Modern Slavery Statement 2025
Introduction
This statement, published in accordance with the UK Modern Slavery Act 2015, outlines the steps taken by Avon Cosmetics Ltd* to prevent all forms of forced labour and modern slavery in our business and supply chains during the financial year 1 January to 31 December 2025.
Avon’s purpose is to create a better world for all. We aim to achieve that by being a socially and environmentally responsible business. Our core business strategy is designed to protect our planet, invest in people and make our products more sustainable.
As part of this, we are committed to protecting human rights for all people in both our business and supply chains. We take steps to identify human rights risks, prevent abuses, and mitigate harm, through our own initiatives and in partnership with suppliers and industry groups.
We acknowledge that modern slavery takes many forms and is often hidden, particularly in complex supply chains. In line with best practice, we focus our efforts on sectors that pose relatively high risks of forced labour and other modern slavery concerns.
This statement was approved by the Avon International Board of Directors. It was signed and approved by CEO of Avon International, Kristof Neirynck on 16 March 2025.
Our structure, operations and supply chains
Business overview
Avon is a global beauty brand. We manufacture and sell high-quality, cruelty-free beauty and wellbeing products as well as fashion and home items. Our products are made accessible through our omnichannel ecosystem of online and retail stores, and through an extensive network of independent Representatives, including a small but growing number of franchisees.
Avon Cosmetics Ltd. manages Avon’s operations in Europe, the Middle East and Africa, and Asia Pacific supported by two manufacturing hubs in Europe and Asia. In 2025 we directly employed around 3,000 Associates and around two million independent Representatives sold our products to earn a primary or supplementary income.
Business structure and governance
Avon Cosmetics Ltd is part of Regent LP’s investment portfolio. Avon’s CEO and Enabling Leadership Team lead Avon’s operations and governance, with support and scrutiny from Avon-specific Environmental, Social and Governance (ESG) and Sustainable Growth and Ethical Business committees. Any activities or concerns relating to human rights are included in our quarterly management reporting.
We are guided by our Sustainable Growth Strategy and key performance indicators (KPIs) specifically relating to protecting our planet, investing in people, and making our products more sustainable (see diagram).
Each of these three pillars relates to human rights and modern slavery in some way. Our Invest in People pillar includes a specific focus on defending human rights and gender equity.
This is particularly pertinent for a business in which the customer and Representative base is mostly women, and because we know that women and girls face greater risks of human trafficking and modern slavery.
Supply chains
Like other global manufacturers and retailers, our supply chains are complex. We engage around 6,800 direct (tier 1) and indirect (lower tier) suppliers across Europe, Asia, the Americas, and Africa.
Our approach to tackling modern slavery.
We continually monitor, review, and improve our approach to prevent, identify, and remedy all forms of modern slavery. We regularly review our performance against specific measurable KPIs, including suppliers’ degree of audit compliance, and traceability and certification levels in critical material supply chains.
Our human rights work aligns with key international frameworks and standards:
- UN Guiding Principles on Business and Human Rights
- International Bill of Human Rights
- International Labour Organization Declaration on Fundamental Rights at Work
- International Labour Organization Declaration of Principles Concerning Multinational Enterprises
- UN Convention on the Elimination of All Forms of Discrimination against Women
- UN Women’s Empowerment Principles
Risk assessment in our operations and supply chains.
In 2024 we mapped the severity and likelihood of the main human rights risks linked to our business activities and products. This analysis guided us to prevent and reduce risks, as well as take actions to support people across our business and supply chains.
As Avon evolves, we will continue to update our human rights policies and procedures, with a particular focus on women's rights and labour rights.
Sustainable Procurement Due Diligence Programme
Our Sustainable Procurement Due Diligence Programme is designed to ensure that key supply chains comply with our Supplier Code of Conduct , and all applicable laws and regulations in their countries of operation.
All in-scope suppliers must ensure that no abusive, exploitative, or illegal workplace conditions exist in their operations or supply chains.
This four-step programme involves:
- Registration: A questionnaire to determine whether suppliers meet essential criteria, such as compliance with relevant policies.
- Risk assessment: Conducted by our Sustainable Procurement team using the Sedex RADAR tool, or a similar tool, to determine the required level of due diligence.
- Audits: All in-scope suppliers and sites must commission a third-party social and environmental audit every two years, covering safe and decent working conditions, and fair pay among other areas. We prefer Sedex Members Ethical Trade Audits , but also accept Amfori Business Social Compliance Initiative or Disney International Labor Standards social audits.
- Monitoring: If audits identify any areas of concern, we work with suppliers and sometimes independent specialists to address them, when required, through a corrective action plan. When necessary, we will terminate supplier relationships. In 2025, approved third party auditing companies completed 75 audits across high-risk countries.
High-risk Materials:
In line with best practice, we have specific supplier guidelines relating to critical and high-risk materials that may be linked to environmental or social risks, including the potential for labour exploitation. We also have procurement policies in place for these materials and report publicly on our progress towards achieving our sourcing goals for these materials.
We are active members of several commodity-specific action groups and initiatives that aim to strengthen human rights and drive systemic change.
Working with others to increase impact
As well as working with our suppliers and international multi-stakeholder certification and verification initiatives to source high-risk materials, we work with other partners to drive up working conditions and labour standards.
Avon continued to strengthen its approach to preventing modern slavery and protecting human rights within complex palm‑derived supply chains. We participated in ASD’s annual transparency investigation, contributing data to support enhanced mapping of direct and indirect suppliers and gaining access to detailed individual and collective risk assessments that improve our ability to identify and address potential labour and human rights risks in upstream sourcing.
Through ASD’s strengthened grievance management system, Avon benefited from coordinated monitoring and engagement on high‑priority social and labour‑related grievances across the palm sector.
Our membership also enabled us to support and learn from ASD’s on‑the‑ground human rights initiatives, including the Respect in Palm programme, which completed its 2025 exploratory phase to scale gender‑based violence prevention and worker‑safety training across palm plantations.
Avon maintained RSPO certification for palm derived ingredients, helping ensure that the palm oil used in our products is sourced through audited and traceable supply chains that meet strict sustainability and social responsibility criteria, as set out in the RSPO Supply Chain Certification Standard.
This certification provides third-party assurance over supply chain controls, supporting our ability to identify and mitigate risks related to labour exploitation in high-risk raw material categories.
Avon is a member of RMI, a global coalition working to build a fair, responsible and sustainable mica supply chain. Through our membership, we strengthen traceability, implement robust due diligence, and support efforts to prevent child labour and improve working conditions in mica producing communities. We also contribute to collective action that improves transparency, governance and risk management across the mica value chain. This work forms an important part of our broader human rights due diligence framework and supports alignment with international expectations.
We continued our collaboration with the Fair Labor Association coalition to promote decent working conditions for seasonal agricultural workers and child protection in the Turkish rose and Egyptian jasmine sectors.
Avon sources cotton through CmiA, an internationally recognised standard that promotes dignified labour conditions and improved livelihoods for smallholder farmers while enforcing clear social and environmental requirements in cotton production.
Using CmiA‑verified cotton enhances transparency and reduces exposure to forced‑labour risks in global cotton supply chains, an area widely recognised as vulnerable to labour exploitation.
Potential/actual incidents of modern slavery
In 2025 we finalised and published guidelines for our teams on recruitment fees and related costs prevention and remediation. The purpose of these guidelines is to prevent and mitigate adverse human rights impact, particularly those arising from the charging or payment of recruitment fees and related costs by workers within our operations and supply chain.
We recognise that this practice can leave workers vulnerable to difficulties leaving an employer to whom they owe money (debt bondage).
We use the guidelines to support suppliers with resolution via full reimbursement of the fees and encourage compliance via education of Avon’s zero tolerance position.
In 2025, two new incidents of recruitment fees were flagged during factory audits. In total there are seven cases identified across our supply chain.
The status of cases related to concerns is as follows:
- One case resolved through termination of business relationships due to absence of meaningful remediation commitment despite engagement efforts.
- Three cases under remediation and ongoing monitoring. These suppliers either acknowledged the findings, committed to corrective action plans and demonstrated willingness to improve or are now under a structured exit plan, supported by the identification and onboarding of compliant replacement suppliers to ensure continuity of operations. These cases remain under continual monitoring to ensure sustainable resolution.
- Three cases under internal review. Due to the complexity of associated risk considerations, these cases are pending escalation and final determination. Identifying an appropriate resolution is a high priority.
Our policies
Several policies and frameworks guide our work to prevent and mitigate any form of labour exploitation in our employment, purchasing, and sourcing.
Employment practices
We endeavour to be a diverse, equitable, inclusive, and supportive employer that provides safe and decent working conditions.
All our Associates are paid at least the Living Wage and can benefit from a range of progressive employment policies and supportive workplace programmes.
We champion our six Associate Resource Groups designed to promote DE&I and support best practice in business policies and initiatives.
Our Employee Code of Conduct requires all Associates to uphold human rights, behave ethically, and treat others with dignity and respect. Not doing so may be grounds for dismissal.
Associates complete annual training on these topics.
Our Associates complete surveys on ethics and compliance, along with other topics, and we listen to what they tell us and take action to address.
Employment policies
We ensure Associates are aware of all policies and mechanisms relevant to their role, and general and specific local risks relating to modern slavery.
Our Code of Conduct sets out our position and policies on diversity, equity, and inclusion; responsible supplier engagement; anti-discrimination; prevention of harassment and violence; anti-corruption; business conduct and ethics; and conflicts of interest, among other areas.
Our website outlines our Diversity, Equity, and Inclusion position.
Our Ethics Line enables anyone working in our operations or supply chains to anonymously report any suspected breach of our codes of conduct, policies, or standards. Reports can be made online in multiple languages. Our Ethics & Compliance team allocates any reported breaches to relevant teams for investigation and remediation.
The Avon Human Rights Statement outlines our commitments to protect human rights and the planet, which have been informed by external stakeholders and potentially affected rightsholders.
The Avon Global Supplier Code of Conduct forms part of our contract with all suppliers. It specifies the standards we expect of all tier one suppliers and their own related supply chains in relation to human rights and employment practices, including grievance and remedy processes. This code of conduct explicitly prohibits any form of modern slavery, forced labour, child labour, or human trafficking. It goes beyond legal compliance by committing our suppliers to positive actions such as responsible recruitment and paying living wages.
In line with best practice, we have specific supplier guidelines relating to critical and high-risk materials that may be linked to environmental or social risks, including the potential for labour exploitation. We also have procurement policies in place for these materials and report publicly on our progress towards achieving our sourcing goals for these materials.
Our Sustainable Procurement Due Diligence Supplier Guidelines outline our responsible procurement processes and procedures. This includes onboarding, risk assessment, audits, monitoring, and compliance.
Training on forced labour risks and mitigation remained a key focus of our modern slavery work in 2025. Informed as a direct result of our 2024 Human Rights Risk Assessment, we delivered targeted training and guidelines to internal teams on Recruitment Fees and the effective handling of supplier grievances. This included a focused session, attended by over 100 associates, reinforcing awareness on these topics as well as our strengthened approach to Sustainable Procurement Due Diligence, strengthening our capability to identify and address modern slavery risks across our operations and supply chains.
Next steps
In 2026 we will maintain a similar approach to preventing, identifying, and remedying all forms of modern slavery.
Our priorities for the year ahead are:
- Review ongoing progress and priorities around high-risk materials.
- Further strengthen our due diligence procedures - continuing to implement recommendations from the findings of the BSR Human Rights Risk Assessment.
- Continue preparatory work to comply with strengthening legislation around supply chain due diligence, notably the EU Forced Labour Regulation.
- Continue to provide training for all Associates on the importance of addressing forced labour, and the evolving regulatory context.
External engagement and accreditations
Action for Sustainable Derivatives
Business for Social Responsibility
Roundtable on Sustainable Palm Oil
*Avon Cosmetics Limited, the UK trading entity, and the principal company of Avon International.