Avon Modern Slavery Statement 2023


This is Avon’s eighth 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 2023 and ending 31 st December 2023. Our 2022 Modern Slavery Statement can be found here.

Sustainability forms part of our core business strategy and key performance indicators, and we educate and engage our colleagues and suppliers in ways to integrate sustainability into all business activities. For Avon, sustainability means supporting the wellbeing of both people and planet in everything we do.

We are a responsible business and are committed to respecting human rights and ensuring there are no forms of modern slavery or 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.

Creating a better world for women and for all involves protecting the human rights of people throughout our business and our supply chain. This includes our associates, Representatives and everyone working in our distribution centres and manufacturing sites, even if they’re not directly employed by us. We have a robust Human Rights statement which reinforces our pledge to respect and defend Human Rights, as defined by the UN Guiding Principles on Business and Human Rights. In 2024, we’ll be building on this further as we embark on the next phase of work to advance processes to identify, prevent and mitigate human rights risks across our supply chain and operations.

Our Business

Responsible Business – More than a beauty company

At Avon, we believe in a better world for women, which is a better world for all. Avon has been helping women to transform their lives since 1886. We offer our independent Representatives – almost all women – flexible earning opportunities. Avon has stood for women, providing innovative and high-quality beauty products, which are primarily sold towomen, 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.

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.

Our Sustainability Steering Committee, which includes our Head of Sustainability and a representative from the Enabling Leadership Team, leads on our sustainability strategy, supported by our central Sustainability team.

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 review and strengthen our own due diligence processes.

Our Organizational Structures

Avon is a global manufacturer and retailer serving 2 million active independent Representatives. Avon has three of its own global manufacturing hubs across Europe and Asia. Avon provides innovative, quality products to customers at irresistible value. 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 5,000 employees worldwide, of which 66% of our workforce is made up of women, with 49% in managerial positions.

Our Supply Chains

Avon International has over 16,500 direct and indirect suppliers. 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 policies and framework integrate modern slavery concerns in our employment, purchasing and sourcing practices.

Human Rights Statement

What we stand for: In 2020, we launched our 2030 sustainability goals, 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.

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 and the UN Women’s Empowerment Principles.

We will embed these commitments 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.

We also 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.

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.

To read the Human Rights statement in full click here .

Avon employment policies and employee resources

Avon aims to be a fair and decent employer and continue to foster an inclusive culture.

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. We support people by providing a diverse and equitable working culture, paying at least the Living Wage, protecting human rights throughout our business and value chain and championing women’s wellbeing. In 2023, all our associates were paid at least the Living Wage and 48.7% of our senior leaders were women (2022: 51.7%). We work to maintain a 50% female leadership. We’re proud to have no unexplained gender pay gap.

As a responsible business we have the following formal polices and employee engagement and grievance mechanisms in place:

  • Workplace Violence policy
  • Gender Based Violence policy and programme
  • 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 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 including reports about modern slavery or related indicators:

  • 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 Supplier Code of Conduct

All new Avon suppliers must commit to our Supplier Code of conduct before we enter a commercial relationship with them. This policy is based on the UN Universal Declaration of Human Rights, the UN Global Compact, and the Ethical Trading Initiative (ETI) Based Code. The code 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 terms of the 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.

Our code of conduct includes broader human rights expectations and reference to access to remedy and grievance mechanisms, a key focus for us in 2024 to ensure that voices of those working in our supply chain are heard. 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.

Our Critical Materials Policies

We have identified six materials that Avon uses (palm, cotton, mica, soya, paper and ethanol) as having high human rights and environmental risks (see table below).

To ensure these Avon ingredients and materials do not cause harm, including the risk of forced labour, we have developed critical material policies which set clear standards on traceability (where they come from) and require certification that their production meets specific international standards which include the prohibition of forced labour. We are pursuing full traceability and/or certification of these six critical materials.

In 2023, we made good progress on meeting our traceability targets – we achieved between 89%-100% traceability across our critical materials and sourced 92% of our palm oil and 84% of our paper as certified. We continued to participate in collaborative initiatives such as the Action on Sustainable Derivatives (more details below) and Sustainable Palm Index for palm, and the development and implementation of Responsible Workplace Standard for mica processors in high risk sourcing regions to assure good social standards. We are on track for full delivery of the commitment to full traceability and certification across all 6 critical materials.


In addition, as members of Action for Sustainable Derivatives , we are actively collaborating with other companies on an efficient and effective approach to monitor and respond to grievances about environmental and human rights violations linked to palm production in complex, shared supply chains. Avon has supported ASD to develop its grievance methodology to identify, prioritize and respond to palm supply chain grievances, coordinating approaches with key stakeholders and expert partners. Building on these systems, Avon continuously monitors our own supply chain-related grievances and works with relevant suppliers to ensure that they are being addressed.


Responsible Procurement Programme

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 .

This programme enables us to identify issues, manage risks and improve working conditions and labour rights in our supply chains by collaborating with key subject matter stakeholders including SEDEX, the responsible sourcing data sharing platform.

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 a pre-screen risk assessment using the RADAR tool via the Sedex platform to ensure that new suppliers are carefully selected and meet our standards.

Avon requires regular social and environmental compliance audits on factories that are in scope of our Responsible Procurement Programme . Factories and service providers that are in-scope include:

  • Avon branded or non-branded finished products for re-sale
  • Avon branded and non-branded Beauty product components
  • Raw Ingredient manufacturers
  • Labour providers, logistics, warehousing and distribution providers
  • 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
  • Child Labour
  • Forced Labour
  • Harassment
  • Wages and Benefits
  • Hours of work
  • Health and Safety
  • Discrimination
  • Women’s Rights
  • Freedom of Association and Collective Bargaining
  • Environment
  • Subcontracting
  • 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 2023, 123 audits were completed in 23 countries. These were carried out by approved third party auditing companies such as those conducted by SMETA or BSCI (which can be shared with other selling companies).

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.

Additional responsible procurement tools and initiatives

Anyone working in our operations or supply chains can anonymously report any labour concerns to the free Ethics Line. Professionals from the Avon Ethics & Compliance investigations team triage any reported breaches and allocate to the relevant teams for investigation and remediation.

In 2023, Avon was 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.

In 2023, as part of our commitment to training and capacity building towards the elimination of modern slavery, we supported the filming of an educational film on modern slavery risks in the UK by offering our distribution centre in Corby as a filming site. This fictional film dramatized realistic scenarios of labour exploitation and poor labour practices in the UK warehousing sector. Produced by Stronger Together, an organisation set up to tackle modern slavery and labour exploitation in supply chains, the film is available to download for free.

In December 2023, we joined EcoVadis, an ESG rating service and data management platform that provides supplier ratings in scorecards covering environmental, labour and human rights, ethics and sustainable procurement topics. We plan to use the platform to understand the sustainability performance of our suppliers better, and to use the labour and human rights pillar in the EcoVadis platform to monitor our suppliers’ exposure and capacity to deal with cases of modern slavery in their supply chains.

Modern Slavery Risk Assessment and Management

In 2023 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 supply chains. In 2024 we will continue to map our key risk areas and to strengthen due diligence processes to mitigate against modern slavery risks further upstream in our supply chains. This will be an area of focus for us in 2024 and beyond.

In our last two Modern Slavery statements, we reported that we identified foreign migrant workers had paid recruitment fees to labour agencies in order to secure work in factories producing for Avon in Taiwan. This remains an ongoing and systemic issue in the region. All new suppliers using third party recruitment providers in the region are required to submit an audit of the labour provider to ensure that no recruitment fees are paid by workers in their recruitment, hiring and placement processes. This will continue to be an area of focus in 2024.

Future steps

We will continue to embed new policies and Human Rights Due Diligence processes into our procurement decision-making. In 2024, we will be undertaking a comprehensive human rights due diligence risk assessment with the help of a specialized third-party consultancy to map the salient human rights risks across our operations and supply chain. We will also undertake further deep-dive investigations on priority human rights issues, such as gender-based violence and responsible recruitment.

We will continue to use Sedex to monitor Human Rights due diligence and modern slavery indicators in our supply chain, as well as utilizing EcoVadis human rights risk assessment capabilities for our supply base.

We plan to develop a supplier grievance mechanism and process that will be used to manage and remediate grievances from our suppliers’ employees. This will enhance access for workers in our supply chains to report any breaches of human rights violations and modern slavery risks.

We will continue training and awareness building for associates to highlight the risk of modern slavery in priority categories.

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.







Approval of Statement

This statement has been approved by the Board of Directors of Avon Products, Inc. approved and signed by our CEO Kristof Neirynck on 27 June 2024.