Avon Modern Slavery Statement 2022
This is Avon’s seventh statement published in accordance with the UK Modern Slavery Act (2015). It relates to the activities of Avon Products, Inc., and its applicable consolidated subsidiaries, including Avon Cosmetics Limited in the UK (collectively, ‘Avon’ or the ‘Company’ for the 12-month financial reporting period beginning 1 st January 2022 and ending 31 st December 2022.
Since becoming part of Natura &Co (the cosmetic group comprising of The Body Shop, Avon, and Natura, also referred to herein as the “Holding”)) in 2020, we have set ambitious targets in line with the Holding’s sustainability vision Commitment to Life which sets out to tackle some of the world’s most pressing issues by 2030. One of the three key pillars within Commitment to Life is to defend Human Rights and to be Human-kind. Avon, as well as the wider Natura &Co holding, seeks to respect human rights and address human rights violations within our supply chain and our own business operations.
We are a responsible business and are committed to respecting human rights and ensuring there are no forms of modern slavery and child labour throughout our own business operations, our supply chains and in the local communities in which we operate. We recognise that modern slavery can take many different forms and is a complex global problem and we aim to seek out, identify and remediate problems and risks to protect those workers most vulnerable to human rights abuses. Our initiatives to combat modern slavery and human trafficking practices from global supply chains are increasingly aligned across Natura &Co, allowing us to collectively strengthen our impact to tackle this growing human rights abuse of modern slavery.
This year, the ongoing impacts of the Covid-19 pandemic, the socio-political and economic global environment, heightened by the war in Ukraine have continued to cause disruption and challenges in our supply chains, increasing some workers’ vulnerability to labour exploitation and hindering some of our risk assessment and due diligence practices. We recognise that these factors continue to worsen some drivers of modern slavery, such as poverty and restricted movement, making people more vulnerable to exploitation.
Our Business, structure and supply chains
Responsible Business – We do beauty differently
At Avon, we believe in a better world for women, which is a better world for all. Our purpose has always been since our founding 137 years ago to use the power of beauty to transform women’s lives for the better, and this remains our driving focus today. Avon has stood for women, providing innovative and high-quality beauty products, which are primarily sold to women, by women. We have proudly stood for women’s empowerment, long before women’s rights were formally recognised, and we continue to drive this powerful mission in the respect of all human rights and combatting modern slavery today.
Around the world, we empower more than five million independent sales Representatives to earn on their own terms. This inspiring community has been the driving force for women for 137 years, championing women and helping them succeed, making Avon ‘a global force for women.’ Whilst being known as ‘The Company for Women,’ we are proud to say that Avon is a democratic beauty brand. Our driving force is not about focusing on women at the cost of others however, we strive to achieve a better world for everyone.
Our business model provides opportunities for entrepreneurs around the world to earn and learn, supporting them to build their own businesses and achieve economic freedom. We have empowered generations of business owners to earn and learn in their own way, on their own terms, and we now support Representatives across the world to be successful beauty entrepreneurs – whatever that means for them. Globally, our Representatives can earn on average, more than 20% of the price of every product bought, meaning self-employed women are creating better future for themselves.
The Avon culture is based on five core values which serve as the guiding principles for all decisions, actions, and behaviours since Avon’s BIRTH:
Belief – We believe our people, and our business have the power to beat the odds and succeed
Integrity – We do what’s right by upholding a duty of care to our Representatives, our customers, our associates, the communities we serve and ourselves
Respect– We value differences and appreciate each person for their unique qualities
Trust – We build environments that are safe and open, where people are empowered to share their point of view and make decisions
Humility – We are not always right but we are always willing to learn.
Each core value plays a vital role in how we do business, as we believe business should be a force for good. We are proud of our culture, which holds belief and integrity front and centre of everything we do. Our ethical standards are embedded in the business, with an emphasis on the personal responsibility of every associate to behave ethically and in compliance with the laws and expectations of the communities in which we operate.
Our approach to responsible business and ensuring that a better world for women is a better world for all, is informed by the UN Sustainable Development Goals (SDGs). We continue to support the delivery of the goals, with a particular focus on the eight SDGs where we can make the biggest difference.
We are committed to tackling modern slavery by focusing on the delivery of SDG 8 – to promote sustained, inclusive, and sustainable economic growth, full and productive employment, and decent work for all. We also continue to support calls for stronger legal frameworks to tackle global forced labour in our supply chains and continue to review and strengthen our own due diligence processes.
Our Business and Structure
Avon is a global manufacturer and retailer operating in more than 50 countries, serving 5 million active independent Representatives. Avon has 9 of its own global manufacturing hubs across Latin America, Europe, and Asia. Avon provides innovative, quality products to customers at competitive prices. Our product lines include Avon make-up, Avon fragrance, ANEW skincare, Skin so Soft and Advance Techniques. Avon also sells an extensive range of wellbeing products, jewellery, lingerie, accessories, and gifts.
Avon employs approximately 15,000 employees worldwide, of which 66% of our workforce is made up of women, with 52% in managerial positions.
Our Supply Chains
Avon products and components procured for re-sale are sourced from 678 direct suppliers in 31 countries. As with other brands and retailers, Avon’s supply chain is complex, and we face challenges when dealing with changing economic, political, and environmental landscapes.
Our Modern Slavery Policy Frameworks
Avon does not have a standalone modern slavery policy. Instead, several policies and frameworks (outlined below) guide our efforts to provide decent work, and prevent and mitigate any form of labour exploitation, in our operations and supply chains. These mainstream modern slavery concerns in our employment, purchasing and sourcing practices are increasingly aligned across Natura &Co, which prides itself on being a global purpose driven group and the world’s largest B Corp.
Commitment to Life
This is Natura &Co’s 2030 Sustainability Vision, which guides operations and value chains throughout our group with the single purpose of creating the best global beauty group for the world. The principle behind this vision is to provide business solutions for the main socio-environmental problems the world is facing, generating positive impact. This approach calls for an all-encompassing business model that gives back more than it takes.
One of its three pillars is to defend human rights and be human kind, reflecting the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, the International Labour Organization (ILO) Declaration on Fundamental Rights at Work and the ILO Declaration on Multinational Enterprises.
This commits Avon and our sister brands to:
- Adopt a robust group-wide human rights policy by 2023 - achieved
- Have fully traced and/or certified supply chains for six high-risk raw materials (palm, mica, soy, cocoa, ethanol, and cotton) by 2025 – in progress
It also incorporates specific, measurable targets in how we treat our employees and our wider networks. These include pay equity and paying all employees globally at least a living wage by 2023, which we achieved early in 2022, with all our employees being paid at least the living wage for their region . We are also aiming to increase senior-level representation of under-represented groups by 2025, and zero tolerance of any human rights infringements in our supply chains.
The Natura &Co Global Supplier Code of Conduct
All new Avon suppliers must commit to our code of conduct before we enter a commercial relationship with them. This group-wide policy is based on the same internationally recognised standards and frameworks as Commitment to Life, as well as the UN Universal Declaration of Human Rights, the UN Global Compact, and the Ethical Trading Initiative (ETI) Base Code.
The code was updated in 2022 to encompass the Natura &Co Group, all brands, and geographies. It outlines the standards we expect of all direct suppliers and their own supply chains in relation to human rights and employment practices, prohibiting any form of modern slavery. The more robust code of conduct includes broader human rights expectations and reference to grievance mechanisms. It goes beyond legal compliance by committing our suppliers to positive actions such as responsible recruitment and paying living wages, not just avoiding poor practices. We are committed to working collaboratively with our suppliers to resolve any non-compliance. When necessary, we terminate relationships in a responsible way.
The Natura &Co Responsible Procurement Programme
This group-wide programme enables us to identify issues, manage risks and improve working conditions in our supply chains by collaborating with key subject matter stakeholders including BSR , andSEDEX, the responsible sourcing data sharing platform.
Through this programme, we embed human rights and environmental sustainability across all group operations, implementingresponsible sourcing policies and supplier guidance. See Our Due Diligence Approach section for more information.
In 2022, we launched a new vendor onboarding system at Natura &Co, which allows us to risk- assess our suppliers and factories, obtain key sustainability data and to work more closely with our suppliers to solve issues.
Natura &Co Critical Materials Policies
Linked to internationally recognised certification standards, six supply chains were identified by Natura &Co as high risk for potential labour and environmental exploitation (palm oil, cotton, mica, soy, paper, and ethanol).
In 2022 we launched our group wide critical material policies and action plans covering six items that are associated with social or environmental risks, such as forced labour in mica supply chains and human rights on palm plantations (see table).
To ensure these Avon ingredients and materials do not cause harm, we have clear standards on traceability (where they come from),and require certification that their production meets specific international standards.
In 2022, we trained suppliers to ensure they understand our sourcing requirements, including over 500 of our direct and indirect suppliers. We continued to participate in collaborative initiatives such as the Sustainable Palm Index and The Responsible Workplace Standard for mica processors to assure good social standards and address modern slavery in global supply chains. In 2022 we achieved over 90% traceability across all critical materials as well as 76.8% certification for paper (FSC or PEFC) and 57.5% certification for palm (RSPO (Roundtable on Sustainable Palm Oil) MB (Mass Balance)). We are on the good path for full delivery of the commitment across all 6 critical materials.
As members of Action for Sustainable Derivatives under Natura &Co holding membership, we have included active palm grievance management as part of our collaborative approach. With a high number of environmental and human rights violations linked to palm production, accurate risk monitoring and operational grievance management are key to building a sustainable supply chain. Avon both benefits from ASD strong grievance management and governance systems, including Grievance Prioritization Methodology, coordinating approaches with key stakeholders and experts, and supporting ASD members in engaging suppliers on high priority grievances. Building on these systems, Avon continuously monitors our own supply chain-related grievances and works with relevant first tier suppliers to assure that they are being addressed.
Natura &Co Human Rights Statement
What we stand for: to defend Human Rights and to be Human-Kind Respecting human rights is a big part of what Natura &Co is about. Avon, Natura, The Body Shop and Aesop share common principles, and for different reasons throughout their histories, human rights have always been important to all. In 2020, we launched our Commitment to Life, which reinforces our pledge to respect and defend Human Rights, as defined by the UN Guiding Principles on Business and Human Rights. It is our responsibility to be more Human-Kind; not only as a corporation, but collectively, and we commit to respecting the human principles of empathy and solidarity.
At Natura &Co we have built a comprehensive vision to step up and address some of the world’s most pressing issues. We commit to respect internationally recognized human rights as defined by the International Bill of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Rights at Work and the ILO Declaration on Multinational Enterprises. We are signatories of the UN Global Compact, the UN Women’s Empowerment Principles, and are certified or aspiring B Corporations.
We will embed this commitment in our operations and value chain and conduct human rights due diligence and provide access to effective remedy. We know we cannot do this alone, so beyond our engagement with our employees, we will rely on our business partners and stakeholders to help us identify human rights risks, prevent abuses, and mitigate harm when it occurs.
Through the ‘Defend Human Rights and Be Human-Kind’ pillar of our Commitment to Life, we are already pursuing initiatives to improve gender balance in our management team; closing the gender pay gap in our own business; creating a living wage for associates; working towards inclusion in management of under-represented groups; creating measurable gains for Consultants, Representatives and sourcing communities in earnings, education, health and digital inclusion. We are pursuing full traceability and/or certification for critical raw materials supply chains such as palm oil, paper, mica, ethanol, soy, and cotton.
The two other pillars in the Commitment to Life are ‘Address the Climate Crisis and Protect the Amazon’ and ‘Embrace Circularity and Regeneration ’. We know that ecosystem’s health is definitively intertwined with well-being of people – whether they be customers, employees, or local communities that touch our products. We are committed to respecting the right to a healthy environment and will take action to ensure the balanced protection of human rights and protection of the planet, by reducing the impact of climate change through the protection of forests and biodiversity and investing in regenerative solutions.
Finding ways for business to create positive change is a must: drawing from our existing efforts, we will build even stronger foundations to credibly manage human rights risks. Our approach will be informed by the perspectives of external stakeholders and potentially affected rightsholders.
The Statement: whose rights we defend
At Natura &Co, this human rights statement applies to us all. To over 35,000 of our employees, to our 5 million Representatives and Consultants from across the four iconic beauty companies which form us: Avon, Natura, The Body Shop and Aesop. It applies to people working in more than 110 countries: to the employees, Consultants/Representatives that sell our products, to our customers, contractors, temporary workers, franchisees, retailers and retail workers, suppliers and supply chain workers, and to the local and traditional communities where ingredients and minerals are sourced.
This means we respect the rights of all people connected to our business, brands, products, and services, with whom we promote positive business impact and opportunities.
Focus on potentially vulnerable populations
Women are an essential driver of our business model, and this inspires us to have a commitment to ensure the rights of women, of gender equality and economic empowerment. Upholding the UN Convention on the Elimination of All Forms of Discrimination against Women is important to us and our employees, Consultants/Representatives, retail workers that sell our products, persons throughout our extended value chain, members of local communities as well as our customers. It relates to women and anyone who identifies as female or transgender, including those who may be particularly vulnerable.
We recognize the equal rights of all, regardless of race, colour, sex, age, disability, language, religion, political or other opinion, national or social origin, caste, wealth, birth or the international status of the country or territory to which a person belongs. We have a specific focus on supporting the equality of people who are potentially politically, economically, and socially disadvantaged, including all under-represented groups: racial and ethnic, of all sexual diversities and gender identities (LGBTI), all socio-economically disadvantaged people and those with physical or mental disabilities. Natura &Co is already working to include these groups in at least 30% of our management as part of our targets for 2030.
For years, our brands have implemented ethical sourcing programs and community building activities in our supply chains that create economic benefits for indigenous populations and other producer communities. These actions are aligned with the UN Declaration on the Rights of Indigenous Peoples. Finally, we are committed to engaging and defending affected stakeholders, including women, traditional communities, all under-represented groups and human rights and environmental defenders. This is how our brands can help to build a bridge to a better reality: to bring voice and agency into our business decisions, and advocacy to connect stakeholders’ experiences to customers around the world.
Stakeholder engagement and grievance mechanisms
How will we do that? By asking for internal and external input from potentially affected stakeholders and their credible representatives, such as worker organizations. These activities include seeking inputs in our risk assessment process and in tracking the effectiveness of actions taken to prevent, mitigate and address negative human rights impacts. We will ask for feedback from our stakeholders and any partners we work with directly and contact representatives of these groups to understand the impact of our business operations and of business partners.
We believe, as a group, that everybody should feel safe to speak up. Employees and third parties have access to the Natura &Co Ethics Line and our Global Code of Conduct for employees and the Global Supplier Code of Conduct provide rules that relate to human rights issues in practice and emphasize the importance of raising concerns and seeking guidance related to business ethics and integrity as a critical component of our values. The Natura &Co Global Whistle-blower Policy is also publicly available to employees and third parties and shows how to report a concern and the process that will be undertaken to investigate such a concern to ensure that any concern is addressed on a timely basis. We do not tolerate any form of retaliation.
Priority human rights for our Group
As a Group, we need to set our priorities connected to our business activities and the activities of our business partners and based on input from our stakeholders’ groups. The below Human Rights risks list has been defined based on where the most severe risks exist. It will guide us in focusing our resources and attention to address or remedy adverse human rights impacts. During 2022, it was further refined and updated according to internal discussion and ongoing risk identification.
- Forced labour
- Gender equality
- Privacy and integrity
- Decent & Safe Working Conditions including freedom of association and collective bargaining
- Minorities & Communities’ Rights
- Land rights
- Fair wages & economic empowerment
- Child labour
- Right to a Healthy Environment
Defining priority Human Rights for our Group were made respecting the relationship between human rights and environment, according to our Commitment to Life. We are in the process of completing a formal exercise to determine the main human rights risks that can be connected to our business activities, products, and services by mapping the severity and likelihood of such risks. We commit in our strategies and programs to focus on these salient priority human rights issues through risk mitigation and prevention and will consider opportunities to take positive action that benefits and supports rightsholders. This will become an ongoing process, continually assessing risks and emerging issues to identify potential changes to our salient human rights risks and will be shared in our sustainability communications.
How to take action: scope & implementation
This human rights statement applies to all of us: to our own operations and business partners. We expect all Group and brand employees, contractors, franchisees, retailers, suppliers, and other business partners to understand this and to be in compliance with domestic law wherever we and they operate and adhere to international human rights standards. Where domestic and national law may not be aligned with international human rights standards, we commit to the higher standard.
It is only working together that we will make the progress that we wish for. Every business partner will be required to comply with our updated guidelines. Suppliers will be expected to follow our Global Supplier Code of Conduct to demonstrate and implement the shared commitment to respecting human rights, and we expect they will take this commitment to respect human rights in their own business relationships. We will also update our policy and procedures for collaboration with franchisees, Consultants/Representatives, wider community partners and investors and are planning to launch and implement a Reseller Code of Conduct across the Natura &Co Holding in 2023.
Implementation: how to make it real
To take action and implement this statement, business leaders in our Legal and Compliance, Human Resources, Procurement, Retail, Franchisee, Logistics, Marketing, Direct Sales, Risk Management, Internal Audit, Group Affairs, Communications and other functions will integrate human rights management into our standard planning, operating, and performance measurement procedures, programs that seek to achieve positive impact for all stakeholders, and all other regular business activities. This includes responsible marketing and setting expectations for Consultants/Representatives that sell our products directly to customers.
We are committed to conducting formal human rights due diligence, which includes:
- Assessing human rights risks on an ongoing basis, for our own business and across the value chain including for new markets, products, ingredients, and minerals
- Integrating risks identified into our management decisions and actions
- Preventing, mitigating, and managing human rights risks, while also creating positive change for our people, our wider network, and our partners in the value chain
- Using a data-driven approach to inform decision-making and track progress for effective remediation
- Communicating the outcomes of putting our human rights policy into practice, including continuous review of the effectiveness of our processes and regular and transparent reporting to internal and external stakeholders.
The Natura &Co Group human rights statement is approved and overseen by Natura &Co’sBoard of Directors and signed off by Natura &Co’s CEO. The Audit, Risk Management and Finance Committee of the Board has specific responsibility to review human rights risks on a regular basis, including utilization of a defined escalation process to identify negative human rights impacts and potential and actual emerging risks. A Human Rights Steering Committee has responsibility for strategic direction and decision-making on human rights, including being the starting point for escalating human rights issues to the Audit, Risk Management and Finance Committee.
The Board is supported by the group and business units’ leadership in delivering on our commitments aligned with the UN Guiding Principles, and expectations to be more Human-Kind, aligned with the Commitment to Life. This means the leadership teams instruct and supervise activities to operationalize the commitments made in this statement, including regarding human rights due diligence throughout our business activities and activities of our business partners. Our Director of Human Rights is responsible for the Natura &Co Group’s implementation of human rights risk management throughout our business activities and value chain, and reports to the Group Chief HR Officer. In turn, the Group Chief HR Officer will regularly report on respect for human rights to the Audit, Risk Management and Finance Committee and to the Board.
Avon employment policies and employee resources
Avon aims to be a fair and decent employer. We aim to provide supportive and inclusive working environments where each person can bring their whole self to work. We launched our Equity and Inclusion Position in 2022, clearly outlining that we are open to all, have zero tolerance for harassment or discrimination and will be strong allies to under-represented groups.
Our policies on fair recruitment, employment of young people, hours of work, diversity, and inclusion, and working with suppliers, include robust provisions to tackle issues relating to modern slavery. All our employees around the world have access to a wellbeing resources that includes mental health support.
As a responsible business we have the following formal polices and employee engagement and grievance mechanisms in place:
Workplace Violence policy
Global anti-corruption policy
Employment of young workers policy
Code of Business Conduct & Ethics
Conflict of Interest policy
We strive to ensure our employees are aware of specific local risks relating to modern slavery and more general risks. The Natura &Co 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, online or via a 24/7 telephone service available in 23 languages.
In 2023, we plan to launch a holding-wide Supplier Grievance Guide that will be used internally to manage grievances from our suppliers' employees and will communicate the grievance mechanisms available to them. This will allow workers in our supply chains and operations to report any breaches of human rights violations and modern slavery risks to Natura &Co.
In addition to the policies listed above, there are also established processes and procedures to allow associates to give feedback on the company’s operations and raise any concerns or grievances they may have:
- Country and market-specific employee engagement forums; for example, the Have Your Say forum in the UK
- Regular employee ‘pulse’ surveys in key markets, building on a company-wide survey (Glint)
- New associate ‘lifecycle’ surveys and check-ins – conducted with new associates after 30 days, 90 days and 12 months of joining Avon.
Our Due Diligence Approach
Rather than just resolve any potential labour exploitation identified in Avon operations and supply chains, we aim to prevent all forms of exploitation and ensure that all workers enjoy decent working conditions.
Avon is committed to supporting suppliers and their factories to improve working conditions in their production sites and supply chains. The Responsible Procurement team works directly with suppliers and factories to ensure that they build capacity and demonstrate compliance with the requirements of Responsible Procurement Programme .
We expect all Suppliers to act responsibly and to ensure that no abusive, exploitative, or illegal conditions exist in their workplaces. These expectations also apply to our suppliers’ supply chains,and we ask our suppliers to ensure that our Code of Conduct and the requirements of our Responsible Procurement programme are cascaded and communicated to our suppliers’ supply chains.
The first step in this process is carefully selecting new suppliers and committing them to our high labour standards. We work collaboratively with our suppliers, to strengthen their understanding, capacity, and systems to prevent, uncover and resolve any issues relating to modern slavery.
If we identify any areas of concern through our supplier audits, we immediately work with our suppliers and sometimes also independent specialists to address them. Where necessary, we support suppliers to develop and implement a Corrective Action Plan to do this. These issues can span multiple indirect suppliers so addressing them can be a complex, years-long process involving considerable time and resources.
If a supplier fails to remedy any non-compliance despite our intervention and support, we terminate that supplier relationship in a responsible way.
Anyone working in our operations or supply chains can anonymously report any labour concerns to the free Natura &Co Ethics Line. Professionals from the Ethics & Compliance investigations team triage any reported breaches and allocate to the relevant teams for investigation and remediation.
Our minimum expectations apply for all suppliers of goods or services in the Natura &Co Global Supplier Code of Conduct. The terms of the Natura &Co Global Supplier Code of Conduct prohibit:
- The use of any form of forced labour – including prison, bonded and indentured labour
- Any engagement in, or support for human trafficking.
The Supplier Code of Conduct forms part of our contractual agreements with all suppliers and acceptance of these terms is a pre-requisite of working with Avon and our sister brands.
Avon requires regular ethical audits on factories that are in scope of our Responsible Procurement Programme . Factories that are in-scope include:
- Avon branded or non-branded finished products for re-sale
- Avon branded Beauty product components
- Selected Avon branded goods not for re-sale
The Avon ethical standards that all in-scope factories are audited against are as follows:
Laws and Regulations
Wages and Benefits
Hours of work
Health and Safety
Freedom of Association and Collective Bargaining
Monitoring and Compliance
As part of our ongoing commitment to working with suppliers and factories that share the Avon values of honesty and integrity, and respecting workers’ rights, we aim to ensure full audits are conducted at all in-scope factories every two years. Our auditing process is a vital due diligence tool as it helps our suppliers and their factories understand their responsibility to comply with our ethical standards and to combat any human rights abuses that are found.
Overall, in 2022, 122 audits were completed in 22 countries. This includes Avon social audits, carried out by our appointed third-party auditing agency – Bureau Veritas, as well as other robust third-party audits that we accepted in lieu of Avon social audits, such as those conducted by SMETA or BSCI (which can be shared with other selling companies).
This year we have onboarded 300 more factories to Sedex, a responsible sourcing online platform that helps us achieve better supply chain transparency in real time, to be able to manage and improve working conditions in our supply chain, making a total of 872 suppliers and 1,045 factories onboarded in total. We will continue to work with our suppliers and factories to improve supply chain transparency in 2023.
Natura &Co is a sponsor of the Responsible Recruitment Toolkit (RRT), which supports businesses in our supply chain to embed ethical and professional recruitment and labour supply practices. Through the RRT, suppliers can access a wide range of responsible recruitment guidance, resources, training, and self-assessment tool.
We joined this initiative as a sponsor in recognition of the identified risks of modern slavery and labour exploitation, particularly in relation to recruitment and the supply of temporary, contract and seasonal labour. We ran two introductory webinars to the toolkit in 2022, starting with the pilot phase with labour providers supplying directly to our distribution centres in Europe, Middle East, and Africa (EMEA). We will continue to engage more labour providers throughout 2023 to ensure all workers in our own operations are recruited lawfully, and in a fair transparent manner that respects and protects their rights.
Modern Slavery Risk Assessment and Management
In 2022 we found no new direct evidence of modern slavery in our operations or supply chains. However, modern slavery is often hidden and some of our supply chains are complex and not fully transparent beyond tier 2, so we are not complacentto expect that global supply chains are modern slavery-free.
We know that several commodities, sectors, and regions pose high risks of potential labour exploitation in our operations and supply chains. In 2023 we will continue to map our key risk areas as a group and to develop due diligence processes to mitigate against modern slavery risks further down our supply chains. Our Enterprise Risk Management Team has begun work to map and prioritise salient risks, which highlights target areas further down our supply chains where forced and child labour tend to be present. This will be an area of focus for us in 2023 and beyond.
In our last Modern Slavery statement, we reported that we had identified that foreign migrant workers had paid recruitment fees to agencies in order to ensure work in their factories producing for Avon in Taiwan. Workers from the Philippines, Indonesia, Vietnam and Thailand were employed by the three suppliers through multiple Taiwanese labour agencies, which were then connected with labour agencies in the migrant workers’ home countries. Taiwanese employers often have no oversight or knowledge of the recruitment practices of agents based in the sending/home countries and local agents’ practices in Taiwan. Some workers indicated that they had borrowed money from lending agents in their home country and worked with informal sub-agents to obtain the jobs. We also identified that one supplier held custody of workers’ passports and savings passbooks.
We recognise that the risks of modern slavery for workers are not well known and not well- communicated in Taiwan, and we enlisted the help of a specialist consultant in-country to work with our local suppliers to better understand the modern slavery risks specific to the region. The specialist consultancy drafted Recommendation Guidelines to help facilitate remediating the existing problems and repayment plans.
Going forward we are requiring new suppliers to refund the total overcharged costs to affected workers and to ensure that no fees are charged to migrant workers in their recruitment, hiring, and placement processes. We also advised them to partner with labor recruitment service providers that are committed to the zero-payment policy - ensuring no fees are required from workers to secure employment.
In addition, to mitigate future risks, we are working with suppliers to implement the below in their recruitment process:
- Establish a mechanism for monitoring the recruitment and hiring procedures and practices of all recruitment agents to verify their compliance with the facility policies, laws and regulations;
- Ensure all HR-related staff fully understand regulations related to the employment of foreign workers;
- Ensure relevant staff members possess sufficient knowledge of the recruitment practices of the sending country agents and local agents in Taiwan, including but not limited to:
- the recruitment, selection, and hiring processes
- profiles and contact information of the sending country labour agencies (even if the company does not have any formal relationship)
We will continue to embed new group-wide policies and Human Rights Due Diligence processes into our procurement decision-making. Our new smart due diligence monitoring system that flags risks will enable us to target resources effectively. We will prioritise action to maximise our positive impact, such as sectors or areas with a high number of vulnerable workers.
Avon will continue to work on mapping salient human rights risks in the lower tiers of our supply chains and operations , working collaboratively with internal stakeholders and suppliers.
We will prioritise training and awareness buildingfor associates to highlight the risk of modern slavery in our global markets.
Avon will continue to seek opportunities to collaborate and participate with other brands, retailers and stakeholders on tackling common modern slavery and human rights risks .
Angela Cretu, Chief Executive Officer, Avon
Approval of Statement
This statement has been approved by the Board of Directors of Avon Products, Inc. approved and signed by our CEO Ms Angela Cretu on 21st June 2023