Twinings Ovaltine

Twinings Ovaltine has controls and processes in place to assess and manage human and labour rights risks across its global supply chain. The business is committed to embedding the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises into its sourcing, and thereby conducting business with integrity and respecting human and labour rights principles through its Code of Conduct and Human Rights Policy.

Twinings Ovaltine’s due diligence approach includes audit procedures and training to support the implementation of its Code of Conduct and Human Rights Policy. These include its Factory Monitoring and Improvement Programme (‘FMIP’), the Twinings Community Needs Assessment (‘TCNA’) programme and Modern Slavery Awareness training.

FMIP is the due diligence approach for assessing and managing human rights and worker safety across Twinings Ovaltine’s own operations and tier one suppliers, including third-party manufacturers, warehouses, packaging, raw material processors, promotional items and construction services and tier two branded packaging suppliers of third-party manufacturers. It plays a central role in Twinings Ovaltine’s Human Rights and Environmental Due Diligence strategy by helping to identify, assess, prioritise, address and monitor human rights risk.

Each site in scope of FMIP is risk-assessed as high, medium or low, which takes into account country, workforce and labour rights risk. Low and medium-risk sites undergo sample spot checks, while all high-risk sites, defined as those with significant potential for human rights or labour issues, require an audit. All audits are semi-announced, where suppliers are given a two-week window for an audit to be conducted by independent third parties. Twinings Ovaltine uses the Sedex platform, where appropriate, to inform its supply chain assessment process.

As of 2026, 190 of Twinings Ovaltine’s 775 sites are classified as high-risk. Based on audit findings and remediation requirements, the businesses subsequently categorise sites using ratings (red, amber and green), which determines the frequency of future audits:

• red rating – re-audited following the completion of a time-bound remediation plan, with the ambition of changing their rating to amber or green (currently seven sites);
• amber rating – audited every two years (currently 118 sites); and
• green rating – audited every three years (currently 65 sites).

Where non-conformances are identified, suppliers are required to take action to resolve the issues within a specified timeframe. This includes both health and safety and modern slavery training programmes for supplier factories where non-conformances on these issues have been identified. These e-learning courses were co-developed by Twinings Ovaltine, and suppliers are able to complete the course once they have registered.

Since February 2022, 195 high-risk sites have received the health and safety training and 80 high-risk sites have undertaken modern slavery awareness training.

In 2026, Twinings Ovaltine completed a comprehensive review of its FMIP approach to risk to ensure alignment with industry best practice and emerging international standards. As a result of this review, the division has evolved its approach and processes when categorising suppliers, to place greater emphasis on severity and likelihood of human rights impacts and strengthened its assessments regarding migrant workers.

Modern slavery training continues to be rolled out for supplier factories operating in high-risk countries, with a focus on suppliers employing migrant workers. The e-learning course is developed by Twinings Ovaltine, and suppliers are able to complete the course once they have registered.

In its tea and herb supply chains, Twinings is working towards supporting suppliers to address the needs of the communities from which it sources. Twinings has never owned any tea estates, but purchases the tea used to make its blends only from Rainforest Alliance certified gardens, who may also source leaf from smallholders. To better understand the issues in its tea and herbs supply chains it complements third-party certification with its own TCNA programme across tea gardens, estates and smallholders, as well as key herbs on a risk-basis. To strengthen its approach to monitoring its tea supply chain, it has moved to an annual risk-based approach cycle. It will carry out a full TCNA in year one, which is repeated in year two for high-risk sites, and for lower-risk sites it will carry out a follow-up visit to focus on implementation of any action plans and context-specific risks.

Twinings’ TCNA framework takes a holistic approach to assessing human rights risks and community needs in its supply chain. It focuses on hearing directly from workers, farmers and community members through focus group discussions, interviews, surveys and observations. This provides insight into the challenges and aspirations of these communities and helps identify areas for improvement.

A TCNA covers issues related to human rights and the welfare of workers in Twinings’ supply chain such as gender, health and nutrition, children’s rights, livelihoods, water and sanitation, natural resources, farming practices, housing and working conditions. This approach allows Twinings to identify specific issues and develop targeted programmes.

Following issues identified in its Kenyan tea supply chain in 2023, Twinings developed a Gender Based Violence and Harassment (‘GBVH’) Policy to help tea gardens effectively prevent and address GBVH, reduce risks, and aim to protect women workers. During 2026, Twinings updated this policy and the accompanying supplier guidance. In total, 100% of its tea producers have signed the policy and compliance with it is checked as part of a full TCNA.

Twinings is committed to playing a leading role in developing a progressive and thriving tea and herbs industry. It recognises that this will require collaboration with a range of stakeholders across the sector to help bring about industry-wide change. To achieve its ambitions, it works with partners on the ground in its key sourcing regions to help address societal and environmental industry-wide issues. Its partners include producers, NGOs, government agencies and industry platforms, as well as the tea and herb growing communities it sources from.