EXTERNAL BUSINESSPARTNER (EBP)
STEWARDSHIP OVERVIEWCONTENTSOBJECTIVESPOLICIES/EXPECTATIONS/GUIDELINES

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CONTENTS

CONTENTSOBJECTIVES/OVERVIEW

P&G Objectives / Overview

3

P&G Policies / Expectations / Guidelines

5

P&G’s 5 Global Sourcing Principles

6

Expectations / Guidelines for All External Business
Partners

7

Other Service Specific Expectations / Guidelines

29

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• As an external partner to P&G, whether you are providing materials, finished products orservices, the following core expectations and guidelines can help quickly equip you to
become a successful partner to P&G.

OBJECTIVES –WHAT THISOVERVIEW IS• P&G’s Worldwide Business Conduct Manual explains global standards that P&G
employees must follow at all times. P&G also expects external parties with whom P&G
does business to follow standards equivalent to its Worldwide Business Conduct
Manual.
• We take ethical conduct and legal compliance very seriously. The intent behind thissummary of core expectations / guidelines is to clearly communicate P&G’s standards
among its external partners.
• While we hope and expect that external parties share P&G’s commitment to ethicalconduct, deviations from these expectations may result in termination of businessamong other remedies consistent with contractual rights and applicable law.

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3 OF 33NOTOBJECTIVES –WHAT THISOVERVIEWIS NOT

CONTENTSOBJECTIVES/OVERVIEWPOLICIES/EXPECTATIONS/GUIDELINES• Providing these reference document does not change your contract with P&G,
the employment status of your workers, or the requirement that external parties alone
train, manage, and supervise their own employees.
• Though we expect you to demonstrate the same commitment to governance andstewardship with comparable high standards, it remains your responsibility to ensurecompliance with contract terms, applicable law, and ethical business practices.
• As you manage the policies and controls within your own organization, you areresponsible to identify and mitigate risks particular to your industry, geography,
workforce, and any allowed sub-vendors consistent with these general expectations.

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P&G POLICIES / EXPECTATIONS /GUIDELINES• P&G's policy is to operate within the spirit and letter of the law and tomaintain high ethical standards wherever we conduct business. P&G does notcondone or tolerate efforts or activities to achieve results through illegal orunethical dealings anywhere in the world.
• P&G’s external business partners know that the Company is concerned not
only with results, but also with how those results are achieved. We expect
all off our external business partners to conduct their business with the samehigh standards. We will actively seek business relationships with externalbusiness partners who share our values and promote the application of thesehigh standards among those with whom they do business.

pgsupplier.com

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5

GLOBAL
SOURCING
PRINCIPLES

These five principles
establish a foundation forour discipline and serve
as guidelines in our daily
activities as we interact
with EBPs.

CONTENTSOBJECTIVES/OVERVIEWPOLICIES/EXPECTATIONS/GUIDELINES

1

BEST TOTAL VALUE
We make sourcing decisions on the basis of best total value offered to supply our
requirements for goods and services.

2

HONEST, ETHICAL AND FAIR DEALINGS
We treat all suppliers with respect and deal with them honestly, ethically, and fairly.

3

EXTERNALLY LINKED SUPPLY SOLUTIONS
We deliver solutions that meet P&G business needs by bringing the Company's
deep supply and market knowledge and access to supplier competencies,
resources, and relationships around the globe.

4

COMPETITION AND COLLABORATION
We apply the strategic use of competition, collaboration or a blend of the two in our
approach towards managing our supplier relationships

5

SUPPLIER INCUMBENCY
We prefer ongoing relationships with incumbent suppliers because we believe they
deliver lower long-term costs and higher value to our business.

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THE FOLLOWING EXPECTATIONS / GUIDELINES ARERELEVANT TO ALL P&G EXTERNAL BUSINESS PARTNERS(EBPs)

1

2
3

CONTENTS

P&G WBCM (Worldwide
Business Conduct Manual)• Conflict of Interest• Anti-Bribery Expectations• Global Social Media• Competitive Information
Collection
Gifts and BusinessEntertainment Expectations
Purchase Documents
Expectations

OBJECTIVES/OVERVIEWPOLICIES/EXPECTATIONS/GUIDELINES

4

EBPs that Manage Personal
Data

8Entering P&G Facilities

5

Information Security
Expectations

9

Supplier Citizenship andSustainability Compliance6

Access to P&G Systems

10

Publicity Guidelines

7

Utilization of Non-P&G
Workers

11

Global Violence Free
Workplace

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• Worldwide Business Conduct Manual (WBCM)
is the summary of our Purpose, Values andPrinciples (PVPs) that are the foundation of
everything we do at P&G.

WORLDWIDE
BUSINESSCONDUCTMANUAL• The WBCM Includes guidelines related to:– Conflict of Interest,– Anti-Corruption,– Global Social Media, and– P&G Competitive Information Collection
among others.

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• An actual or personal conflict of interest can arise when a P&G employee has an
undisclosed personal relationship with an external business partner, when such P&G
employee has direct or indirect decision-making authority or influence over thebusiness relationship.
– Similar conflicts can arise between your company and sub-vendors you are authorized
to select to perform P&G work.

CONFLICT OF
INTEREST• Any decision or input to decisions about P&G business must be made to further P&G
interests, not those of individual employees or other personal interests.
• You must report via the P&G Helpline if P&G employees ask for personal favors oroffer special pricing to an external business partner / contractor in exchange for somepersonal benefit.​

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ANTI-BRIBERY EXPECTATIONS
You must not offer, give, seek, or accept bribes. You also must
not allow any other party working on behalf of P&G—such as
an agent, consultant, or subcontractor—to offer, give, seek, or
accept a bribe. A bribe is anything that is given or offered to
improperly influence the behavior of someone in business or
government. It need not be made in cash. A gift, meal, drink,job offer, travel, or anything of value can also be a bribe—any
attempt to “buy” an improper benefit is prohibited, no matterthe amount or value of the thing offered.

The Anti-Bribery Guide further outlines P&G's expectations on
anti-bribery and anti-corruption compliance. It is available fromthis link:

Anti-Bribery
Guide

P&G also prohibits “facilitation” payments. These are small,unofficial payments made to government officials that prompt
or expedite routine tasks, such as clearing goods throughcustoms, obtaining a travel visa, or connecting utilities.

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ANTI-BRIBERY EXPECTATIONS(CONTINUED)

External Business Parties providing services to P&G who may interact withgovernment officials must:
Complete P&G’s Antibribery screening process.
1

Agree to our anti-corruption compliance agreement:

2

Print & Sign Contract – English Version

3

Ensure their employees working on P&G business are trained and supported inrobust antibribery compliance.

Distributors of P&G finished products are also expected to comply with the following
two schedules:
Distributor Schedule A
Distributor Schedule B

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GLOBAL SOCIAL MEDIA POLICY
Many of our employees and partners use social media in their daily work. As we use social
media, it’s important to understand that the many laws around the world regulating what P&G
can say about the Company, our brands and our products apply in social media, just as they doin many other business interactions.
P&G has developed a Global Social Media Policy (PDF) that describes the principles for its use,
as well as standards & procedures for employees and partners when they use it as a key
responsibility of their job, for collaborating internally and externally, or in their personal life.
You must take great care not to disclose confidential P&G information over social media—
including photographs.

You should also remember to disclose your affiliation with P&G whenever you provide opinions
or reviews of P&G or competing products and / or services. These disclosures are equallyimportant for any agency, vendor, partner, or a similar third party who comments on Company orcompetitive products or business initiatives (i.e., #ad, #paid, #sponsored, #PGClient). Similarly,
if you create a P&G-sponsored Social Media forum (site, mini-site, chat-group, etc.) clearly
indicate that P&G is the sponsor.

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P&G COMPETITIVE INFORMATIONCOLLECTION POLICY• Competitive intelligence is the process of understanding and anticipating thecompetitive environment in which P&G operates to maximize our competitive
advantages, positively influence our decisions and consequently, impact ourbusiness results.
• P&G’s Competitive Information Collection Policy is organized around Core
Principles, such as:– We only seek to obtain competitive information in compliance with applicable laws
– We never misrepresent or mislead anyone about our relationship with P&G– We do not make promises in exchange of proprietary information to customers,competitors and other third party– We don’t use third parties as messengers of information between us and ourcompetitors• These expectations also apply to external business partners when acting on
behalf of P&G.

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Competitive
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Collection
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GIFTS AND
BUSINESSENTERTAINMENT
EXPENSES​Exchanging anything of personal value with P&G employees can (or canappear to) improperly influence business decisions, as well as create strain
and awkwardness in the business relationship. This is because P&G
employees are required to conduct their work solely in the interests of P&G.
They are prohibited from personally benefiting in a meaningful way fromany external party’s dealings with P&G.

For this reason, external parties must not attempt to improperly
influence P&G employees using gifts, meals, entertainment, travel,
hotel accommodations, or anything else of value.

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​SOME EXAMPLES:
P&G expectation is to host our share of appropriate businesslunches / dinners.

GIFTS AND
BUSINESSENTERTAINMENT
EXPENSES(CONTINUED)

CONTENTSOBJECTIVES/OVERVIEWPOLICIES/EXPECTATIONS/GUIDELINES

We expect the cost of business lunches and dinners, regardlessof who pays, to be modest.

Accepting tickets, or any other gift, from an external business
partner or customer raises significant conflict of interest
concerns within P&G. If the tickets to a game are not associatedwith any business event (e.g., they are purely for personaluse), this will be graciously declined. If the tickets are for P&G
team and co-workers so they can attend the game withrepresentatives of the customer, then attending the event may
have genuine business relationship-building value and will beassessed by P&G management appropriately.

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PURCHASE DOCUMENTS EXPECTATIONSWork / service for P&G should only start when a Purchase Order is received by theExternal business partner. NO PO = NO Service/Work

English中国

TürkРусский

한국어

Français

Español‫العربية‬Português

Purchase orders are governed by the Procter & Gamble Terms and Conditions for
the Purchase of Goods / Services that you can open from these links:
EBP’s supplying Raw & Pack goods must have relevant P&G purchasedocuments before providing the goods.
P&G expects to have a clear scope of work and required proof of performance
documentation defined at time of the agreement.
Where needed, external business partners are required to have signed contracts
with a P&G Purchases contact (Statements Of Work (SOW), Master Service
Agreements, Supplemental Agreements) for goods/services that will be delivered
to P&G.

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EXTERNAL BUSINESS PARTNERS THAT MANAGEPERSONAL DATAThe Privacy requirements apply to all Third Parties who manage Personally Identifiable
Information (PII) for or on behalf of P&G.
These requirements are the basic organizational security and privacy requirements for externalbusiness partners. They describe the expectations P&G has with external business partners andexternal business partners to align with the P&G Information Security and Privacy Policies.

Privacy & Security Requirements for External Business Partners
P&G's Privacy & Security Requirements for External business partners
The following Exhibits make up P&G's Privacy and Security requirements for vendors who
access or handle P&G Personal Data on behalf of P&G:
• Exhibit A P&G Privacy Requirements• Exhibit B Standard Contractual Clauses for Personal Data Vendors who transfer P&G
Personal Data across certain country borders• Exhibit C P&G Information Security Requirements• Exhibit D Privacy Agreement for Non-Data Processors• Exhibit B (Module 1) Standard Contractual Clauses for Personal Data Vendors who transfer
P&G Personal Data across certain country borders (if applicable)
Contact your Purchases representative for support.

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EXTERNAL BUSINESS PARTNERS
THAT MANAGE PERSONAL DATA(CONTINUED)PERSONAL DATA• Personal data, also known as PII (Personally, Identifiable Information) is classified
based on the types of data processed (name, consumer email address, etc.) andvolumes of personal data processed or handled by the end user. Third Parties
collecting or processing PII as part of the activities provided to P&G must be
specifically assessed on their Privacy handling capability.
• Respond to the assigned PII screening and remediate any outages required
to complete the screening.
• EBP’s Employees (and Subcontractors) must be made aware of the key elementsof P&G's Privacy Requirements and understand their personal responsibilities.
Staff must be trained in how to implement P&G's Privacy Requirements.
• If applicable ensure Information Security and Privacy compliance is included in
the contract.

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These retention schedules apply to P&G United States (US),European Union (EU) and United Kingdom (UK) consumer andemployee data, only.

P&G RETENTIONSCHEDULESFOR PERSONALDATA

They do not apply to P&G consumer and employee data from other countries. The
general rule is that any personal data should not be kept for longer than it is needed toprovide the service. The periods outline the maximum time personal data should be kept
by External business partner in providing the services. If the External business partner
can delete the personal data sooner, this should be done. If a Master Services Agreement
or Statement of Work provides for a more specific retention period for US, EU or UK
personal data for the services you are providing to P&G, that retention period takes
precedence over this document.

Retention
Schedule

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INFORMATION SECURITY
EXPECTATIONS• Cyber Security is an increasing risk for both P&G and our External Business
Partners. Please remain alert and diligent and continue to improve yourcapabilities to protect all our supply chains. We encourage you to explore andadopt best practices and certifications that support the needs of P&G and theother CPGs and industries with whom you work.
• P&G’s Information Security requirement are published here.
Exhibit C P&G Information Security Requirements• Whenever there is an incident or suspected incident related to Privacy/InfoSec,
please immediately report the details to P&G via securityincident.im@pg.com
directly.

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INFORMATION SECURITY EXPECTATIONS (CONTINUED)
LOCATED ON THE P&G SUPPLIER PORTAL: pgsupplier.com• All external business partners who deploy,manage, or support P&G IT assets (applications,data, platforms, software, networks andinformation systems) and / or require accessprivileges to any P&G system to performtheir role.

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21 OF 33• This policy requires that individuals are authorized forspecific business purposes by requiring them to be
granted access privileges in line with their role.

P&G SYSTEMACCESS POLICY• Individuals must be authenticated use access control
mechanisms (e.g. password, token, biometric) andsubject to a rigorous sign-on process before being
provided with approved levels of access.
• This policy also protects the business information thatprovides access to partners, customers, contractors,
and consumers by performing information risk
assessment to determine the information security
requirements and implementing security arrangements
in contracts and agreements.
System AccessPolicyCONTENTSOBJECTIVES/OVERVIEWPOLICIES/EXPECTATIONS/GUIDELINES

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UTILIZATION OF EXTERNAL PARTY RESOURCES• P&G establishes and maintains clear distinctions between P&G employee
relationships and those with External Party resources.
• External Party resources are not used to establish an entry process for
employment at P&G or on an ongoing basis to fill or delay filling P&G
positions.

Link: Utilization ofExternal Party
Resources• External Party resources should perform work or service that are different
from the work or service executed by P&G employees and be
distinguishable from P&G employees (e.g. uniforms, work areas, badges).
Any use of External Party Resources to perform work or services normally
performed by P&G employees must be infrequent and short-term.
• External Party Resources must be utilized in a manner that remains
compliant with the spirit and letter of the local labor law, international labor
standards, P&G’s Human Rights Policy Statement, PVPs and WBCMCONTENTSOBJECTIVES/OVERVIEWPOLICIES/EXPECTATIONS/GUIDELINES

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All visitors must provide their credentials to the receptionist uponentering P&G facilities.

ENTERING P&G
FACILITIES• All visitors will always display the badge provided at the entrance of the facility.

• Where applicable the visitors will follow all safety and security protocols required by the
P&G facility.
• All visitors will be allowed access
via P&G authorized escorts.

Accessing P&G
Facilities

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P&G SUPPLIER CITIZENSHIP
P&G is committed to providing products and services of superior quality and value to the world’s consumers, now and forgenerations to come. Our Citizenship framework is how we are investing in the United Nations Sustainable Development Goals
and include focused programs in Diversity & Inclusion, Gender Equality, Sustainability, Community Impact and Ethics &Corporate Responsibility.
P&G cannot deliver those products without collaboration from our supply chain partners and we are making intentional choices
to leverage the footprint of our external business partners, buyers, and manufacturing sites to be a Force for Good and a Forcefor Growth. We believe we can accelerate and amplify our Citizenship results by intentionally enrolling our External Business
Partners in this work via two strategy pillars: Supplier Diversity and Responsible Sourcing.

ETHICS &CORPORATERESPONSIBILITYCONTENTSOBJECTIVES/OVERVIEWCOMMUNITY
IMPACTPOLICIES/EXPECTATIONS/GUIDELINES

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SUPPLIER SUSTAINABILITY COMPLIANCE
GUIDE
These Sustainability Guidelines for External Business Partners explain the global
standards to be followed in your daily business activities on behalf of P&G. Externalbusiness partners and their suppliers are expected to share P&G’s commitment to thesestandards. P&G reserves the right to conduct audits to assure compliance with theseguidelines and reserves the right to discontinue any relationship should the externalbusiness partner violate, fail to correct, or have a pattern of violating these guidelines.
This guides cover:• Legal Compliance• Human Rights• Child Labor• Forced Labor, Human
Trafficking & Employment
Eligibility• Wages and Hours

CONTENTSOBJECTIVES/OVERVIEW• Coercion, Harassment
and Discipline• Preventing Bribery andCorruption• Discrimination• Gifts, Entertainment andGratuities• Health & Safety• Environmental
Sustainability• Freedom of Association
and Collective Bargaining

POLICIES/EXPECTATIONS/GUIDELINES

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pgsupplier.com
Responsible
Sourcing page

• Employee & Data Privacy• Personnel & Facility Security• The P&G Worldwide BusinessConduct Helpline

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• P&G generally does not allow External Business Partners to reference publicly theirrelationship with P&G and our brands due to the confidential nature of our partnerships.
• Examples of this include (but are not limited to): Use of P&G logo, press releases,
testimonials or references, P&G speaking requests at External Business Partner orindustry events, external award submissions.

PUBLICITY
GUIDELINESCONTENTSOBJECTIVES/OVERVIEW• In some cases, it may be beneficial to both P&G and the EBP to do some sort ofpublicity. In these cases, P&G Purchases should be contacted first, who will assess andthen link with Communications, Legal, and other necessary functions to secure an
exception to our policy, where appropriate.

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GLOBAL VIOLENCE-FREE WORKPLACE POLICY

Procter & Gamble provides a safe and secure environment that is free of any form of violence
for our employees, non-P&G workers, visitors, etc. At P&G, “violence” includes threats or actsof violence towards people or property, intimidation of others, or attempts to instill fear inothers. Weapons are not allowed in the workplace.
There is nothing more important to P&G than the safety and security of its employees andvisitors. In support of this principle, threats or acts of violence against employees or any otherauthorized third party on our premises and/or property will not be tolerated. Violations of thispolicy will lead to disciplinary action up to and including termination of employment, or removal
if an external party, and the involvement of local law enforcement authorities as needed.
Violence Free workplace Policy
The HS&E policy referenced in the Terms and Conditions is available
from this link:
P&G HS&E
PolicyCONTENTSOBJECTIVES/OVERVIEWPOLICIES/EXPECTATIONS/GUIDELINES

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OTHER SERVICE-SPECIFIC EXPECTATIONS/GUIDELINES(CONTINUED)For External business partners providing Beauty
Care Business services where U.S. State
Requirements for Animal Testing and / orExpectations for Cruelty-Free Brands apply, andExternal business partners located in, or doing
business in, France the following guidelines apply
related to French Black Labor.

IT

For External business partners providing IT services
to P&G please review the applicable expectations /guidelines.

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OTHER SERVICE-SPECIFIC EXPECTATIONS/GUIDELINESSAFEGUARDING ASSETS AND INFORMATION • PROTECTING P&G
Keeping P&G Information and Assets Secure (Physical & Digital security)
REPUTATION
Proper handling of confidential information and P&G assets on site and in-transit toprevent losses. Review the Physical Security Expectations Link.

Records & Information GovernanceP&G considers records created or received during the normal course of business a
P&G asset.

P&G Technologies and Electronic Communications
You must safeguard P&G’s proprietary information and data, as well as thetechnologies this information is stored on.

EBP’s Committed toSecuring
P&G Assets andinformation

CONTENTSOBJECTIVES/OVERVIEW

Ensuring Product Quality and Safety
Our products and packages are not used for unauthorized purposes.
Scrapping of P&G product/inventory is done in accordance to agreed requirements.
POLICIES/EXPECTATIONS/GUIDELINES

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P&G VARIOUS REQUESTSEXPECTATIONSAll EBPs should reply to P&G various requests such:

Assessments
for Antibribery

Privacy orInformation
Security

Citizenship
Surveys

Sustainable
Sourcing
AuditsQA Audits

Reply timely on all requests.

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If you have concerns that P&G employees or
your employees performing P&G business havedeviated from these expectations or violated
some other applicable policy, legal requirement,or ethical standard, promptly report this to the
P&G Helpline here.
P&G does not tolerate any form of retaliation
against people who report a suspected violationin good faith. This is not just something we say,
but a commitment we actively work against
when a report is made.

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We take compliance very seriously. The intent behind our core expectations /guidelines is to enable compliance at the highest standards for P&G and its partners
and to protect and value the information of our customers, consumers, shareholders
AND external partners.
If you have any questions about the expectations / guidelines, ask your P&G
Purchasing contact for clarifications.
As you manage the policies and controls within your own organization, pleasetake note of our expectations on how to conduct business with or for P&G, including
as to allowed sub-vendors handling projects for P&G.
This is not a one-time overview; we expect that you review all the relevant
expectations / guidelines with appropriate frequency (i.e. once a year).

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