risk assessment resulted in the following:• A list of 450 high-risk suppliers and supplier sites. The majority of the high-risk suppliers are located in China, India, Malaysia, South Korea and the U.S. and are suppliers of cocoa, packaging material, palm oil, sugar, or are co-manufacturers/co-packers, licensing partners or The Hershey Experience vendors. Our goal is to enroll 100% ofhigh-risk suppliers in our Responsible Sourcing Supplier Program by the end of 2021; we are on track with a 75% enrollment rate at the end of 2020. • A recognition that responsible recruitment risks are higher in South and East Asia, but we should be monitoring risks globally for all vulnerable groups such as migrant workers and women. As a result, we developed our new Responsible Recruitment Policy and Program and the goal is to expand the program to 100% of in-scope labor service providers (~75 suppliers). We also began tracking the number and geographic location of migrant workers in our broader supply chain both through our Responsible Sourcing and Recruitment programs. • Integration of human rights risk screening into our supplier qualification and monitoring process to ensure we are assessing forced labor and other human rights risks prior to entering into a commercial relationship. This new process will be implemented starting in 2021.Priority Ingredients and Materials Risk Assessment: In addition to our Tier 1 suppliers, Hershey uses the Risk Segmentation tool to assess risks across the full value chain of our ingredients and materials. In 2020, we conducted an internal gap analysis to assess which risks our Responsible Sourcing specific ingredient and material policies and programs currently address. Through this, we defined priority ingredients and materials which will be revisited annually to assess possible reprioritization based on i) changes in our supply chain, ii) developments in the environmental and human rights strategies, and iii) changes in sustainability risks. Overall, this a process identified the following: • Cocoa, sugar, and palm oil present the most significant risks of forced labor due to the nature of their value chains and geography. These ingredients remain the focus areas for Hershey’s human rights and responsible sourcing efforts. • While cocoa is sourced from multiple regions, Cote d’Ivoire and Ghana remain the focus of our sustainable cocoa sourcing efforts, including the implementation of Child Labor Monitoring & Remediation Systems (CLMRS). Based on identified risks, Hershey has committed all cocoa from Cote d’Ivoire and Ghana in our supply chain will be sourced directly through our suppliers by 2025. We also committed to 100% CLMRS coverage of our directly sourced cocoa in these two countries by 2025. We have found 0 instances of forced labor in our supply chain to date. • Child Labor & Forced labor risks in sugarcane exist across multiple origins, including but not limited to Mexico, Brazil and Belize. We are currently working on an updated sustainable sugar sourcing strategy in 2021.• Child labor and forced labor risks in palm oil exist across multiple origins from which Hershey sources, including Indonesia and Malaysia. Hershey updated our Responsible Palm Oil Sourcing Policy to further strengthen our requirements around an exploitation-free palm supply chain, including promoting and following ethical recruitment, hiring and employment practices in line with the Priority Industry Principles.
The statement does not name specific vendors but mentions that "the majority of the high-risk suppliers are located in China, India, Malaysia, South Korea and the U.S. and are suppliers of cocoa, packaging material, palm oil, sugar, or are co-manufacturers/co-packers, licensing partners or The Hershey Experience vendors."