The Modern Slavery Act 2015 (the ‘Act’) requires each business with an annual turnover of over £36m to publish a transparency statement which sets out the steps they have taken to ensure there is no modern slavery in their own business and in their supply chains. This statement is made pursuant to the Act.

Huel’s mission is to make nutritionally complete, convenient, affordable food with minimal impact on animals and the environment. We strive to act ethically and with integrity in all aspects of our business, and we take a zero tolerance approach to any instance of modern slavery within our business and its supply chains and we expect organisations with whom we do business to adopt and enforce policies to comply with the legislation.

We are fully committed to compliance with the Modern Slavery Act 2015 and recognise the importance of taking all necessary action to combat modern slavery in all its forms including slavery, servitude, forced and compulsory labour and human trafficking.

Organisation and business structure

Huel creates and sells complete food products and supplements - sold in the forms of powder, instant savoury meals, ready to drink meals, bars, daily greens powder and A-Z Vitamin drink. We sell our products online directly to consumers as well as in stores through retail partners. Our products are sold globally with the largest markets being the UK, US, and Europe. Our ingredients are sourced from around the world, and our products are manufactured and packaged in the UK, US, and Europe.

We work with external partners to source our ingredients and manufacture our finished products, which means that we don’t own the farms that grow the ingredients for our products, or the factories that blend and package them.

Our global headquarters are in Tring, UK and we have additional offices in Birmingham and London, UK, New York, US and Leipzig, Germany. As at the end of our most recent financial year ended 31st July 2023, we employed 240 people globally.

Our supply chain

Our products are 100% composed of plant-derived ingredients, primarily in the form of powders and liquids, which are sourced globally either directly from suppliers, or via agents and distributors. Our key source countries for ingredients are the UK, Europe, China and the US. Our primary and secondary packaging is sourced from the UK, Europe, and US. Packaging materials include paper, cardboard, aluminium cans and plastic. Product manufacturing is carried out by selected third-party manufacturing partners, the locations of which are based on proximity to our downstream distribution centres, as well as their capability to meet our quality requirements, manufacturing standards, and available production capacity.

Our direct and indirect supply chains include services that are not specifically used in our products but support the operation of our business such as marketing agencies, professional advisor fees, and third-party warehouses. These service providers are located primarily within the countries where our offices are located but can extend globally for any specialist items or service which cannot be obtained domestically.

Internal Policies

At Huel we want to provide our employees (also known as Hueligans) with a safe and fair working environment that protects their human rights. We currently have the following measures in place:

• Right to work checks are conducted for all potential employees in accordance with relevant legislation, with a minimum working age of 18 years;
• Employee contracts to protect fundamental rights in the workplace;
• Market-related pay and rewards are reviewed annually;
• Huel Culture Handbook which describes our preferred way of working, doing business in a fair way, and treating each other and those we work with outside of Huel with honesty and respect;
• Working at Huel Handbook which includes a commitment to equal opportunities, a safe working environment that is free from discrimination and a whistleblowing procedure for employees if they see anything that they think goes against our expected ways of working;
• All new employees complete a people team induction during which both the Culture and Working at Huel handbooks are discussed.

Huel will occasionally use internally approved recruitment agencies, in which case the agency is expected to adhere to the policies outlined in the Working at Huel Handbook.

We also ask our employees to support our commitment to combat modern day slavery. All new employees attend a sustainability induction to ensure an understanding of the risks of modern slavery and human trafficking.

Employees involved in procurement activities receive additional ethical sourcing training for a deeper level of understanding, and to understand the tools used by Huel to prevent slavery and human trafficking in our supply chain.

Due Diligence

Huel recognises that the biggest risk of slavery and human trafficking is in our global ingredient supply chain and as such have focused our efforts in these areas. We undertake the following actions within our supplier approval process to prevent slavery and human trafficking in our supply chain:

• Huel undertakes an annual risk assessment for all potential ingredient sourcing countries to identify the likely level of risk for both modern slavery and other human rights issues. This risk assessment guides the level of investigation and certification that we require before sourcing from a new supplier. Data used for the risk assessment is sourced from both publicly available risk indices and a number of subscription based data platforms;
• Since 2020, all potential new suppliers are required to complete a Self-Assessment Questionnaire indicating their approach to the protection of human rights and against modern slavery within their organisation. The response to this questionnaire informs our decision as to whether or not to proceed in establishing a sourcing relationship with each supplier.
• Since 2021, all new suppliers are required to sign the Huel Supplier Code of Conduct. This specifies Huel’s requirements with regard to the protection of human rights and the environment. Failure to adhere to the Code may result in termination of the supply arrangement.
• Since 2021, all new suppliers are required to hold an internationally recognised, independently verified ethical certification at the time of supply to Huel or for suppliers with a lower risk profile within 6-12 months of the commencement of supply. Any indicators of risk identified during the certification process are followed up as appropriate with either a request for further information, a visit, commitment for corrective actions or another independent audit; and
• Huel are members of the Supplier Ethical Data Exchange (Sedex) and we use the information available via this platform to assist in identifying and managing risk within both our existing and prospective ingredient suppliers.

Performance 2022/23

Our primary measure of performance is the number of our suppliers that hold an internationally recognised, independently verified ethical certification. We typically require an ethical certification at the point of ingredient processing (or the point of greatest risk) in our supply chain, regardless of the point where the commercial relationship is held.

At the end of our financial year 2022/23, 84% of our ingredient volume and 87% of our ingredient purchasing spend was from suppliers that held an independently verified, internationally recognised, ethical certification. Our goal for the end of the financial year 2023/24 is for both of these indicators to be above 90%.

Going Forward

In 2024 we will continue to work with our suppliers to improve their performance, and to utilise risk ratings for modern slavery and human trafficking for all our sourcing.

We will also be expanding the requirement for ethical certifications to our manufacturing, logistics and packaging suppliers.

Thanks

Thanks for reading, we hope that you have found this statement useful. At Huel we take our mission very seriously and our compliance to the Modern Slavery Act is an integral part of our commitment.

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 July 2023. This statement was approved by the Huel Limited Board of Directors.

James McMaster – CEO Huel Limited

30 October 2023