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Mondelez nearly doubled its human-rights audits of suppliers in 2025 and, for the first time, extended that due diligence to the companies moving its freight, the snack maker said, pushing compliance scope out of factories and into logistics for the first time at a large CPG.

By the numbers: the company completed 1,237 SMETA audits of tier-1 suppliers last year, up from 649 in 2024 (a 91% jump), covering 99% of its prioritized suppliers on a three-year cycle, per its modern-slavery report

The program now spans its own operations in 46 countries and an indirect tier-1 base (warehousing, transport, logistics) across 80.

Into the freight tier: Mondelez piloted human-rights due diligence on cross-border road freight, rolled out a scorecard for transport providers across its European business units, and adapted Bureau Veritas social assessments for its own warehouses. 

Audit regimes have lived inside factories for two decades; this is one of the first large CPG programs to treat carriers as auditable suppliers. 

Betina Corbellini, the company's supply-chain HR chief, called embedding due diligence "into our daily operations" the foundation of the risk program.

Know more: the company also ran capability sessions to roll out the tougher SMETA 7 audit methodology across its manufacturing sites, trained procurement and other stewardship staff on human-rights risk, and co-developed a combined human-rights-and-environment screening tool with the Fair Labor Association and Proforest, which it has already used to train Indonesian palm-oil suppliers.

Why now: the report names the UK Modern Slavery Act, Norway's Transparency Act, and Swiss child-labor rules, with EU sustainability reporting ahead. The pressure is regulatory, and it is all European.

The gap: the 31-page report never mentions UFLPA, the US forced-labor law CBP actively enforces at the border, despite cocoa, palm, and hazelnut sourcing from high-risk geographies. For a company with major North American import flows, that is the exposure CBP would examine first.

What it shows: the emerging CPG compliance model runs in tiers - audit cycles for factories, scorecards for carriers, program-based work at farm level. Carriers are the tier regulators ask about next.

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