Huel Human Rights Policy

About This Policy

Huel is committed to acting ethically and with integrity in every aspect of our business and to respecting the human rights of our employees, customers, workers in our supply chains, and the wider communities connected to our activities. Human rights are the basic rights and freedoms to which all people are entitled, grounded in dignity, equality, fairness, and respect.

We respect all internationally recognised human rights, as set out in the International Bill of Human Rights and the International Labour Organization’s (ILO) core conventions, and are committed to upholding these standards across our operations and value chain.

To support this commitment, we operate an ongoing human rights due diligence process to identify, assess and address both actual and potential adverse human rights impacts arising from our operations, products and services, and business relationships.

This policy is guided by the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the Ten Principles of the UN Global Compact. This includes alignment with the International Bill of Human Rights and the principles set out in the International Labour Organization’s Declaration on the Fundamental Principles and Rights at Work. Our approach to labour standards in supply chains is informed by the Ethical Trading Initiative (ETI) Base Code, which is grounded in International Labour Organization’s conventions.

This policy applies to Huel’s own operations and extends across our value chain, including suppliers, contractors and business partners. It is reflected in our Supplier Code of Conduct, which sets out the human rights expectations for those we work with.

Our Human Rights Commitments and Salient Issues

Huel regularly reviews and assesses human rights risks through our due diligence processes, drawing on internal analysis and engagement with relevant stakeholders. We conducted a saliency assessment to identify the human rights issues most salient to our business, based on the severity and likelihood of impacts on people.

The most salient human rights risks identified are:

  • Forced labour and human trafficking in global supply chains
  • Child labour risks in agricultural supply chains
  • Safe and healthy working conditions within manufacturing and supply chain operations
  • Freedom of association and collective bargaining for workers across our value chain
  • Fair remuneration and decent working conditions, including responsible working hours

These issues were prioritised based on their severity and likelihood of impact, particularly within agricultural and labour-intensive supply chains.

Huel respects all internationally recognised human rights. The commitments set out below reflect our broader human rights framework and apply across our operations and value chain. While the rights outlined below are all relevant to our business, we prioritise action and resources in line with the salient risks identified through our human rights due diligence process.

Expectations for Business Partners

Huel expects our suppliers and business partners to respect and uphold the human rights set out in this policy within their own operations and supply chains.

Suppliers must comply with applicable national laws and regulations. Where national law and this Human Rights Policy differ, Huel expects suppliers to adhere to the higher standard.

Where national law conflicts with internationally recognised human rights standards, we expect suppliers to seek ways to uphold the principles of international human rights to the greatest extent possible without violating local law.

Right to Freedom of Association and Collective Bargaining

Huel respects the right of workers to join, form, or not to join trade unions and to bargain collectively without fear of reprisal, intimidation, or harassment. Where workers are represented by a legally recognised union, we engage in constructive dialogue with freely chosen representatives and bargain in good faith.

Right to Equality at Work and Freedom from Discrimination, Harassment and Violence

Huel is committed to equality at work and to preventing all forms of discrimination, harassment, and violence. Discrimination refers to any distinction, exclusion, or preference that undermines equality of opportunity or treatment in employment or occupation, as defined by relevant International Labour Organization (ILO) Conventions.

Huel prohibits discrimination based on any actual or perceived characteristic, including race, colour, ethnic or national origin, age, religion, sex, sexual orientation, pregnancy or related medical conditions, gender identity or expression, nationality, immigration status, citizenship or ancestry, caste or descent, physical or mental ability, or any other basis prohibited by law. Harassment or violence of any kind is not tolerated.

This applies across all stages of employment, including recruitment and hiring, wages and benefits, training, promotion, discipline, grievance handling, termination, retirement, and access to opportunities.

Huel is committed to protecting all workers from discrimination, including permanent and temporary workers, agency workers, apprentices and trainees, probationary workers, migrant workers, and foreign contract workers. We explicitly prohibit asking job applicants about pregnancy status or conducting pregnancy testing as a condition of hiring, continued employment, or promotion.

We recognise that discrimination and gender inequality can increase the risk of child labour and forced labour, particularly for women, girls, migrant workers, and other vulnerable groups. Our human rights due diligence considers how such risks may disproportionately affect certain groups when assessing and prioritising impacts.

Right to Safe and Healthy Working Conditions

Huel is committed to providing a safe and healthy working environment and to complying with applicable occupational health and safety laws. We work to minimise the risk of accidents, injury, and exposure to health hazards and to continuously improve workplace safety through hazard identification, remediation, and worker engagement.

This includes implementing risk assessments, clear procedures and controls, training, incident reporting and investigation, and providing appropriate personal protective equipment (PPE) where required.

Right to Just and Favourable Remuneration and Decent Work

Huel is committed to providing fair and favourable remuneration and to respecting the right to decent work. We comply with applicable laws relating to wages, working hours, overtime, rest periods, and benefits.

Huel compensates employees competitively in relation to the industry and local labour market. We regularly review Living Wage benchmarks and adjust pay through our annual pay review process to support fair compensation.

We recognise the right to rest and leisure, including paid leave, reasonable working hours, and the right to family life. We support a healthy balance between working and private life and comply with local laws and regulations relating to working hours, overtime, and rest.

As a buyer, we conduct our sourcing and procurement practices responsibly and seek to avoid contributing to adverse impacts on workers’ rights to fair compensation and decent working conditions. We take steps to ensure our purchasing practices do not undermine suppliers’ ability to comply with labour standards.

Freedom from Forced Labour and Human Trafficking

Huel prohibits all forms of forced labour, human trafficking, and unfair recruitment practices. Forced labour refers to any work or service exacted under threat or penalty and not undertaken voluntarily, in line with International Labour Organization (ILO) standards.

This includes debt bondage, retention of identity documents, restriction of movement, threats, coercion, deception, abuse of vulnerability, and the charging of recruitment fees to workers. Such practices will not be tolerated in any part of our operations or value chain.

Huel complies with applicable labour, employment, and migration laws in the countries where we operate and source.

We recognise that forced labour risks often arise through recruitment and migration practices. We therefore expect recruitment and employment practices within our operations and supply chains to be fair and transparent. This includes clear terms of employment, no recruitment fees charged to workers, written contracts in a language workers understand, protection against deceptive recruitment practices, and access to grievance mechanisms and relevant information to support workers’ rights.

Huel engages with recognised industry standards and multi-stakeholder initiatives aimed at preventing forced labour and improving labour practices in global supply chains.

We expect our suppliers and business partners to uphold these standards and to take appropriate measures to prevent, identify, and address forced labour risks within their operations and supply chains.

Abolition of Child Labour

Huel prohibits the employment of children under the age of 15, or below the legal minimum age for employment or completion of compulsory education, where higher.

We expect our suppliers and business partners to comply with all applicable laws relating to child labour and to apply these requirements consistently within their own operations and supply chains, including beyond Tier 1.

Children under 18 must not perform hazardous work or any work that may harm their physical, mental, or moral well-being. This includes dangerous or unhealthy environments, night work, exposure to abuse, handling hazardous substances or equipment, or involvement in forced labour or trafficking.

Where young workers aged 15 to 18 are legally employed, we ensure that appropriate risk assessments are conducted and that measures are in place to protect their health, safety, and wellbeing.

Huel communicates its expectations clearly to suppliers and works collaboratively to support implementation across the supply chain.

Where child labour is identified in our operations or supply chains, we support remediation that prioritises the best interests of the child, including access to education, and monitor the effectiveness of corrective actions.

Right to a Healthy Environment and Community Health

Environmental practices can affect the health and wellbeing of local communities, particularly within agricultural supply chains. Huel is committed to identifying and addressing potential adverse impacts where environmental activities may affect community health.

Land, Community and Indigenous Peoples’ Rights

Huel respects land rights, community rights, and the rights of Indigenous Peoples. We seek to avoid causing or contributing to adverse impacts related to land acquisition, land use, or community displacement.

Digital Rights and Data Privacy

Huel is committed to respecting digital rights, including privacy and data protection. We handle personal data responsibly and take steps to prevent misuse of digital technologies that could harm individuals.

Right to Health (Customers)

Huel is committed to protecting consumers’ right to health by ensuring that our products are safe, nutritious, and responsibly marketed. We comply with applicable food safety, labelling, and consumer protection laws and regularly assess risks related to product quality and safety.

Our Human Rights Approach and Due Diligence

Huel’s approach to respecting human rights is grounded in ongoing due diligence across our operations and value chain. We identify and address human rights risks by integrating safeguards into our policies, processes, and decision-making, and by reviewing the effectiveness of our actions over time.

We conduct regular country and regional risk assessments using credible public sources to evaluate human rights, labour rights, governance, and related environmental risks. These assessments inform sourcing decisions and determine the level of due diligence applied to different countries, regions, and suppliers.

Responsible Sourcing and Supplier Due Diligence

We apply a risk-based approach to supplier due diligence, focusing on suppliers, ingredients, and sourcing regions associated with higher human rights risks. Findings from this process inform supplier approval, sourcing decisions, and ongoing supplier management.

All suppliers are expected to comply with Huel’s Supplier Code of Conduct and align with internationally recognised labour and human rights standards.

Ethical Audits and Certifications

As part of our due diligence, suppliers are required to hold an internationally recognised, independently verified ethical audit or equivalent assessment aligned with relevant International Labour Organization (ILO) Conventions and covering, at a minimum, labour standards and health and safety. Where available, audits that also address environmental practices and business ethics are preferred.

Audits are renewed regularly. Where non-compliances are identified, suppliers must implement corrective action plans within agreed timelines. Where a supplier does not yet hold an audit and is assessed as lower risk, alternative due diligence measures may apply and a plan for obtaining certification will be agreed.

Supplier Engagement, Monitoring and Continuous Improvement

Effective human rights due diligence goes beyond compliance. Huel works collaboratively with suppliers to support implementation of our human rights expectations, particularly where risks are identified.

We monitor identified risks, non-compliances, and corrective actions and follow up to ensure issues are addressed in a timely manner. Where appropriate, follow-up may include requesting additional information or engaging directly with suppliers, including through on-site engagement. Higher-risk suppliers may be prioritised for enhanced due diligence.

Where Huel has caused or contributed to adverse human rights impacts, we provide for or cooperate in their remediation through legitimate, fair and appropriate processes. Where impacts are directly linked to our operations, products or services through business relationships, we seek to use our leverage to support effective remediation.

We prioritise engagement and remediation and recognise that sustainable improvement is best achieved through partnership.

Accountability and Responsible Procurement Practices

Our purchasing and sourcing practices influence human rights outcomes across our supply chain. Huel is committed to responsible procurement and to ensuring that our commercial decisions do not undermine suppliers’ ability to uphold labour standards.

We integrate human rights considerations into procurement and supplier approval processes and maintain internal procedures to support responsible sourcing and supplier management.

Grievance Mechanism & Resolution Process

Huel is committed to enabling individuals and communities who may be adversely impacted by our operations, products or business relationships to raise concerns and seek resolution in a safe, fair and transparent manner, with clarity on how concerns are assessed, handled and resolved.

We provide a publicly accessible grievance mechanism for stakeholders, including employees, suppliers, workers in our supply chain, customers and affected community members, to raise human rights-related concerns. Grievances may be submitted via our online grievance form. If you are unable to access the online form, you may raise concerns by emailing grievances@huel.com or through existing communication channels, including supplier contacts or customer support, and these will be escalated where appropriate.

Submissions may be made anonymously and in any language. We aim to ensure that this mechanism is accessible and inclusive and will make reasonable adjustments where necessary to support individuals in raising concerns.

Concerns raised through other channels that relate to potential human rights impacts will be directed into this grievance process.

This mechanism is intended for human rights-related concerns connected to Huel’s operations or value chain and does not replace Huel’s internal employee grievance procedure. Employees should continue to use the internal process, managed by the People Team, for employment-related matters. Human rights-related concerns raised internally will be reflected in annual oversight and reporting where appropriate.

This mechanism operates alongside Huel’s existing internal grievance and whistleblowing procedures, which remain available to employees and workers.

Scope of the Mechanism

This grievance mechanism applies to concerns relating to potential human rights impacts connected to Huel’s operations, products or value chain.

Examples may include:

  • Labour rights concerns
  • Health and safety impacts
  • Discrimination or harassment
  • Forced labour or child labour risks
  • Environmental impacts affecting community health

This mechanism is not intended for issues relating solely to product returns, delivery queries or general customer service matters. Such issues should continue to be directed to our customer support channels. Where a submission falls outside the scope of this mechanism, the individual will be informed and, where appropriate, redirected to the relevant channel.

What This Mechanism Cannot Do

This mechanism:

  • Does not replace emergency services where there is immediate risk to life or safety.
  • Does not replace Huel’s internal employee grievance procedures.
  • Does not provide legal advice.
  • Is not intended for general product or customer service complaints.

Process and Timelines

Upon receipt of a grievance:

  1. The grievance will be acknowledged within 7 working days.
  2. An initial assessment will determine whether the matter falls within the scope of this mechanism.
  3. Where accepted, the grievance will be escalated to the appropriate internal function for investigation and response, taking into account any confidentiality concerns raised and avoiding conflicts of interest. The individual will be informed of the proposed next steps where appropriate.
  4. Huel will seek to investigate and respond within 28 days, or communicate if additional time is required. Where a grievance indicates an immediate risk to life or safety, it will be escalated without delay. Individuals who believe they are in immediate danger should contact local emergency services.

Where contact details are provided, we will seek to maintain appropriate communication throughout the process, inform the individual of next steps where appropriate, and confirm when the grievance has been resolved or closed.

Escalation will involve relevant functional leaders depending on the nature, severity and likelihood of the grievance, and significant or material matters will be reported to senior leadership where appropriate.

Protection from Retaliation

Huel will not retaliate against any individual who raises a concern in good faith and does not tolerate any form of retaliation, intimidation or harassment related to the submission of a grievance. Any such behaviour will be treated as a serious matter and addressed through appropriate disciplinary processes.

Fairness and Conflict of Interest

Grievances will be handled impartially and in accordance with Huel’s governance procedures. Where a grievance involves an individual responsible for managing the mechanism, or where a potential conflict of interest arises, the matter will be escalated to an appropriate senior leader to ensure an independent and objective review.

Tracking, Oversight and Reporting

All grievances received under this mechanism are logged and tracked in a secure system.

Huel conducts an annual review of grievances to analyse their number, nature and status, identify trends or recurring issues, assess the effectiveness of the mechanism and determine any necessary improvements. A summary of this review is provided to Huel’s Board.

In addition, Huel reviews significant human rights-related concerns identified across relevant internal and external channels to ensure appropriate governance oversight.

Huel publicly reports high-level information on grievance activity and outcomes in line with applicable standards. Where remediation is required, it will be addressed in line with the commitments set out in this policy.

Governance

This Human Rights Policy has been approved by Huel’s Board of Directors, which holds ultimate responsibility for oversight of human rights matters. The Board provides strategic oversight of Huel’s approach to human rights.

Day-to-day responsibility for implementation sits with the Senior Sustainability Manager, supported by the Senior Leadership Team and relevant Team Leads across the business.

The Board Audit Committee reviews progress in relation to human rights annually to ensure continued alignment with Huel’s commitments and relevant international standards.

This policy is publicly available on Huel’s website and is communicated to suppliers and relevant stakeholders through our Supplier Code of Conduct and related processes.

Policy ownerSenior Sustainability Manager
Policy coversAll legal entities
Date of last reviewFebruary 2026
Approved byBoard of Directors on 21st April 2026