Modern Slavery Statement 2024

Introduction

This statement is published in accordance with the UK Modern Slavery Act 2015. It outlines the steps taken by Avon Cosmetics Ltd* to prevent all forms of forced labour and modern slavery in our business and supply chains in the financial year 1 January to 31 December 2024.

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 ensure that we protect our planet, invest in people and make our products more sustainable.

As part of this, we’re 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 good practice, we focus our efforts on sectors that pose relatively high potential 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 our CEO Kristof Neirynck on 20th June 2025.

Our structure, operations and supply chains

Business overview

Avon is a global beauty business. We manufacture and sell high-quality, great value fragrance, skincare, make-up and personal care products. We also sell gifts, accessories, and fashion and home items. Our customers buy our products online, in partner 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 three manufacturing hubs in Europe and Asia. In 2024 we directly employed around 5,000 associates and approximately two million independent Representatives sell our products in their own way to earn a primary or supplementary income.

Business structure and governance

Avon Cosmetics Ltd. is part of Natura, a Brazilian based beauty group. Avon’s CEO and Enabling Leadership Team lead Avon’s operations and governance, with support and scrutiny from Avon-specific ESG and Sustainable Growth and Ethical Business committees.

Avon’s work is 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 us as a business that’s largely run by women, for women customers, 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 source materials from 97 countries and have around 6,000 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.

Key frameworks that guide our approach include the UN Guiding Principles on Business and Human Rights , International Labour Organization declarations and standards, and the Ethical Trading Initiative Base Code .

Risk assessment in our operations and supply chains

In 2024 we commissioned the external consultancy Business for Social Responsibility (BSR) to conduct a comprehensive human rights risk assessment of both our operations and supply chains – going beyond, but including, forced labour and modern slavery.

This assessed our sourcing countries in 21 human rights-focused categories, including child labour, forced labour, gender equality, governance, working conditions, working hours, wages and benefits.

This review found some inherent high human rights risks in our operations and supply chains. It concluded that forced labour is not a high risk in our own manufacturing, distribution, logistics or office-based operations, but that it can be a high risk in some parts of our supply base. The review also found that transparency and traceability is well managed in our tier 1 supply base and in some upstream material supply chains. We’ll act on these findings to strengthen our approach to identifying and managing forced labour and other identified human rights risks, for example by improving our supplier-facing grievance mechanism.

Responsible Procurement Due Diligence Programme

Our Responsible 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.

We expanded the scope of this programme in 2024. It now covers suppliers and subcontractors of products or services in: raw ingredients; packaging; print and paper; contract manufacturing of our fashion, home and cosmetics products; distribution, manufacturing and warehousing; manufacture of uniform for workers in our facilities; and human resources (temporary staff providers).

All in-scope suppliers must ensure that no abusive, exploitative or illegal workplace conditions exist in their operations or supply chains.

Our four-step programme involves:

1. Registration: a questionnaire to determine whether suppliers meet essential criteria, such as compliance with relevant policies.
2. 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.
3. Audits: All suppliers and sites must commission a third-party social and environmental audit every two years, covering decent work, safe working conditions and fair pay among other areas. We prefer Sedex Members Ethical Trade Audit s, but also accept Amfori Business Social Compliance Initiative or Disney International Labor Standards social audits.
4. Monitoring: If audits identify any areas of concern, we work with suppliers and sometimes independent specialists to address them, if necessary, through a corrective action plan. When necessary, we terminate supplier relationships.

In 2024, approved third party auditing companies completed 156 audits in seven high-risk countries. Compliance audits in 2024 did not identify any new evidence of forced labour in our in-scope supply chains.

Over recent years we’ve invested significant effort in investigating cases of some suppliers in Taiwan charging recruitment fees to migrant workers and communicating our policy on this issue. However, this resulted in little apparent change as a result of various factors. In 2024 we took a different approach, reviewing each case with procurement leaders to agree appropriate action. These reviews involved assessing commercial options, our existing contractual agreements, our leverage with suppliers, and the likelihood of us and other businesses influencing positive change. This will be a priority area in 2025 (see section on Next Steps). 

Critical Materials (see Critical Materials Policies section):

We apply more stringent supply chain standards for six ‘critical materials’, which may be associated with heightened social and/or environmental risks. Three of these materials (cotton, mica and palm) have links with labour rights concerns, including forced labour. Our supply chains for these three materials are now almost all fully traceable to the country of origin (see table).

In 2024 we made huge progress in externally verifying our mica supply chain against internationally recognised standards (see case study 2).

• Visiting mica processors and mines in India 
• Reviewing all our mica supply chains in depth against human rights criteria
• Adapting our raw ingredient procurement to source mica only from verified sources and, in India, confirming our future ambition to source only from suppliers committed to paying the Living Wage 
• Contributing to human rights risk assessments of mica supply chains in China, Brazil and Malaysia, and supporting collective audit, as part of the Responsible Mica Initiative

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 help drive up working conditions and labour standards.

As a member of Action for Sustainable Derivatives, in 2024 we continued to support social projects, including an initiative to improve workplace safety and inclusion for women working in Indonesia’s palm industry. In addition, all 20 of our palm suppliers assessed in the Sustainable Palm Indexcomplied with itsstandards, including human rights criteria, and most performed very highly.

During the year, we also joined the Fair Labor Association coalition to promote child protection and decent working conditions for seasonal agricultural workers in the Turkish rose and Egyptian jasmine sectors.

See our Communication and Training section for details of our information sharing and training to benefit other businesses and the External engagement and accreditations section for a list of our salient memberships and affiliations.

Potential/actual incidents of modern slavery

While we identified no new incidents of modern slavery in our supply chains in 2024, we continued to address a previously identified case of foreign migrant workers paying agency recruitment fees to secure work in Taiwanese factories that produce goods for us. We recognise that this practice can leave workers vulnerable to difficulties leaving an employer to whom they owe money (debt bondage).

Our policies

Several policies and frameworks guide our work to prevent and mitigate any form of labour exploitation in our employment, purchasing and sourcing.

In late 2024, Avon-specific versions of several Natura policies and resources were under development for launch in 2025.

Employment practices

We aim to be a fair, decent and inclusive employer. We listen to our associates, including via location-specific forums and surveys, a company-wide annual survey and our onboarding process. All our associates have access to wellbeing resources, including mental health support.

In 2024 we continued to pay all associates at least the Living Wage and our unexplained gender pay gap was less than 1%. We aim to have a 50% female leadership, achieving 47% during the year (plus 1% of non-declared gender).

Employment policies

We make our associates aware of all policies and mechanisms relevant to their role, and general and specific local risks relating to modern slavery.

Our most salient employment issues and grievance mechanisms relate to fair recruitment, employment of young people and hours of work, which are covered by our flexible working policy and The Natura Code of Conduct .This Code of Conductincludes our commitments to, and policies on, diversity, equity and inclusion, working with suppliers, anti-discrimination, harassment and violence, anti-corruption, code of business conduct and ethics, and conflicts of interest, among others. Our website clearly outlines our position on equity and inclusion .

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, online or via a 24/7 telephone service available in multiple languages. Our Ethics & Compliance team allocates any reported breaches to relevant teams for investigation and remediation.

The Natura&Co 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 1 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.

Our Critical Materials policiescover six materials we source that are associated with relatively high potential human rights and/or environmental risks (cotton, mica , palm , soy , paper and ethanol ). To address this, these policies set clear standards on traceability of these supply chains to the country of origin, and require certification that production meets specific international standards – including the prohibition of forced labour.

Our Responsible Procurement Due Diligence Supplier Guidelines outline our responsible procurement processes and procedures, including onboarding, risk assessment, audits, monitoring and compliance.

Communication and training

Internal and external training around forced labour risks is a key part of our modern slavery work.

Our supplier engagement and training around responsible procurement and decent labour standards increased in 2024. We hosted supplier events in Europe and Asia. In the Philippines, over 60 direct suppliers participated in annual refresher training on responsible procurement due diligence. And our Responsible Procurement team visited more supplier sites in China and the Philippines (a raw ingredients distributor and Beauty+ manufacturing sites).

To share best practices with our peers, our Head of Sustainable Procurementhosted a workshop at the 2024 Responsible Sourcing Innovation Forum on how companies can manage forced labour risks in the cotton sector, featuring case studies from our work.

Internally, we conducted training for 105 associates involved in procurement on various forms of modern slavery, where it’s likely to be more prevalent in global supply chains, how to spot possible signs, and how to report any concerns – including via Avon and external channels.

External engagement and accreditations

Action for Sustainable Derivatives

Bonsucro

Business for Social Responsibility

Cascale (formally Sustainable Apparel Coalition)

Cotton made in Africa

Fair Labor Association

Quantis

Responsible Business Forum

Responsible Mica Initiative

Roundtable on Sustainable Palm Oil

Sedex

Sustainable Palm Index

Next steps

In 2025 we will maintain a similar approach to preventing, identifying and remedying all forms of modern slavery.

Our priorities for the year ahead are:

• Review progress on full traceability and/or certification of six critical materials ahead of the delivery date and establish priorities going forward.
• Act on 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.
• Contract a new supplier grievance mechanism to facilitate workers in our supply chain to report any concerns they have.
• Establish a recruitment fees working group to align our company-wide approach and resolve this issue, supported by engagement with suppliers and third-party support where required.
• Conduct responsible procurement training for the wider business.