Modern Slavery & Human Rights Statement
REPORTING PERIOD
Fiscal Year 2025
REPORTING PERIOD
Fiscal Year 2025PUBLICATION DATE
January 30, 2026
LAST UPDATED
January 30, 2026
APPROVED BY
Board of Directors
EFFECTIVE DATE
January 1, 2025
LAST UPDATED
January 30, 2026
REPORTING PERIOD
FISCAL YEAR 2025
PUBLICATION DATE
January 30, 2026
LAST UPDATED:
January 30, 2026
APPROVED BY
Board of Directors
CONTENTS
Our Commitment
Zero tolerance for modern slavery, forced labor, and human trafficking
Risk-based due diligence across our operations and supply chains
Supplier standards and contractual controls with audit rights
Training for procurement and operations teams on risk identification
Monitoring, remediation, and continuous improvement processes
Confidential reporting channels with non-retaliation protection
Learn how we conduct due diligence →
Our Commitment
Learn how we conduct due diligence →
1. Our Business, Structure & Supply Chain
Organization Overview
Entity Covered: Zoiko Foods Corp and its controlled subsidiaries
What We Do: Zoiko Foods Corp is a global food and beverage company engaged in:
- Sourcing and procurement of agricultural commodities and ingredients
- Manufacturing and production operations (owned and contract)
- Distribution and logistics management
- Brand development and portfolio management
Where We Operate: Our operations span multiple regions including North America, the Caribbean, Europe, Africa, and Asia. We maintain offices, production facilities, and distribution networks across these markets.
Supply Chain Overview
Our supply chain includes the following key categories:
- Agricultural sourcing: Raw materials, commodities, and ingredients
- Contract manufacturing: Third-party production facilities
- Packaging materials: Primary and secondary packaging suppliers
- Logistics and warehousing: Transportation, storage, and distribution partners
- Services: Cleaning, security, maintenance, and temporary labor providers
Scope of This Statement
Operations Covered
- All owned and controlled entities, offices, and production sites
- Direct employees and on-site contractors
Supply Chain Coverage
- Tier 1 suppliers: Direct suppliers to Zoiko Foods Corp (primary focus)
- Tier 2+ suppliers: Suppliers to our suppliers (monitored where feasible and risk-appropriate)
Exclusions
This statement does not cover third-party entities not controlled by Zoiko Foods Corp, including independent retailers,franchisees, or separate joint ventures where we lack operational control.
2. Policies & Governance Framework
Policy Framework
Our commitment to preventing modern slavery is supported by the following policies:
- Code of Conduct: Sets expectations for ethical behavior across our organization
- Supplier Code of Conduct: Establishes labor, health & safety, and ethical standards for suppliers
- Human Rights Policy: Affirms our commitment to internationally recognized human rights
- Whistleblowing / Speak Up Policy: Provides safe channels for reporting concerns
- Anti-Bribery & Anti-Corruption Policy: Addresses corruption risks that may enable exploitation
- Procurement Standards: Governs supplier onboarding and ongoing management
Policy Access:These policies are available to employees and can be shared with suppliers and stakeholders upon request. Contact [email protected] for more information.
Policy Access:These policies are available to employees and can be shared with suppliers and stakeholders upon request. Contact compliance@
zoikofoods.com for more information.
Governance & Accountability
| Function | Responsibility |
|---|---|
| Management | Sets strategic direction, approves statement, provides oversight |
| Executive Management | Ensures resources and accountability for implementation |
| Compliance / ESG | Maintains policy framework, coordinates reporting, manages escalations. |
| Procurement | Conducts supplier due diligence, manages contracts and audits |
| Operations | Implements on-site labor standards, manages contractors |
| Internal Audit | Provides independent assurance over controls (where applicable) |
3. Risk Assessment
Risk Principles
Modern slavery risks vary by sector, geography, labor intensity, and supply chain complexity. We recognize that risks can exist at multiple points in our value chain, and we take a risk-based approach to identification and prioritization.
Important Note
The risk areas outlined below are not exhaustive. They represent areas where modernslavery risks are more commonly identified in the foodand beverage sector. This does not imply that these risks are present in our operations or
supply chain.
Typical Risk Areas in Food & Beverage Supply Chains
- Agricultural sourcing: Seasonal and temporary labor, migrant workers, informal employment
- Labor brokers and recruitment: Recruitment fees, debt bondage, deceptive recruitment practices
- Contract manufacturing: Subcontracting layers, labor-intensive processes, informal workforce
- Logistics and warehousing: Temporary labor, subcontracted drivers, informal arrangements
- Packaging and commodities: Labor-intensive extraction and processing
- Migrant worker vulnerability: Language barriers, document retention, restricted movement
Risk Assessment Methodology
Supplier Segmentation: Categorize suppliers by criticality, spend, geography, and labor intensity
Risk Screening: Conduct initial risk assessment during supplier onboarding
Documentation Review: Evaluate supplier responses to human rights questionnaires
Targeted Audits: Conduct on-site assessments for higher-risk suppliers
Remediation & Verification: Address findings and verify corrective actions
4. Due Diligence & Controls
Supplier Onboarding Controls
New suppliers undergo the following due diligence before onboarding:
- Identification and verification: Legal entity verification, ownership structure
- Modern slavery questionnaire: Assessment of labor practices, recruitment, and working conditions
- Code of Conduct acceptance: Suppliers must acknowledge and accept our Supplier Code of Conduct
- Sanctions screening: Check against relevant sanctions lists and adverse media
- Risk-based documentation:Request certifications, audits, or supporting evidence for higher-risk suppliers
Contractual Controls
Our supplier contracts include the following provisions:
- Prohibition clauses: Explicit prohibition of forced labor, child labor, and human trafficking
- No recruitment fees: Workers must not be charged fees to obtain employment
- No passport retention: Workers must retain possession of their identity documents
- Audit rights: We reserve the right to audit suppliers and request evidence
- Cascade obligations: Suppliers must flow down standards to their subcontractors
- Corrective action: Suppliers must implement corrective action plans for identified issues
- Termination rights: We reserve the right to terminate for material breaches
Monitoring & Audit Approach
We use a risk-based approach to supplier monitoring:
- Desktop reviews: Ongoing review of documentation and questionnaire responses
- On-site audits: Physical inspections for higher-risk suppliers or when red flags emerge
- Worker interviews: Confidential interviews with workers during audits (where safe and feasible)
- Third-party audits: Use of accredited third-party auditors with proper oversight
- Re-audits: Follow-up audits to verify closure of corrective actions
Red Flags & Escalation Triggers
The following indicators trigger escalation and investigation:
- Evidence of recruitment fees or debt bondage
- Withholding of identity documents or passports
- Restrictions on worker movement or excessive overtime
- Undisclosed or unusual subcontracting arrangements
- Worker complaints or whistleblower reports
- Audit findings indicating non-compliance with labor standards
- Adverse media or NGO reports about a supplier
5. Supplier Standards & Expectations
Core Requirements
All suppliers must comply with the following minimum standards:
| Standard | Requirement |
|---|---|
| No Forced Labor | All work must be voluntary; no physical, psychological, or financial coercion |
| No Child Labor | Comply with minimum age law; no hazardous work for young workers |
| Freedom of Movement | Workers are free to leave employment; no restriction on movement |
| No Document Retention | Workers retain possession of identity documents and passports |
| No Recruitment Fees | Workers do not pay fees to secure employment; employer covers costs |
| Fair Wages | Comply with minimum wage laws; pay on time and in full |
| Safe Working Conditions | Provide safe, healthy workspace; comply with health & safety laws |
| Freedom of Association | Respect workers’ rights to organize and bargain collectively where permitted |
Supplier Responsibilities
- Implement and maintain systems to prevent modern slavery in their operations
- Cascade these standards to their subcontractors and suppliers
- Provide evidence of compliance upon request
- Allow access for audits and inspections
- Report concerns or suspected violations promptly
- Cooperate with corrective action and remediation efforts
6. Remediation & Remedy
Remediation Principles
When issues are identified, we prioritize worker safety and rights. Our approach is guided by the following principles:
- Worker-centered: Remediation must not harm the workers it is intended to protect
- Proportionate: Response is proportionate to severity and supplier cooperation
- Time-bound: Corrective actions have clear deadlines
- Verified: Completion is verified through evidence and follow-up
- Transparent: Workers and relevant stakeholders are informed of outcomes where appropriate
Remediation Process
Issue Identified: Through audits, monitoring, whistleblower reports, or other channels
Triage Severity: Assess severity (critical / major / minor) and immediate risk to workers.
Immediate Actions: For critical issues, take immediate containment actions to protect workers.
Corrective Action Plan: Develop time-bound plan with supplier; secure commitment
Implementation & Monitoring: Supplier implements plan; we monitor progress
Verification: Verify completion through desktop review or follow-up audit.
Closure & Learning: Close issue, document learnings, improve controls
Escalation & Termination
In cases where remediation is not achieved, or where violations are severe, we may:
- Escalate to executive management and board where appropriate
- Suspend business while remediation is underway
- Terminate the supplier relationship for material or unresolved breaches
- Report to law enforcement or relevant authorities where legally required
Access to Remedy
We are committed to ensuring that workers who have been harmed have access to effective remedy. This mayinclude reimbursement of recruitment fees, restoration of documents, back pay, or other measures appropriate to
the harm suffered..
7. Training & Awareness
Training Audience
We provide modern slavery awareness training to the following teams:
- Procurement and sourcing teams: Supplier risk assessment, due diligence, contract management
- Operations and site management: On-site labor practices, contractor management, red flag identification
- Logistics and vendor management: Risk identification in transportation and warehousing
- Leadership and compliance: Strategic oversight, governance, and escalation protocols
Training Content
Training modules cover the following topics:
- What modern slavery is and how it manifests in supply chains
- Risk areas specific to the food and beverage sector
- How to spot red flags and indicators of exploitation
- Supplier standards and contractual requirements
- Escalation procedures and safe reporting channels
- Non-retaliation and whistleblower protection
- Worker-centered remediation principles
Training Delivery & Frequency
Training is delivered through a combination of online modules, in-person sessions, and role-specific workshops. Key personnel receive refresher training annually or when material updates occur.
Report a Concern
If you are aware of, or suspect, modern slavery, forced labor, or human trafficking in our operations or supply chains, please report it immediately.
📋 Online Report Form
Submit a confidential report
📞 Hotline (Optional)
[Toll-free number to be provided if implemented]
Non-Retaliation
We prohibit retaliation against anyone who reports concerns in good faith. All reports are treated
confidentially to the extent possible and consistent with investigation requirements.
What Happens Next
- Reports are triaged by our compliance team
- We conduct a confidential investigation
- Findings are escalated to appropriate management levels
- Remediation is implemented as needed
- You will receive a response if contact information is provided
8. Measuring Effectiveness
Key Performance Indicators
We track the following metrics to measure the effectiveness of our efforts:
| KPI Category | Metric |
|---|---|
| Supplier Onboarding | % of new suppliers completing modern slavery questionnaire |
| Code Acceptance | % of suppliers accepting Supplier Code of Conduct |
| Audits | Number of supplier audits conducted; % completed on schedule |
| Corrective Actions | Number of corrective actions identified; % closed on time |
| Training | % of relevant employees completing modern slavery training |
| Reports | Number of reports received; average time to resolution |
Continuous Improvement
We track the following metrics to measure the effectiveness of our efforts:
Collect Inputs: Audits, reports, monitoring signals, industry trends
Analyze Trends: Identify systemic issues and root causes
Update Controls: Strengthen policies, supplier requirements, and due diligence
Train & Communicate: Roll out updates to relevant teams
Re-test & Validate: Monitor effectiveness of improvements
Statement Approval & Sign-Off
Approved By
Board of Directors, Zoiko Foods
Corp
Reporting Period
Fiscal Year 2025
Date of Approval
January 30, 2026
Next Review
January 2027 (or sooner if
material changes occur)
Signed: _______________________________
Name:
[Authorized Signatory Name]
Title:
[Chief Executive Officer / Board Chair]
Date:
January 30, 2026
Review Cadence
This statement is reviewed and updated:
- At least annually to ensure accuracy and reflect current practices
- When material changes occur in our business, operations, or supply chain
- When regulatory requirements or best practices evolve
Updated statements are published on our website and communicated to relevant stakeholders.
.com.