THIS WEEK'S COMPANIES

First, a few pointers. 

1.  If there is a link about the company in the summary please do not copy and paste the link from our summary into your letter, particularly if it's a company document. They already have their own document and it transfers kind of weirdly to your letter. 

2.  We have a generic letter for you to use if you want, at the end of the template document linked in Step 1.

3.  The company background information below is just that - for your information.  There's no need to feel you should incorporate it into your letters.  We simply want to help you get to know the company you're writing to.

4. Please keep in mind that whether a company uses prison labor is not directly important to our letters.  We just believe that if they already use prison labor they may be more likely to use detention camp labor.

1.  COMPANY NAME, CONTACT INFO:

Henrique Braun, Chief Executive Officer

The Coca-Cola Company

One Coca-Cola Plaza

Atlanta, GA 30313

If you want to write to the Board of Directors too, you can CC and send separately (to the same address) a copy to James Quincey, Executive Chairman of the Board.  

COMPANY BACKGROUND INFORMATION:

The Coca-Cola Company is the world's largest beverage company by volume, with products sold in more than 200 countries and a portfolio that includes Coca-Cola, Sprite, Fanta, Minute Maid, Dasani, and Costa Coffee, distributed through a global network of independent bottling partners.

The company's Supplier Guiding Principles states without qualification or exception: “Supplier will not use forced, bonded, prison, military or compulsory labor or any form of human trafficking.” Coca-Cola's policy names “prison” labor as its own flatly prohibited category, with no carve-out for voluntary or supervised arrangements (as PepsiCo's policy does). 

As stated in the company's own California Transparency in Supply Chain Act disclosure, Coca-Cola maintains a Human Rights Policy and Supplier Guiding Principles that are enforced through mandatory contractual language for direct and authorized suppliers, routine third-party audits assessing compliance — including confidential interviews with workers — mandatory employee and supplier training, and oversight by a dedicated Board of Directors committee that reviews the company's human and workplace rights performance at least annually. 

However, in stark contrast to this policy, Coca-Cola was named directly in the 2024 Associated Press investigation we have become so familiar with, into U.S. prison labor supply chains. The AP requested records from all 50 states and traced hundreds of millions of dollars' worth of prison-linked agricultural goods into the supply chains of major food and beverage brands. Coca-Cola is listed by name as one of the companies supplied by such labor.

As a major purchaser of sugar and other agricultural commodities used in its beverages, Coca-Cola sources through complex, multi-tiered agricultural supply chains.

The AP investigation names the commodity trading companies it found buying goods straight from prison farms: “mammoth commodity traders... Louis Dreyfus, Archer Daniels Midland" and others, that have in "recent years scooped up millions of dollars' worth of soy, corn, and wheat straight from prisons."  A separate reporting on ADM's business operations states plainly that Coca-Cola sources high-fructose corn syrup from ADM. 

In addition, Coca-Cola sources sugar from other troublesome regions with massive amounts of forced labor: 

1)  China:  Its bottling facility in China's Xinjiang region sources from COFCO Tunhe, a state-run supplier whose Xinjiang facility has been alleged by the Wall Street Journal and Chinese-language media to have ties to Uyghur forced labor. In March 2020, the bipartisan Congressional-Executive Commission on China named Coca-Cola specifically as a company that had benefited from Uyghur forced labor. Later that year, the New York Times reported that Coca-Cola was lobbying Congress, alongside Nike and Apple, to weaken the Uyghur Forced Labor Prevention Act before its passage. 

2)  India:  A 2024 New York Times investigation into sugar cane plantations supplying Coca-Cola and PepsiCo in Maharashtra's Beed district found workers laboring 12 to 15 hours a day, sleeping on mats in the fields, and — most seriously — girls pushed into child marriages so they could work alongside husbands, with wages withheld to repay employer-issued cash advances, some of which funded pressured, unnecessary hysterectomies. Labor rights groups and the International Labour Organization have characterized these debt-bondage arrangements as forced labor.  Coca-Cola's own consultants visited these plantations in 2019 and reported child labor and debt-bondage practices — meaning the company had internal documentation of the conditions roughly five years before they became public, during which time the practices continued.

3)  El Salvador. A Human Rights Watch investigation found child labor, including interviews with children as young as 12, at the Central Izalco mill, El Salvador's largest sugar mill and a supplier of sugar for Coca-Cola products sold across most of Central America.

For your letters you can consider the following comments:

1. Coca-Cola's Supplier Guiding Principles ban “prison” labor by name, with no exception for voluntary or supervised arrangements.  This written commitment does not square with its inclusion in a major, well-documented AP investigation into prison-labor-linked agricultural supply chains.  We are asking you to make sure this inconsistency does not bleed over to immigrant detainee labor.

2.  We know that prison labor is legal. However, detained immigrant labor is not.  We are asking that Coca-Cola commit explicitly, in writing, that whatever gaps exist or existed in its agricultural supply chain will never be compounded by sourcing tied to detained immigrant labor, which has no legal basis for compulsion.

3.  Coca-Cola already has a Board-level human rights oversight committee, third-party supplier audits, and mandatory training. Ask the company to use that same existing infrastructure to issue one additional explicit commitment: that detained immigrant labor will never be a source, directly or through subcontractors, anywhere in Coca-Cola's supply chain.

2.  COMPANY NAME, CONTACT INFO:

Gary Pilnick, Chairman & Chief Executive Officer

WK Kellogg Co

One Kellogg Square

Battle Creek, MI 49016

COMPANY BACKGROUND INFORMATION:

WK Kellogg Co is an American food manufacturing company.  It split off some of its snacking brands in 2023, and retaining the Kellogg's name and iconic brands including Frosted Flakes, Froot Loops, Frosted Mini-Wheats, Special K, Rice Krispies, and Raisin Bran.

As with Coca-Cola, WK Kellogg Co's flagship brand, Frosted Flakes, is one of the most frequently cited examples in the Associated Press's 2204 investigation into U.S. prison labor supply chains.  Virtually every summary of the investigation leads with the same line: goods tied to U.S. prison labor “wind up in the supply chains of a dizzying array of products … from Frosted Flakes cereal . . . to Coca-Cola," with these products found on the shelves of virtually every major American supermarket. The investigation traced hundreds of millions of dollars' worth of soy, corn, and wheat sold by prison farms to major commodity traders including Cargill, Archer Daniels Midland, Louis Dreyfus, and Consolidated Grain and Barge — the same kind of large-scale commodity supply chain that feeds cereal manufacturing.

When contacted by the AP for comment, Kellogg did not respond to questions about their links to prison farms. Kellogg's own Supplier Code of Conduct states that the company has “A zero-tolerance stance prohibiting human trafficking-related activities” and prohibits forced labor “in any of its manifestations including involuntary, compulsory, indentured, bonded, slave, or human-trafficked labor.”  BUT the same section then explicitly carves out an exception: “Suppliers may use Workers in an official and voluntary government prison” program. 

As a result of the company permitting prison labor as long as it is "government" or "voluntary" in origin, we should ask the company to commit explicitly it will exclude detained immigrant labor since detained immigrants have no legal capacity to consent to compelled labor the way the policy assumes convicted prisoners in a voluntary program might. 

For your letters, you can consider telling WK Kellogg:

1.  WK Kellogg Co's Supplier Code of Conduct explicitly permits the use of workers in an “official and voluntary government prison” program.  Ask the company to add one explicit sentence clarifying that this exception can never be read to include detained immigrants, who cannot legally consent to compelled labor the way the policy's “voluntary” language assumes.

2.  Make the distinction that this is not an accusation that WK Kellogg Co's current supply chain violates its own rules. It is a request that the company commit explicitly, in writing, that its prison-labor exception will never be extended or adapted to cover detained immigrant labor.

SECOND LETTER TO A COMPANY

You can also write a second letter to Wadley Holdings.  You'll find the original information at this link. It's at Week 14.