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The California Transparency in Supply Chains Act

HelloFresh is committed to ensuring the welfare and rights of workers involved in its supply chain. As a socially responsible business, HelloFresh strives to ensure that its products are manufactured and sourced in an environment that respects human rights.

HelloFresh makes the following disclosures pursuant to the California Transparency in Supply Chains Act of 2010, which requires certain companies operating in California to disclose their efforts to eradicate slavery and human trafficking in their product supply chains.
Verification of Requirements for Suppliers
HelloFresh requires its suppliers to represent and warrant that they comply with all applicable laws and its Ethical Trading Policy. This Ethical Trading Policy defines labor practices that HelloFresh deems unacceptable, both within the company and in its supply chains. The Ethical Trading Policy prohibits forced or bonded labor (including any form of modern slavery or human trafficking), child labor, discrimination, harassment, harsh or inhumane treatment, and excessive working hours. It also requires suppliers to provide respect for worker rights, a safe and hygienic workplace, and timely payment of wages.

In addition, HelloFresh conducts supplier audits, described below, in order to verify that its suppliers are complying with these labor standards. HelloFresh may utilize independent third parties to conduct audits when circumstances require.
Supplier Audits

HelloFresh’s internal auditing team annually conducts announced audits of its direct suppliers to evaluate, among other things, their compliance with the company’s anti-slavery and human trafficking standards. Audits consist of written questionnaires; interviews with supervisors and management; reviews of existing third-party audit reports; and exhaustive tours of production facilities, farms, worker accommodation, offices, distribution centers, and storage sites.

HelloFresh also reserves the right to conduct unannounced audits of direct suppliers if there is reason to suspect a serious infringement to its Ethical Trading Policy. Suppliers are expected to fully cooperate with unannounced audits, which includes responding to reasonable requests and providing full access to its facilities. Independent third-party audits may be required, as well.

Suppliers identified in either third-party or HelloFresh internal audits as failing to adhere to the Ethical Trading Policy must complete corrective actions to promptly remediate any violations.

Certification of Supplier Compliance
HelloFresh requires its direct suppliers, as a condition of doing business with the company, to contractually agree to adhere to each and every requirement set forth by the HelloFresh Ethical Trading Policy and applicable anti-slavery and human trafficking laws.
Maintaining Accountability
Non-compliance with HelloFresh’s Ethical Trading Policy can result in corrective action or termination of commercial agreements, depending on the nature of the violations. When corrective action is necessary, HelloFresh works with suppliers to develop corrective action plans that detail clear timescales, responsibilities, and specific actions to achieve compliance. HelloFresh will cease to conduct business with any supplier that fails to agree to or deliver on a corrective action plan to an acceptable standard within the designated time frame, unless and until HelloFresh is satisfied that the supplier has fully committed to the corrective action plan process.
Training to Company Employees
Every member of the HelloFresh Procurement and Food Safety & Quality Departments, which are responsible for supply chain sourcing and auditing, respectively, receives and reviews a copy of the Company’s Ethical Trading Policy. Additionally, all of the Procurement team’s management and staff receive annual training on the Ethical Trading Policy, which includes a discussion about the company’s requirements that its supply chain be free of slavery, human trafficking, and other unlawful and unethical labor practices. These employees are provided with such training so each is better able to identify and report risks associated with unethical or unlawful behavior at any stage in HelloFresh’s supply chain.