Modern Slavery Policy
Whittaker’s makes chocolate in New Zealand for Whittaker’s Chocolate Lovers here and around the world. As a family-owned business with a strong commitment to ethical business practices, we recognise the importance of addressing the risks of modern slavery in global supply chains, especially the cocoa supply chain. In this context, while there is currently no mandatory requirement for us to do so, we have published a Modern Slavery Policy, which includes a commitment to this voluntary annual reporting against our policy.
Whittaker’s is committed to doing business in a way that respects human rights and is compliant with all local and international laws, and UN conventions on human rights. We oppose all forms of modern slavery and commit to progressively taking active steps to minimise the risk, to the extent possible, of modern slavery occurring in our direct operations, supply chain or any other business relationship we have.
Operations and supply chain
Whittaker’s makes all of our world class chocolate at our one factory in Porirua, New Zealand using high quality ingredients from here and around the world. As well as the domestic market, Whittaker’s exports to customers in Australia, South East Asia, North America, the South Pacific, and China.
Our supply chain includes domestic service providers and suppliers of ingredients, including NZ milk products, and suppliers of key ingredients from around the globe, including West Africa, Asia, USA, India, Europe, the Middle East, the Pacific Islands and Australia.
We only source cocoa beans from three Rainforest Alliance-certified cocoa cooperatives in Ghana and from a cocoa cooperative in Samoa called Savai’i Koko that we have a close, direct relationship with through our Whittaker’s Cocoa Improvement Programme there (to provide practical support as well as commercial certainty).
Key risks in our supply chain and operations
The biggest risks are in the global cocoa supply chain, which we depend on to make our products. For this reason, addressing modern slavery risks within our cocoa supply chain is our top priority. However, we are committed to taking steps progressively to identify, assess and mitigate any modern slavery risks within our wider supply chain beyond cocoa. In this context, we conduct ongoing assessment of our supply chain risks by taking into account:
- The risk profile of individual countries based on the Global Slavery Index
- The business services provided by the suppliers
- The presence of vulnerable demographic groups
- New Zealand Plan of Action against Forced Labour, People Trafficking & Slavery 2020-2025.
Contractual controls with suppliers
Our supplier selection and onboarding procedure includes conducting full due diligence on the supplier's reputation, respect for all the relevant laws within their jurisdiction, and compliance with health, safety and environmental standards (with efforts to go beyond compliance actively encouraged). We also conduct due diligence on existing suppliers at regular intervals.
Our contracts with smaller local suppliers require the supplier to work through their supply chain to identify, assess, prevent and mitigate modern slavery within their supply chain. The supplier must, on request, supply us with any information to enable us to assess any risks for ourselves. If a supplier is suspected of breaching this agreement, we will complete a risk assessment on the issue(s) found and ideally work in conjunction with the supplier to remedy any issue found or terminate the contract. For larger suppliers, we are in the process of developing an even more in-depth contractual agreement in line with global best practice.
For our part, we hold ourselves to a Procurement Code of Conduct to guide how we operate with our suppliers to meet our own compliance obligations and our broader expectations of ourselves to treat our suppliers fairly.
Actions we have taken in the past reporting year to assess and address the risk of modern slavery
- Achieved full traceability of all the cocoa beans used to make our chocolate, well ahead of our commitment under international agreements to achieve this by 2025. Full traceability enables us to trace the cocoa beans that we use right down to farm level, which gives us much more transparency over ensuring those cocoa beans are produced ethically and sustainably.
- Developed a supplier risk matrix, which considers not only commercial & operational risks, but also the risk of modern slavery and other social and environmental risks.
- Developed new contracts for major global suppliers that include more in-depth requirements to assesses, identify and take action to mitigate any modern slavery risks, which we are beginning to roll out.
- Put a process in place for ongoing supplier audits, targeting the completion of 10 audits per year, prioritised according to the risk matrix we have developed.
- New Service Level Agreement in place with Rainforest Alliance, which provides for them to conduct annual on-the-ground audits in Ghana, including assessment of modern slavery risks.
- Senior members of Whittaker’s team (Co-Chief Operating Office, Matt Whittaker, and Head of Procurement, Michael Tannenbaum) visited its Rainforest Alliance certified cocoa cooperatives in Ghana (November 2023) to see for themselves how policies and processes are being implemented. (A planned visit to our Samoan cocoa cooperative was rescheduled to early 2024). We are targeting at least annual visits to both Ghana and Samoa.
Evaluation and monitoring
Our key partners on-the-ground in Ghana are Rainforest Alliance, which certifies the ethical sourcing of the cocoa beans we buy from three Rainforest Alliance-certified cocoa cooperatives in Ghana; and Agro Eco, which provides practical support to the cooperatives to enhance productivity and ethical business practices.
Rainforest Alliance conducts annual audits of its cocoa cooperatives in Ghana, which are shared with us. Agro Eco provides us with regular updates and reports on not only things relating to the cocoa cooperatives’ performance, but also on environmental and social aspects, such as appropriate labour practices (including ensuring children are in schooling rather than working on cocoa farms, for example).
These reports from Rainforest Alliance and Agro Eco are considered by Whittaker’s Procurement & Quality teams, enabling us to engage with the supplier in question to address any issues of concern before taking further action. Any major issues identified are escalated to Whittaker’s senior management team.
In addition to this, as noted above, we have set ourselves a target of completing 10 supplier audits per year, which includes assessment of their management of modern slavery risks, with a view to working with the supplier to remedy any issue found or face termination of the contract.
Our ongoing plan
Our focus in the short term is the rollout of our supplier audits, targeting 10 per year, as noted above. We will also continue to build on our relationships with our key partners, Rainforest Alliance and Agro Eco, who work with our cocoa farmers on-the-ground in Ghana, and we will continue to build direct relationships with farmers there and in Samoa through regular visits.