OPPORTUNITIES FOR IMPROVEMENT
Hershey is encouraged to develop and disclose a policy that requires recruitment agencies in its supply chain to uphold workers' rights and requires suppliers to disclose the recruiters that they use. The company may also consider requiring that no fees be charged to workers during any recruitment process in its supply chain and ensuring that these fees are reimbursed in the event that they are discovered. Further, Hershey may consider auditing recruiters to assess the risks of human trafficking and forced labor.
Although Hershey discloses its Supplier Code of Conduct in multiple languages, it is encouraged to take steps to ensure supply chain workers are aware of its forced labor related policies. Hershey is also encouraged to support its suppliers in ensuring workplace environments in which workers are able to pursue alternative forms of organization where there exist regulatory constraints on freedom of association and to engage with workers outside of the context in which they work. Finally, the company may consider developing and disclosing a grievance mechanism for supply chain workers and ensuring that supply chain workers are made aware of its existence.
Although Hershey monitors its suppliers, the company is encouraged to disclose further information on this process, including whether it conducts non-scheduled audits and interviews with workers. To enhance its transparency, Hershey is also encouraged to disclose information on the outcomes, such as the number and percentage of suppliers audited annually, information on who carried out the audits, as well as a summary of the audit findings, including any regarding any violations revealed.