Responsible Recruitment and Employment
Respect for human rights is foundational to Hershey’s responsible sourcing approach. We strive to protect the rights of workers across our operations and supply chain, from the point of recruitment through the duration of their employment.
Hershey does not tolerate forced labor, human trafficking or child labor in our operations and value chain. We recognize that exploitative recruitment practices can be a significant driver of forced labor risks, particularly for migrant and temporary workers. Addressing these risks is an important component of our broader human rights due diligence efforts.
Our Commitment to Responsible Recruitment
Hershey endorses internationally recognized standards to promote ethical recruitment, including the Employer Pays Principle and the Priority Industry Principles for Responsible Recruitment. These principles are rooted in the expectation that workers should not bear recruitment related fees or costs and should never be placed in a position of debt or coercion as a condition of employment.
We publicly affirm this commitment through our Statement Against Human Trafficking and Slavery and our Responsible Recruitment & Employment Policy, which apply alongside our Supplier Code of Conduct.
Responsible Recruitment & Employment Program
In 2021, Hershey launched our Responsible Recruitment & Employment Program to help identify, prevent, and address forced labor risks with third-party labor and service providers in Hershey’s owned operations (offices and plants) and select strategic co-packers. We engage with labor and service providers on their recruitment and employment practices and verify compliance with our Responsible Recruitment Policy. Through this program, Hershey collaborates with our labor and service providers on continuous improvement through corrective action plans and capability building where needed.
Responsible Recruitment and Employment Program Approach
The Responsible Recruitment & Employment Program follows a structured process designed to strengthen labor and service providers’ recruitment practices and protect workers.
Policy Acknowledgement
All labor service providers enrolled in the Recruitment Program formally acknowledge our Responsible Recruiting & Employment Policy and Supplier Code of Conduct on an annual basis.
This acknowledgment is renewed annually and reinforces expectations related to ethical recruitment, prohibition of worker-paid fees, freedom of movement, and fair treatment.
Risk Assessment and Due Diligence
Labor and service providers complete a recruitment-specific Self-Assessment Questionnaire (SAQ) on a reoccurring basis. The frequency is informed by geographic risk related to migration and labor practices, previous assessment results, and the nature of services provided.
The SAQ provides insights on the recruitment, hiring and employment practices of our labor and service providers. Where gaps are identified, labor and service providers are required to implement corrective action and submit evidence of completion.
Audit & Remediate
Labor and service providers are also included in the scope of Hershey’s owned-facilities SMETA 4-Pillar social compliance audits. During these audits, their workers may be interviewed and practices reviewed, such as those related to worker eligibility verification, pay and working hours.
Where recruitment-related risks or non-conformances are identified, additional actions may include:
- On-site assessments of the individual labor or service providers (e.g., SMETA 2 Pillar audits or Sedex Service Provider audit)
- Anonymous and confidential worker engagement tools
- Targeted corrective action and remediation plans
Corrective and remedial actions are verified through follow-up audits or assessments to confirm effectiveness and closure.
Capability Building & Training
We recognize that responsible recruitment requires strong management systems and informed partners.
Hershey collaborates with industry partners, including Sedex, AIM-Progress, and Stronger Together to support training and capability building for labor and service providers and Hershey internal teams. Through these engagements, we leverage:
- Tools and guidance on ethical recruitment and migrant worker protection
- Targeted training modules via industry platforms
- Shared industry research on recruitment corridors and forced labor risks
Integration with our Broader Human Rights Due Diligence Approach
Our Responsible Recruitment and Employment Program works in coordination with Hershey’s Responsible Sourcing Supplier Program, as well as our use of certifications, supplier engagement and origin-level programs.
Together, these efforts support Hershey’s approach to identifying, preventing, and addressing human rights risks across our value chain.
Transparency and Ongoing Progress
Hershey recognizes that addressing forced labor and recruitment related risks requires continuous improvement and collaboration. We disclose our approach, progress, and challenges through our Responsible Business Report and Statement Against Slavery and Human Trafficking, and we continue to refine our program as risks, regulations, and expectations evolve.
