Modern Slavery Statement

Fair Trade

Modern Slavery Statement

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Hotel Chocolat Group PLC for the period 2nd July 2023 – 29th June 2024 to prevent modern slavery and human trafficking in its own business operations and supply chains.

Introduction - Business and Operational Structure

Hotel Chocolat is a UK based cocoa grower, chocolate manufacturer and omni-channel retailer with outlets in the UK and Ireland, a joint venture in Japan, an Online presence in the US and a hotel/restaurant/experiential programme in St Lucia.

Working with >200 suppliers, employing 2,000+ colleagues and serving an estimated 5 million customers.

Key Focus Areas

  • We completed training for all senior leaders, delivered by Unseen UK, covering the key risk factors, how to identify warning signs and how to mitigate modern slavery in practice.

  • We undertake Supplier Compliance Audits (using GLAA standards) for our existing temporary labour suppliers and pre-engagement audits for all new potential agency partnerships. The business has long operated an Engaged Ethics programme (see website for details) to support cocoa farmers and their families to positively affect environmental and labour conditions.

  • In the year we have further developed our enhanced programme - the Gentle Farming Project, which aims to achieve increased farm incomes from funded best practice initiatives aimed to increase yields, farmer income and improved sustainability of land use, with a goal of zero child or forced labour.

  • In return for receiving increased payments for cacao along with yield improving resource “on farm”, farmers sign up to the charter, which outlines sustainable farming practices and forbids modern slavery and illegal child labour. Third-party visits are undertaken annually and industry best practice of CLMRS put in place where risks and occurrences are identified.

  • Governance structure

    The Exec have responsibility and accountability for adherence to the Modern Slavery act. Specific activity is delegated to the Directors and Heads of Department with assurance provided in the form of reports to the Board and regular assessment of risks.

    Each Executive Director has responsibility for ensuring compliance with the act within their business area.

    Due Diligence

    Supplier selection assessment considers strategic future “fit” with our scale, culture and capability requirements followed by a formal supplier-approval process including risk assessment, technical specification and quality auditing criteria, code of conduct assessment and a check of commercial feasibility for both parties.

    All new suppliers are subject to an onboarding programme that formally covers all considerations above with Director level governance to support and approve in advance of supply partnering commencing.

    Responsible Recruitment

    We undertake right to work (“RTW”) checks for all new Hotel Chocolat employees on their first day, along with regular RTW audits. We routinely check bank account details; telephone numbers and addresses for duplication/anomalies.

    We have a comprehensive approach to ensuring our temporary labour providers are also following best practice and minimising the risk of modern slavery and we have a third-party audit programme to a) measure performance to agreed standards as well as applying best practice & lessons learned consistently with all partners.

    Training and Awareness

    We recognise the importance of leadership in tackling modern slavery and will embed this into our SLT (Senior Leadership Team) development framework that commences in September 2023 ongoing.

    As the business grows, we will review when to extend the training further based on a priority/risk across the business.

    Collaboration and partnership working

    We have worked with Unseen UK to ensure we apply best practice in this space along with the GLAA to ensure we adhere to their standards and protocols.

    Safecall have been our ongoing partner since 2016 providing our whistleblowing hotline and internal media which is communicated and visible at all physical locations.

    Finally, we are working with CLMRS to tackle child and forced labour in the cocoa industry with farm level audits ongoing and annual review of progress and target setting to achieve our aim of zero child and forced labour incidents across our entire farming community.

    Key performance indicators

  • Annual compliance audits for all temporary labour suppliers in the UK and all new suppliers subject to a pre-engagement audit
  • Procurement and HR teams both trained on Modern Slavery
  • Cocoa in St Lucia is purchased from a registered audited group of cocoa farmers.
  • Child labour and forced labour are illegal and our Technical Officers and Support teams are engaged with farmers daily to educate, advise and report relating issues.
  • A formal Child Labour Monitoring and Remediation Scheme is funded by us and is running within cocoa districts with 100% farmer participation

  • This statement was approved by the Board of Hotel Chocolat Group PLC on 28 September 2023.

    Signed by: Matt Margereson
    Position: COO
    Dated: 28th September 2023