CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

Mars, Incorporated is a privately-held, family-owned business with a portfolio of confectionery, food and pet care products and services. For more than 100 years, we have sought to bring our Five Principles of Quality, Responsibility, Mutuality, Efficiency, and Freedom to life every day, seeking to create enduring opportunities and benefits for our stakeholders. We are proud to employ approximately 150,000 Associates in more than 70 countries and to support additional businesses and jobs throughout our value chain. 

Our human rights policy and our approach to implementation are aligned with frameworks laid out in the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, and the ILO-IOE Tool, and draw on the ILO’s 1998 Declaration on Fundamental Principles and Rights at Work. Our approach is focused on deploying programs in three areas: our own operations, Tier One of our supply chain, and our extended supply chains. We engage our Tier-One suppliers through our Next Generation Supplier program, which aims to ensure that our Tier-One suppliers respect human rights in their workplaces. 

Our Next Generation Supplier program is founded on our Supplier Code of Conduct, which describes the human rights standards we expect our Tier-One suppliers to uphold, including on forced labor and modern slavery. The Code prohibits the use of all forms of forced labor and states the expectation that the Code will apply where it establishes a higher standard than required by applicable law. 

1. VERIFICATION OF SUPPLY CHAINS 

We use a variety of methods and data sources to assess risk. We work with partners, such as Verité, to strengthen how we assess human rights risk at the country and regional levels, as well as by material or service. We also use a third-party risk screen that incorporates a variety of data, including indices generated by civil society, UN bodies, the World Bank, universities, and others, as well as data from thousands of social and environmental compliance audits. Our assessment process includes identifying unique regional and sectoral risks, such as the significant migrant labor workforce in the Middle East and Southeast Asia, with a focus on our salient issues, including forced labor. 

Based on specific risks identified, our global human rights team advises and supports colleagues across the business on additional layers of risk assessment. Often implemented with independent human rights experts, this may include further desk research, validated self-assessment questionnaires, audits, and human rights risk assessments at specific sites and supply sheds. 

This risk assessment and verification process helps us determine the actions expected of specific suppliers. 

2. AUDITS OF SUPPLIERS 

Our Next Generation Supplier program is an approach to responsible sourcing that focuses on engaging and supporting relevant Tier-One suppliers. 

Our Next Generation Supplier program includes three components: 

Align: Our Next Generation Supplier program is founded on our Supplier Code of Conduct, which prohibits the use of all forms of forced labor, as described above. Our Supplier Code of Conduct is part of our standard contractual terms.  

Assess: For suppliers operating in high-risk locations and sectors, we use tools to assess their risk, such as EcoVadis, an online validation platform. We then ask suppliers with low scores to improve their management systems based on the improvement areas identified and the corrective action plans generated in their EcoVadis scorecards. In some instances, we carry out social compliance audits for select high-risk suppliers. 

Advance: We support certain higher risk suppliers as they advance their performance through a longer-term model focused on driving systemic change and worker engagement. Through our Supplier Advance programs, third party experts assess these suppliers and build their capacity to prevent and address significant issues, such as responsible recruitment. Supplier Advance programs include workers regularly on-site, including those from contingent labor and service providers. The model leverages the expertise of external advisors, including our global strategic human rights partner Verité. 

These actions are implemented on a global basis using a risk-based approach to prioritization and deployment. The applicability of certain programs may vary based on the differences between consumer goods and veterinary health supply chains and their risk profiles. Certain acquired businesses are at different stages of program rollout regarding the elements discussed above. 

3. CERTIFICATION BY SUPPLIERS 

Our Supplier Code of Conduct is part of our standard contractual terms. 

As part of the Code, suppliers are expected to comply with applicable laws and regulations, including any related to forced labor, including modern slavery and human trafficking. 

In addition to our work with Tier-One suppliers, our Responsible Workplace program aims to drive respect for human rights in our own workplaces. Our Responsible Workplace Standard details our human rights standards and expectations for our own workplaces, including forced labor prohibitions.   We routinely evaluate our factories. 

To identify human rights risks and impacts at specific locations, we take a risk-based approach to prioritize our assessment schedules. We engage independent auditors, expert in labor issues, to assess our workplace human rights performance against local laws and the Mars Responsible Workplace Standard. We will work with our sites to address any non-compliances that may be identified. Responsible Workplace assessments include a focus on service providers and contingent labor at our sites, given this group of workers is often more vulnerable to risks. In certain key countries with known forced labor risks associated with labor sourcing, we are including contractual terms with labor providers to include specific guidance on recruitment fees, access to personal documents and other foundational elements of our Supplier Code of Conduct. 

4. TRAINING 

Our Mars Commercial Associates are expected to take training courses on our overall approach to building responsible and sustainable supply chains, our Supplier Code of Conduct, and our Next Generation Supplier program. These courses cover our human rights standards, our expectations of our suppliers and our overall approach to addressing human rights issues, including forced labor. We also provide a range of resources and tools to help our Associates develop human rights action plans for specific materials and engage suppliers in developing approaches to address key risk factors. Tailored training is provided to relevant teams internally.

Our Supplier Code of Conduct Guidebook provides guidance for suppliers on how to implement our Supplier Code of Conduct in their workplaces, including good practice examples for development management systems to identify, remediate and prevent forced labor and other human rights risks.