No Forced Labour Policy

 

POLICY STATEMENT

UP-UP Chocolate (The Company) states that under no circumstances will make use of forced or bonded labour. All employees shall have the right to enter into employment voluntarily and freely, without the threat of a penalty. The policy is applicable to all personnel as well as interns, consultants and any other person performing a task in the company. The Company’s principle of No Forced Labour is based on International Labour Organization (ILO) conventions and national laws and recognises regional and cultural differences.  The Company forbids the use of coercion, violence, threat of penalties, or other intimidating practices like confiscation of personal documents (only copies) or wage punishments (information about wage cuts should be provided in the books). Employees shall have the freedom to terminate employment of indefinite or long duration by means of notice of reasonable length (in accordance with national law or mutual agreement) at any time without penalty. Employees on contracts of fixed duration shall not be required to serve beyond the expiry of their contract. All terms and conditions of service should be specified in employment contracts for which the employees should provide informed consent. The Company recognises the responsibility that it shares with suppliers, sub-contractors, and recruitment services (collectively referred to as “Suppliers”) to tackle forced labour. This policy represents a clear contractual obligation as condition for any business relationship with the Company. The Company will not tolerate the use of unlawful forced labour within and will not accept products or services from suppliers that employ forced labour or apply similar practices.

 

GENERAL PRINCIPLE

Forced labour is work performed under compulsion (including slavery, servitude and forced recruitment) and subject to a penalty. It is, in all its forms, an abuse of fundamental human rights and it is prohibited in all circumstances. It is explicitly banned by four major international human rights agreements: the 1926 Slavery Convention; the 1948 Universal Declaration of Human Rights; the 1956 Supplementary Convention on the Abolition of Slavery, the Slave Trade and Institutions and Practices similar to Slavery; and the 1966 International Covenant on Civil and Political Rights (ICCPR).
“Forced Labour” as presented in the Company’s policy shall refer to all forms of forced labour, including but not limited to: child labour, human trafficking (e.g. derived from migration for employment), involuntary prison labour, coercion in wage payment (including debt bondage and bonded labour), threat of disciplinary measures, compulsory overtime or document retention. 

All labour should be freely chosen and employees should be free to leave in accordance with the employee’s contract. A company should make sure all the employees present themselves voluntarily for work and are free to leave. 

 

IMPLEMENTATION

The Company shall implement this policy through clear workplace communication, training, and leadership accountability. Management is responsible for compliance in their departments, and all staff should remain vigilant for signs of forced labour.

As part of its commitment to external accountability, UP-UP has engaged Impactt, an independent ethical trade consultancy, to conduct third-party verification of its supply chain. In February 2025, Impactt conducted a full-scope, unannounced audit of UP-UP’s cocoa production in Villanueva estate in Colombia and confirmed full compliance with international standards on forced labour.

The Company has appointed a designated focal point to receive reports and complaints confidentially. Reports may be investigated internally or with external support. No retaliation will be tolerated.

 

PREVENTION

Employment contracts will be written in a language understood by the employee and will clearly outline all employment terms: wages, hours, responsibilities, and lawful termination rights.

Suppliers must adhere to UP-UP’s Supplier Code of Conduct, which prohibits any form of forced or bonded labour. Supplier compliance may be audited by the Company or by Impactt as part of UP-UP's independent verification protocol.

 

REPORTING FORCED LABOUR

All the company staff members are encouraged to report any case of non-compliance with the policy. The employees should be aware that they have a moral and ethical duty to report such instances and should not fear retaliation. The Company recognises the importance of confidentiality and could grant anonymity to the complainants who wish so, giving that such information does not impede the investigation or resolution of the dispute. There should be no limitation to the filing of complaints, in terms of accessibility to all employees and quantity. The Company will make sure that the employees know where and to whom they can refer for denounces or complaints. The Company ensures that appropriate measures and punishment will be applied in case of non-compliance with such policy.

 

MONITORING

UP-UP may perform internal audits and initiatives to maintain vigilance. Additionally, independent audits conducted by Impactt will periodically assess supply chain conditions to verify the continued absence of forced labour.

All concerns will be addressed promptly and appropriately.

 

REMEDIATION AND PUNISHMENT

Violations of this policy may result in disciplinary action, up to and including contract termination. Investigations will comply with all applicable local laws and due process.

In the event of non-compliance identified through Impactt’s third-party audit or internal mechanisms, UP-UP will take immediate steps to correct the issue and provide remediation to affected individuals. Corrective action may include contractual changes, workforce support, or the removal of offending suppliers.

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¹ Company principles should be based on the ILO Convention (No. 29) concerning Forced Labour, and on the ILO Convention (No. 105) concerning the Abolition of Forced Labour

² THE HUMAN RIGHTS AND BUSINESS PAGES, Amnesty International 2006