Huel’s Modern Slavery Statement 2024

Introduction

The Modern Slavery Act 2015 (the ‘Act’) requires each business with an annual turnover of over £36m to publish a transparency statement which sets out the steps they have taken to ensure there is no modern slavery in their own business and in their supply chains. This statement is made pursuant to the Act.

Huel’s mission is to improve the health of people and the planet through complete and convenient nutrition. We strive to act ethically and with integrity in all aspects of our business. We take a zero-tolerance approach to any instance of modern slavery within our business and supply chains, and we expect organisations with whom we do business to adopt and enforce policies that comply with the Modern Slavery Act 2015.

We are fully committed to compliance with the Modern Slavery Act 2015 and recognise the importance of taking all necessary action to combat modern slavery in all its forms including slavery, servitude, forced and compulsory labour and human trafficking. 

This statement relates to Huel Limited and its supply chains.

Business Structure

Huel creates and sells nutritionally complete food products and supplements, including powders, instant savoury meals, ready-to-drink products, bars, greens powders and vitamin drinks. We sell our products online directly to consumers and through retail partners and marketplaces, with our largest markets being the UK, US and Europe.

Our ingredients are sourced from around the world, and our products are manufactured and packaged primarily in the UK, US and Europe, with additional production in Japan starting in 2026.

We work with external partners to source our ingredients and manufacture our finished products, which means that we don’t own the farms that grow the ingredients for our products, or the factories that blend and package them. 

Our global headquarters are in Tring, UK, with additional offices in Birmingham, London and New York, and a remote team based in Germany. In 2024 we opened a production facility and office located in Milton Keynes, UK. Our dry products (powder and meal packs) are produced at this site. At the end of our most recent financial year (ended 31st July 2025), we employed 351 people globally.

Supply chain

Our products are composed of plant-derived ingredients, primarily in the form of powders and liquids, which are sourced globally either directly from suppliers or via approved agents and distributors. Our key source countries for ingredients are the UK, Europe, China and the US. Our primary and secondary packaging is sourced from the UK, Europe, and US. Packaging materials include paper, cardboard, aluminium cans and plastic. Product manufacturing is carried out by selected third-party manufacturing partners, chosen based on proximity to distribution centres, manufacturing capability, quality standards and available capacity.

Our direct and indirect supply chains include services that are not specifically used in our products but support the operation of our business such as marketing agencies, professional advisors, and third-party warehouses. These service providers are located primarily within the countries where our offices are located but can extend globally for any specialist items or service which cannot be obtained domestically.

Internal Policies

This policy applies to all persons working for us or on our behalf in any capacity.

At Huel we want to provide our employees with a safe and fair working environment that protects their human rights. 

We currently have the following measures in place:

• Right to work checks are conducted for all potential employees in accordance with relevant legislation, with a minimum working age of 18 years;
• Employee contracts to protect fundamental rights in the workplace;
• Market-related pay and rewards are reviewed annually;
• Huel Culture Handbook which describes our preferred way of working, doing business in a fair way, and treating each other and those we work with outside of Huel with honesty and respect;
• Working at Huel Handbook which includes a commitment to equal opportunities, a safe working environment that is free from discrimination and a whistleblowing procedure for employees if they see anything that they think goes against our expected ways of working;
• All new employees are provided with access to the Culture and Working at Huel handbooks via internal onboarding channels;
• Huel will occasionally use internally approved recruitment agencies, in which case the agency is expected to adhere to the policies outlined in the Working at Huel Handbook;
• We also ask our employees to support our commitment to combat modern slavery. All new employees complete training modules on modern slavery, human trafficking and whistleblowing;
• Employees involved in procurement activities receive additional ethical sourcing training for a deeper level of understanding, and to understand the tools used by Huel to prevent slavery and human trafficking in our supply chain;
• To protect contracted staff, the agencies we work with must comply with the Modern Slavery Act 2015. They must also ensure the following are in place: 
  • Availability of correct paperwork in relation to right to work in the UK 
  • Legal documentation, e.g. passport / evidence of proof of ID
  • Formal written contracts with workers 
  • Agency workers are paid directly into their chosen bank account

Due Diligence

The biggest risk of slavery and human trafficking exists within our global ingredient supply chain, and as such we have focused our efforts in these areas. We undertake the following actions within our supplier approval process to prevent slavery and human trafficking in our supply chain:

• Huel undertakes an annual country risk assessment to identify the likely level of risk of both modern slavery and other human rights issues across potential ingredient sourcing countries. This assessment is used to prioritise enhanced due diligence in higher-risk locations and inform investigation and certification requirements before sourcing from a new supplier. The assessment draws on a range of publicly available data sources and risk indices;
• All suppliers must sign the Huel Supplier Code of Conduct. This specifies Huel’s requirements with regard to the protection of human rights and the environment. Failure to adhere to the Code may result in termination of the supply arrangement;
• All suppliers are required to hold an internationally recognised, independently verified ethical audit at the time of supply to Huel or for suppliers with a lower risk profile within 6-12 months of the commencement of supply. Any indicators of risk identified through audits are followed up as appropriate and may include requests for further information, site visits, corrective action plans or additional independent audits;
• Suppliers without an ethical audit at the time of supply are required to complete a Self-Assessment Questionnaire indicating their approach to the protection of human rights and against modern slavery within their organisation. The response to this questionnaire informs our decision as to whether to proceed in establishing a sourcing relationship;
• Huel are members of the Supplier Ethical Data Exchange (Sedex) and we use the information available via this platform to assist in identifying and managing risk within both our existing and prospective ingredient suppliers

Performance 2024/25

Our primary measure of performance, and the main way we assess the effectiveness of our approach, is the number of our suppliers that hold an internationally recognised, independently verified ethical certification. We typically require an ethical certification at the point of ingredient processing (or the point of greatest risk) in our supply chain, regardless of the point where the commercial relationship is held.  

At the end of our financial year 2024/25, 94% of our ingredient volume and 93% of our ingredient purchasing spend was from suppliers that held an independently verified, internationally recognised, ethical certification. Our goal for the end of the financial year 2025/26 is to achieve 95% for our volume indicator and maintain the spend indicator above 90%.

Looking Ahead: Our Priorities for 2025/26

In 2026 we will continue to work with our suppliers to improve their performance, and to utilise risk ratings for modern slavery and human trafficking for all our sourcing. 

• Complete a Human Rights Saliency Assessment to further our understanding of the likelihood and severity of risks in our supply chain
• Extend our requirement for ethical certifications or an equivalent to our manufacturing, logistics and packaging suppliers
• Refresh internal training for employees most likely to be exposed to modern slavery and human rights risks
• Conduct a SMETA audit at our own manufacturing site

Thanks

Thanks for reading, we hope that you have found this statement useful.  At Huel we take our mission very seriously and our compliance to the Modern Slavery Act is an integral part of our commitment.

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 July 2025.

This statement was approved by the Huel Limited Board of Directors.

James McMaster - CEO, Huel Limited

24 February 2026