Supply Chain Statement

Author Publish Date: Last Modified Date:

Coerced Labor in Supply Chains Statement 

Updated May 31, 2024 

The California Transparency in Supply Chains Act, the United Kingdom Modern Slavery Act of  2015, and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act require certain businesses to provide disclosures and take other actions concerning their efforts,  

if any, to address the issues of slavery and human trafficking in their supply chains. Similarly,  the revised Federal Acquisition Regulation (FAR) 52.222-50 (“Combating Trafficking in  Persons”) and FAR provision 52.222-56 (“Certification Regarding Trafficking in Persons  Compliance Plan”) are aimed at removing slavery and human trafficking from the U.S. Federal  Government contracting supply chain. This Coerced Labor in Supply Chains Statement  (“Statement”) addresses these statutes and regulations and covers all of Campbell Soup  Company’s (“Campbell”) companies worldwide. 

This Statement responds to the California Transparency in Supply Chains Act, the United  Kingdom’s Modern Slavery Act, and the Canadian Fighting Against Forced Labour and Child  Labour in Supply Chains Act disclosure requirements, even though Campbell is not subject to  the United Kingdom’s Modern Slavery Act. We have undertaken an enterprise-wide approach to  our efforts with respect to the coerced labor and human rights concerns these statutes and  regulations embody and make this Statement on behalf of the entire enterprise.1 

We recognize that slavery and human trafficking can occur in many forms, including forced  labor, child labor, domestic and indentured servitude, sex trafficking, and workplace abuse.  Therefore, the term “Coerced Labor” as used in this document includes these various forms of  slavery and human trafficking.  

Our Business 

Campbell is driven and inspired by our purpose, Connecting people through food they love. We  make a range of high-quality soups and simple meals, beverages, snacks, and packaged fresh  foods. Led by our iconic Campbell’s brand, our portfolio includes Pepperidge Farm, V8Swanson, Pace, Prego, Pacific Foods, Snyder’s of Hanover, Lance, Kettle Brand, Cape CodSnack Factory Pretzel Crisps, Pop Secret, Late July, and other brand names.  

1 For the purposes of the Canadian Act, this Statement is being made on behalf of Campbell Company of Canada.

Our Supply Chain 

Campbell currently sources ingredients, goods, and services from thousands of suppliers  globally. Like many consumer goods companies, our supply chain is complex, and there are  limits to visibility beyond the first tier of suppliers. Efficiently and effectively assessing and  addressing supply chain issues such as human rights beyond the first tier is often challenging.  However, we are on a continuous journey of more complete traceability and transparency  throughout our global supply chain.  

Policies and Statements Addressing Human Rights 

Campbell’s Code of Business Conduct and Ethics supports our purpose and values. This Code is  provided to every Campbell employee and sets out our collective and individual commitment to  conducting business ethically, responsibly, and in accordance with all applicable laws and  regulations. Our Code also sets forth Campbell’s expectations on human rights, which are further  detailed in our Human Rights Principles.  

Our Human Rights Principles detail Campbell’s position on our core human rights principles— diversity, prohibition of discrimination, harassment, and child and forced labor, expectations on  wage and working hours, providing a safe and secure workplace, and enabling freedom of  association to trade unions.  

Our Responsible Sourcing Supplier Code (the “Supplier Code”) was developed to help drive  higher ethical and sustainable standards in our supply chain. It sets forth Campbell’s expectations  and requirements for suppliers in several areas, including business integrity, human rights and  fair labor practices, health and safety, and environmental impact. Campbell’s standard purchase  order includes terms requiring Suppliers to acknowledge they have reviewed the Supplier Code  and agree to comply therewith. 

This Statement sets out the steps Campbell takes to ensure that Coerced Labor does not taint our supply chain and serves as a reinforcement of our long-standing policy of conducting business  with suppliers who share our same values and high ethical standards. 


Campbell engages in a series of verification activities to identify, assess, and manage the risk of  Coerced Labor in our global supply chain. More specifically: 

Expectation-Setting. Campbell’s first step in the verification process is to set clear expectations  for our Suppliers through the contracting documentation they are expected to review,  acknowledge, and execute. Campbell’s Supplier Code applies to every direct and indirect supplier, and, as noted, acknowledgement and agreement to comply therewith is a condition  outlined in our standard purchase orders. In addition, Suppliers are expected to inform their workers about the expectations outlined in the Supplier Code.

The Supplier Code provides clear guidance on Campbell’s expectations and addresses topics  such as compliance with laws, ethics, child labor, forced labor, abuse and harassment, fair and  equal treatment, compensation, benefits, working hours, hiring practices, freedom of association,  health and safety, environment, and animal welfare, work hours, wages, safety and health, non discrimination, and harassment.  

Due Diligence Screening. As part of the process of identifying new Suppliers, Campbell includes inquiries specifically designed to identify and assess Coerced Labor risks. In addition, Campbell  uses a variety of factors and tools to determine a Supplier’s potential for social and  environmental risks. More specifically, Campbell takes into account the geography of origin and  the industry practices for each direct material. Based on the initial determination of risk,  Campbell may require a Supplier to complete a Self-Assessment Questionnaire or to submit to or  provide a Responsible Sourcing audit.  

Compliance Communications. We may send our suppliers targeted communications (i)  reminding them of their ongoing obligation to comply with the Supplier Code, including those  terms dealing with human trafficking and Coerced Labor; and (ii) instructing them to  immediately notify us if and when they have reason to believe they are in violation of our  clearly-articulated expectations and requirements.  

Labor Brokers. Campbell takes steps to assess potential risks related to labor brokers and third party recruiters in our supply chain. The Supplier Code requires that “[w]orkers shall work  freely, aware of the terms and conditions of their work in advance, and must be able to  voluntarily end their employment without any restriction or substantial fines for terminating their  employment contract,” and “shall not be required to pay fees or costs associated with their  recruitment.” 


While “verification” is designed to identify, assess, and manage supply chain risks, “auditing”  refers to activities a company takes to evaluate ongoing supplier compliance with existing  company standards for Coerced Labor in its supply chain(s).  

Auditors and Audit Rights. Pursuant to our Supplier Code, we reserve the right to request or  conduct a Responsible Sourcing audit from or of any Supplier. Specifically, Campbell reserves  the right to request an independent third-party audit to verify adherence to the Supplier Code.  Suppliers are expected to fully cooperate with Responsible Sourcing audits. Campbell prioritizes  collection of audits from Suppliers who are deemed high risk. 

Audit Methodology. Responsible Sourcing audits are performed for the purpose of enhancing visibility into a Supplier’s potential risk and on an as-needed basis. During such audits, Campbell  inspects for evidence of health and safety concerns, wage and social compliance, forced labor and child labor issues, harassment-free workplace policies, environmental issues, and any other  issues germane to compliance with the Supplier Code. 

Access to Records. Our standard purchase orders require Suppliers to agree (i) that in addition to  all other audit rights, Campbell has the right, with or without notice, and at the Supplier’s  expense, to audit the facility(ies) where goods are manufactured and examine the books and  records of the Supplier (and/or its subcontractors and sub-tier manufacturers and suppliers) to  verify compliance with their obligations under the terms and conditions of the purchase order,  including compliance with laws, and (ii) that as applicable, Suppliers will procure from each  subcontractor and/or sub-tier manufacturer and supplier (if any) such agreements, permissions,  and rights as necessary to allow Campbell to perform such audit. 

Our Additional Actions to Encourage Supplier Compliance and Accountability.  

Anonymous Reporting. Campbell has a whistleblower hotline (called the “Campbell  Integrity Hotline”) for our employees and third parties with whom we partner to use if  they have a concern that relates to improper, illegal, or unethical conduct or if they find  themselves in a situation which may lead to a violation of Campbell’s policies or  applicable laws or regulations. Our Integrity Hotline allows any reporter to remain  anonymous. The Hotline is operated by an independent company that specializes in  handling such reports. The Hotline is available 24 hours a day, seven days a week, and  has translation services available at all times. We are committed to investigating and  promptly responding to concerns. 

Pursuant to the Supplier Code, moreover, Suppliers are expected to immediately advise  Campbell of any issues that may arise related to the Supplier Code, particularly any  potential or actual violations. Suppliers may report violations via email or the Integrity  Hotline. In order to ensure that the workers within our supply chain have the opportunity  to confidentiality report concerns that may be in violation of the Supplier Code, Suppliers  are required to make contact information for the Campbell Integrity Hotline available to  its workers and inform them that communications may be made on an anonymous basis.  

Remediation. The presence of Coerced Labor would mean a violation of the Supplier  Code. If Campbell discovers that one of our Suppliers has violated any applicable laws,  rules, regulations, or the Supplier Code, we may take corrective action, up to and  including canceling any outstanding orders, terminating the business relationship, and/or  pursuing legal action. Suppliers are expected to implement recommended corrective  action plans and remedy any act of non-compliance in a timely manner. Supplier’s failure  to implement the recommended corrective actions may result, at Campbell’s sole  discretion, in the suspension of any purchases from Supplier until the corrective actions  have been implemented or termination of the relationship with Supplier. We did not  identify any instances of Coerced Labor in our supply chain and therefore did not take  any related remedial actions. 

Non-Retaliation. We enforce a strict anti-retaliation policy for good faith reporting. In fact, our Supplier Code specifically instructs that a “Supplier shall not retaliate against  an employee who speaks out on an issue.” 

In addition to the foregoing measures, Campbell engages with our Suppliers in various other  ways to ensure Responsible Sourcing and to prevent Coerced Labor in our supply chain. 


The terms and conditions of Campbell’s standard purchase orders include a warranty that  Supplier will comply with Campbell’s supplier requirements, including its Responsible Sourcing  Supplier Code, as well as requirements that the Supplier conduct business in compliance with all  applicable laws, rules, and regulations. 


Internal Accountability Standards & Compliance Monitoring. Campbell maintains and enforces  internal accountability standards for our employees which are set forth in our internal Code of  Business Conduct and Ethics. The Code outlines our broad commitment to conducting business  with the highest ethical standards and in compliance with all laws, a commitment that has been  the strength of our Company for more than 150 years.  

Preventative and Corrective Action. We encourage any employee, officer, or director to seek  guidance if they have questions or concerns relating to our supply chain or Coerced Labor.  Campbell’s Code of Business Conduct and Ethics also requires that individuals report to their  immediate supervisor, a member of Campbell Soup Company’s management team, Human  Resources, the Legal Department, or the Integrity Hotline any violations of the Code, the law, or  other Campbell policy. We investigate reports promptly and thoroughly and expect all  employees and contractors to cooperate with such investigations fully and candidly. Non compliance can result in corrective action, up to and including termination of employment. We  may also exercise our right to notify the appropriate authorities of potential violations of  applicable laws, rules, or regulations.  

Measures to Assess Effectiveness. We review the effectiveness of steps taken to prevent Coerced  Labor by assessing and evaluating our suppliers and regularly engaging and collaborating with  stakeholders. We also regularly review our policies and practices and update them to address  identified risks. As we continue to develop our activities, we will consider the need for additional  ways to assess the effectiveness of our measures. 


Training is an important element of implementing effective human rights practices. Each year,  Campbell provides comprehensive online and in-person training for employees on ethics and  compliance issues and risk-based training tailored to the issues associated with employees’  specific job responsibilities. As part of the Winning with Integrity program, employees are  required to complete training on our Code of Business Conduct and Ethics. This training, offered  in multiple languages, is provided online for salaried employees on an annual basis, and in video format for employees in our manufacturing facilities. 

Employees and managers who have direct responsibility for supply chain procurement receive training on the Responsible Sourcing Supplier Code. The training includes an overview of  policies related to human rights and content specific to recognizing possible signs of slavery and  human trafficking and mitigating risks within the supply chain of our products.  


This Statement articulates the efforts we have taken with respect to our Suppliers to ensure that  our expectations around Coerced Labor are met. Given the nature of our business model, our  supply chains are complex and constantly evolving. We are committed—despite the  complexities—to conducting business in an ethical manner. We will continue to monitor and  assess our evolving supply chains and evaluate new programs and initiatives that may support  our and our Suppliers’ commitment to supply chains free of Coerced Labor. 


For the purposes of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, this Statement was approved pursuant to subparagraph 11(4)(a) by the Governing Body of Campbell Company of Canada for the fiscal year ending July 30, 2023.  

In my capacity as a Director of Campbell Company of Canada, and not in my personal capacity,  I make this attestation in accordance with the requirements of the Act. 

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I  have reviewed the information contained in the Report for the entity or entities listed above.  Based on my knowledge, and having exercised reasonable diligence, I attest that the information  in the Report is true, accurate and complete in all material respects for the purposes of the Act,  for the reporting year listed above. 

I have the authority to bind Campbell Company of Canada. 

 Atul Garg 
Director, Campbell Company of Canada 

David Vincoff 
Director, Campbell Company of Canada