Modern Slavery Statement 2019

This statement constitutes the modern slavery and human trafficking statement for the financial year ending December 31, 2019 of Mars, Incorporated and all its applicable subsidiaries whichfall within the scope of section 54(2) of the UK Modern Slavery Act 2015, 2015 including Mars Wrigley Confectionery UK Limited, Mars Petcare UK and Mars Food UK Limited. The statement issigned by the Chief Executive Officer of Mars, Incorporated and approved by the boards of directors of its relevant UK subsidiaries, pursuant to section 54(2).

Introduction
At Mars, we believe everyone touched by our businessshould be treated with fairness, dignity and respect.
We are a privately-held, family-owned company seeking to promote andadvance respect for human rights across our value chain – from farms to our
suppliers’ factories to our own workplaces. For more than 100 years, we’vesought to bring our Five Principles of Quality, Responsibility, Mutuality,
Efficiency and Freedom to life every day, in pursuit of creating shared growthand opportunity across the communities we touch.
In 2017, we launched our Sustainable in a Generation Plan, a set ofinterconnected ambitions across the areas of Healthy Planet, Thriving People
and Nourishing Wellbeing, supported by a USD 1 billion investment. Our
ambition in the area of Thriving People is to enable 1 million people in ourvalue chain to thrive by driving meaningful improvements in their working
lives. The core focus areas of this ambition are increasing income, respecting
human rights, and unlocking opportunities for women.
• Increasing Income: Our goal is for everyone working within our extended
supply chains to earn a sufficient income to maintain a decent standardof living.
• Respecting Human Rights: Our goal is for everyone touched by ourbusiness to be treated with fairness, dignity and respect.
• Unlocking Opportunities for Women: Our goal is to unlock opportunities
for women in our workplaces, marketplaces and supply chains.

Modern Slavery Statement 2019

The world we want tomorrow starts with how we do business today. Today,
millions of people work hard around the world to produce raw materials andproducts across global supply chains, but many are living in poverty or are
vulnerable to exploitation. Data from the International Labour Organization(ILO) shows that 16 million people working in the private economy are in
conditions of forced labor worldwide1. Global businesses like ours want to do
more to ensure that work empowers people. We believe that forced labor in
any of its forms has no place in our operations or supply chains and thatbusiness, government and civil society must work together to make progresson this complex issue.
Forced labor is defined in the ILO’s Forced Labour Convention of 1930 as “allwork which is extracted from any person under the menace of any penalty
and for which the said person has not offered himself voluntarily.” The ILO
indicates that most situations of modern slavery and human trafficking are
included in their definition of forced labor. As a company committed toadvancing respect for human rights, we have prioritized action on forcedlabor and hazardous child labor as salient issues.
This disclosure is our fourth Modern Slavery statement, in compliance with the
UK Modern Slavery Act of 2015. It contains relevant foundational context fromour previous statements, as well as updates on our efforts to address forcedlabor, including modern slavery and human trafficking, which are corecomponents of our global human rights strategy and programs.

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Business Structure

Policies & GovernanceFor generations, we’ve been making many of the world’s
most loved and iconic brands – across chocolate,confectionery, pet food and food for people, as well as
providing vet health services.

Advancing respect for human rights is a cross-functional
responsibility embedded within our global business. A
dedicated global human rights team establishes ourhuman rights policies, strategies and programs andprovides expertise and guidance to colleagues aroundthe world engaged in this work.

We want that to continue for generations to come, and we know that as a
global business we have the responsibility to advance respect for humanrights across our business and the supply chains we depend on. We have USD$40 billion in annual sales from our business categories of Mars Petcare, Mars
Wrigley, Mars Food, and Mars Edge.

More than 125,000 Associates areworking across our more than 450 sites
including manufacturing facilities,
offices and other workplacesin 80 countries.

To govern the application and implementation of our policies, our Human
Rights Steering Committee meets regularly to review our progress, challenges
and opportunities. Executive oversight supports this governance andcontinued assessment of plans and performance. Our Board of Directors is
informed annually of our human rights plans and performance. Our policies
include a focus on the elimination of forced labor as a critical component of
our overall human rights approach.
Our Human Rights Policy is informed by the United Nations Guiding
Principles on Business and Human Rights, the International Bill of Human
Rights, and the International Labour Organization's 1998 Declaration on
Fundamental Principles and Rights at Work. It articulates our commitment torespect human rights –with an initial focus on our operations, and in sourcing
where we can have the greatest impact, with a particular emphasis on
potentially vulnerable groups.
Our Supplier Code of Conduct is informed by the same international humanrights standards. It describes the human rights standards we expect our firsttier suppliers to uphold, covering forced labor, including modern slavery.
The Code prohibits the use of all forms of forced labor, including any form ofprison, trafficked, indentured or bonded labor.

Modern Slavery Statement 2019

Our Human Rights Approach
Focus Areas
In 2015, we identified forced labor and child labor as the human rights issues thatmay pose the most severe risk to people in our supply chains, based on
consultations across our business, review with leading human rights experts andanalysis of publicly available risk information. Even as we work to advance respect
for all rights, we place special emphasis on these salient issues, and we prioritize
actions that reach the most vulnerable people. A variety of factors may increase aworker’s vulnerability to human rights risks, such as temporary or seasonal work
status, lack of legal protections, poor enforcement of legal protections, or
problematic laws that inhibit respect for rights. Migrant workers, women andchildren are particularly vulnerable to human rights risks. Appropriate
remediation approaches may vary based on the issues present.

Priority Industry Principles
We are taking action in our business and supply chains to advance The Consumer
Goods Forum’s (CGF) Priority Industry Principles on Forced Labour. We played aleadership role in the development of these principles as co-chair of the CGF’s
Social Sustainability Committee, as we believe industry-wide focus and action on
this issue is urgently needed.
The Principles align with our existing human rights approach and provide an
opportunity for us to strengthen work that seeks to identify and address forcedlabor. They are straightforward and when applied by industries at scale, they may
help stop situations that lead to forced labor – especially amongst vulnerable
workers. CGF members have an agreed action plan to advance the Principles that
includes a focus on own operations, engagement with suppliers across industries,
and an emphasis on Southeast Asia.
Modern Slavery Statement 2019

Consumer Goods Forum
Priority Industry Principles

Our Human Rights Approach
Due Diligence & Understanding Risk

Human Rights Due Diligence Regulation

A foundational step in our human rights due diligence approach is supply
chain mapping and traceability analysis, which provides us with essential
information about our extended supply chains. As we increase ourunderstanding and level of traceability, we work with partners such as Verité
and Verisk Maplecroft to better understand human rights risk at the country
and regional level.

We believe all need to take action to fix what is broken about global supply
chains. National governments must enforce and strengthen their own labor
laws, and companies have a responsibility to conduct due diligence to identify
and respond to human rights risks.

We use publicly available data from sources such as the U.S. Department ofLabor, United Nations Development Program, public media and civil society
reports, and proprietary analysis provided by Verisk Maplecroft’s team of
human rights risk analytics experts. This includes the identification of uniqueregional risks, such as the significant migrant labor workforce in the Middle
East. This analysis drives the creation of human rights risk scorecards that
inform the development of our human rights action plans.
Based on the specific risks identified, our global human rights team advises
and supports colleagues across the business on additional due diligence tools.
This due diligence, often implemented with independent human rights
experts, may include further desk research, validated self-assessment
questionnaires, audits, or human rights risk assessments.
In 2019 we developed a Mars position in support of practical human rights
due diligence, and we supported a coalition advocating for this approach.

Modern Slavery Statement 2019

Mars supports strengthened, harmonized regulation of human rights
due diligence requirements for companies in global supply chains,aligned with the UN Guiding Principles on Business and Human Rights.
We believe this can both benefit people working in global supply chains
and set clear expectations for companies – raising the bar so thateveryone is held to the same high standards. Stronger regulation is a key
part of creating the change we need to see: supply chains where rights
are respected and everyone has the opportunity to thrive.
Mars has been conducting voluntary due diligence on our own facilities,
with priority Tier 1 suppliers and in priority extended supply chains, andwe continue to expand this work. Undertaking due diligence inalignment with international standards is fundamental to advancing
respect for human rights in our value chain.
We also believe that businesses, governments and civil society must
work together to address the root causes of human rights risks – this isessential to building inclusive and sustainable supply chains. Morecoordinated and impactful collaboration is needed to identify drivers ofrisk and to deliver results in areas such as migrant labor markets, incomein agricultural supply chains, women’s rights and access to quality
education.

Our Human Rights Approach
Care Framework

Framework in Action

Drawing on the United Nations Guiding Principles on Business and Human
Rights (UNGPs), we have developed an action-oriented framework to guidehuman rights decisions and actions across our business. These actions include
a focus on forced labor. This CARE Framework informs our strategy andplanning development through four key phases – Commit, Assess, Respond,
Engage. We use this framework to develop Human Rights Action Plans forpriority raw material supply chains. We have developed a Practitioners’ Guide
to the CARE Framework, and we train relevant internal teams in applying theframework, which includes the following steps.

Commit: Forming a cross-functional team with clear accountabilities andgovernance processes. Identifying or creating relevant policies, standards
and practices. Allocating appropriate resources to support successful
activation of the agreed plan.
Assess: Conducting human rights due diligence in order to understandrelevant human rights impacts including where possible, input from
impacted people and local communities. Consulting with human rights
experts to understand structural dynamics, root causes and relevant
context.
Respond: Seeking to prevent, address and/or remediate human rights
impacts, either directly or in close collaboration with industry, governmentand civil society. Such actions may include monitoring and verification
systems, awareness raising and training, grievance mechanisms,
remediation of individual cases, and addressing the enabling environmentand root causes.
Engage: Engaging externally to learn from and collaborate with others
and to share our own progress and challenges transparently. Seeking tomobilize or join key industry coalitions and to drive collective action acrosssectors to meet shared goals.

Modern Slavery Statement 2019

Mars Human Rights Strategy
Our human rights strategy is focused on deploying programs in three areas – in our own operations, with our first-tiersuppliers, and in our extended supply chains. We are developing and testing customized human rights training andtools across our programs in all three areas, which include a focus on forced labor.
Responsible Workplace
Mars has always prioritized creating and maintaining
great workplaces where our Associates can thrive.
Our Responsible Workplace program aims to ensure thatthe human rights of all workers in our workplaces are respected.
We hold ourselves to standards and expectations in our own facilities,
and continue to demonstrate what we are learning and actions we aretaking as a part of this program.
No company operating in the global economy today is immune to humanrights risks, including forced labor. Taking a deep look at our own
manufacturing operations has helped us to better understand these risks andthe types of safeguards needed to ensure that human rights are respected.
We will continue to evaluate our facilities on a routine basis while expanding
our efforts to address potential risks.
We engage independent auditors with expertise in labor issues to assess ourhuman rights performance in our workplaces. Any non-compliances that are
identified are addressed. Our Responsible Workplace Site Implementation
Guide details our human rights standards and expectations for our own
workplaces, including a prohibition on forced labor. We also seek to ensurethat all Associates in Mars workplaces are aware of and have access to ouraccredited Ombudsman program through which they can confidentially andanonymously report any workplace issue.

Modern Slavery Statement 2019

Updates
In 2018, we achieved a major milestone in the Responsible Workplace
program – reaching 100% of our 121 in-scope manufacturing sites across
29 countries, including evaluation of forced labor risks. Understanding theserisks in our own facilities generates important insights and has helped us
ensure we are holding ourselves to the same standards we expect of ourbusiness partners.
In 2019 we built on this work, conducting new assessments in 55
manufacturing sites in 20 countries. We also are continuing ongoingengagement to improve practices of labor and service providers, including a
focus on recruitment practices, contract procedures and management ofworking hours. We terminated business with six labor and service providers
who were not able to meet our human rights standards.
Moving forward, we are expanding our focus beyond manufacturing sites toadditional parts of our direct operations by 2025.

Mars Human Rights Strategy
Our success in growing our business while delivering positive social and environmental impacts depends onhigh performing suppliers and supply chains. We expect our first-tier suppliers to respect human rights,
environmental standards and ethics in their workplaces.
Next Generation Supplier• We continue to align all of our suppliers with our social, environmental andethical expectations through our Supplier Code of Conduct.

In 2011, we developed our Supplier Code of Conduct,
which describes our human rights, ethical andenvironmental expectations of first-tier suppliers,
including a prohibition on forced labor, and we initiatedour Responsible Sourcing Program.

• We assess the sustainability performance and social compliance audit
results of prioritized suppliers using the EcoVadis online platform,
leveraging this widely recognized supplier evaluation tool while also
unlocking increased visibility and insights.

This program engaged our first-tier suppliers around the world in improving
their sustainability performance through an industry-standard approach thatleveraged third-party, on-site social compliance audits to identify workplaceissues and drive change where risk is highest.
However, research shows that it is difficult to address the root causes of themost complex sustainability challenges through audits alone – and, that it iscritically important to engage workers in identifying issues and shaping
solutions.
In 2019, we launched our Next Generation Supplier program – an enhanced
approach with a focus on better engaging our suppliers as they deliver
greater positive impact in their workplaces. Our Next Generation Supplier
program builds on years of experience and long-standing commitments while
introducing new tools and technologies that we believe will deliver better
results for our suppliers and the people who work in our supply chains.

Modern Slavery Statement 2019

• We support certain suppliers of our top 10 raw materials, and otherstrategic suppliers, as they advance their performance through a new,longer-term model focused on driving systemic change and engagementof workers. This model leverage the expertise of external advisors,
including our global strategic human rights partner Verité.
We will assess the impact of this work with the goal of understanding the realdifference it makes for people in our value chain and the planet we all share.
Our aim is for this program to help us achieve our goal of working with
suppliers that share our values and commitments and cease work with those
who are unable or unwilling to meet our expectations.
As part of our commitment to building supplier capability, we periodicallyengage suppliers in awareness raising and third-party training initiatives inorder to drive continuous improvements. All of our Commercial Associates are
expected to take our Next Generation Supplier training course, which
includes content on our human rights standards and expectations of our
suppliers, including with regard to forced labor.

Mars Human Rights Strategy
At Mars, our sustainable sourcing efforts focus on addressing five sustainability impacts – greenhouse gas, water,
land, human rights and income. This work begins with seeking traceability of our supply chains, understanding risks,and developing and implementing strategies to drive improvements.
Human Rights in Sustainable Sourcing
We believe some of the highest risks to people may
appear at the farthest end of supply chains, where
we typically have low or no influence, visibility or control.
We focus on advancing respect for human rights in our extended supply chains,in close collaboration with our suppliers, their business partners, the industry,
government, and communities. We prioritize work on supply chains in which themost severe human rights risks, including forced labor, may be present, including,for example, cocoa, fish, and palm oil.
In 2018, we updated our Practitioner’s Guide to Human Rights in Sustainable
Sourcing, with detailed guidance on activating our CARE Framework anddeveloping human rights action plans, including elements related to forced labor,
where relevant. In 2019, we launched additional guidance material focused on
how procurement teams can engage suppliers as they develop approaches toaddress key risk factors. Tailored training is provided to relevant teams internally.
The United Nations Guiding Principles on Business and Human Rights outlines therole of government to protect human rights and the role of business to respect
rights. The following pages outline examples of our human rights approach andefforts to advance respect for rights in extended supply chains in which humanrights challenges are systemic. In each, we recognize the importance ofcollaboration to address root causes and structural barriers to progress.

Modern Slavery Statement 2019

Mars Human Rights Strategy in Action
Cocoa

Updates

Cocoa for Generations is our integrated approach to sourcing cocoa
responsibly and working toward sustainable practices. By 2025, we aim to
be traceable (from the farmer to the first point of purchase) and will workwith our suppliers and certifiers with the goal of deploying child labormonitoring and remediation systems to 100% of our at-risk cocoa supply
chain. Early indications show that these systems have the potential to halve
the risk of hazardous child labor among participating families.

In 2019, we issued our first annual Cocoa for Generations report on progress
and in early 2020 we launched our Protecting Children Action Plan. We
have begun to activate this plan, which includes four mutually reinforcing
elements:

Through our collaborations with the International Labour Organization andthe International Cocoa Initiative (ICI), and through our leadership role in
the World Cocoa Foundation, we are seeking to drive impact and industry
action. As members of ICI, we supported research conducted by Verité in2017 and 2018 to understand drivers of forced labor risks in the West
African cocoa sector. The research found that while forced labor risk ispresent in the cocoa sector in Côte d’Ivoire, it appears to be limited
primarily to a narrow group of people: recently arrived migrant workers.
These insights are valuable and build on research conducted by Tulane
University and Walk Free Foundation, which estimated that 0.42 percent of
adults working in cocoa experienced forced labor in Côte d’Ivoire between
2013 and 2017, and that 0.17 percent of children working in cocoa
agriculture in Côte d’Ivoire were forced to work by someone other than aparent. Mars and other companies across the industry are designingapproaches to address these forced labor risks and to support governmentsin their response, with technical input from Verité and others. This work
includes forced labor training by third party experts – including awarenessraising materials for suppliers, guidance on contracting, and integration offorced labor risk indicators into existing child labor monitoring systems.

Modern Slavery Statement 2019

1. Robust Child and Forced Labor Monitoring and Remediation Systems: Our firstpriority is to ensure our suppliers have in place robust child and forced labormonitoring and remediation systems designed to identify, prevent and seek toremediate cases of child labor and forced labor as relevant. We anticipate needing toreach more than 150,000 cocoa farming households in Ghana and Côte d’Ivoire tomeet our ambitions, taking action in other origin countries as appropriate.
2. Women’s Social and Economic Empowerment: Through our partnership with CARE,
a leading international humanitarian agency, and our chocolate brand DOVE®,
we are supporting Village Savings and Loan Associations in Cote d'Ivoire.
As of year-end 2019, these groups create training and savings mechanisms for morethan 12,000 members in nearly 45 cocoa-growing communities, with a focus on
women and resulting in more than $700,000 in total savings. In 2020, we expanded
our partnership with an additional $10 million investment to reach more than 50,000
women in Ghana and Cote d’Ivoire by 2025.
3. Increasing Access to Quality Education and Development Opportunities forChildren: Since 2017, we have worked with the Transforming Education in Cocoa
Communities program on insights into the powerful linkages between robust
monitoring systems, women’s empowerment and education interventions. In early
2020, we committed to invest $3 million in a new a public-private collaboration toincrease access to quality education in Côte d’Ivoire and Ghana, led by the Jacobs
Foundation.
4. Increasing Income: We directly support farmers income through the premiums wepay them, and indirectly through the training and support we provide on
productivity and income diversification. We are piloting models for increasing
productivity and diversifying household income, through other cash crops and nonfarm earnings – in collaboration with suppliers, expert implementation partners andthe Farmer Income Lab.

Mars Human Rights Strategy in Action
Palm Oil

Updates

Since 2013, we have purchased 100% Roundtable for Sustainable Palm Oil
certified palm oil, and we are working to go beyond certification as we seek
to ensure that the palm oil we use is produced with respect for human rights.
We expect our suppliers to meet our palm oil standards and to engage with
their suppliers to advance respect for human rights in their extended supply
chains, with a particular focus on risks facing vulnerable migrant workers.

In 2019, we announced our Palm Positive Plan, aiming to deliver 100%
deforestation-free palm oil by the end of 2020 and advance respect forhuman rights across our suppliers’ extended supply chains. The plan seeks tosignificantly simplify the Mars palm oil supply chain, with the goal of movingfrom more than 1,500 mills to fewer than 100 in 2020, and further reductions
by 2022. We publish our Tier 1 palm oil suppliers and mill lists, updating as
consolidation progresses.

In 2017, we began a collaboration with our global strategic partner Verité andwith one of our palm oil suppliers, Wilmar, to build supplier capability andcapacity to address human rights issues in extended supply chains – with afocus on forced labor risks.
The collaboration with Wilmar and Verité included assessment of Wilmar’s
current systems, customized training and development of concrete ways tostrengthen existing policies and practices. Verité has provided coaching andtraining to Wilmar focused on improving their system to understand andaddress human rights issues across their supply chain. Informed by thisexperience, Verité plans to disseminate new tools that may be useful to otherpalm oil suppliers as they build their own human rights approaches inextended supply chains.

Modern Slavery Statement 2019

With a shorter supply chain comprised of partners who are committed todriving improvements in management systems and working conditions, we
can increase accountability, influence and connectivity. This approach is
focused on deeper relationships with suppliers and engaging with our Tier 1
suppliers as they build their capabilities to monitor, address and prevent
human rights risks in their supply chains.
As we begin this stepped-up engagement, we’re committed to sharing ourlearnings along the way through regular public updates and engagement inindustry forums. We continue to support the Consumer Goods Forum palm
oil working group, which commissioned research to identify risks of forcedlabor in the palm sector in Indonesia and Malaysia in 2018. Insights from thereport are informing where we prioritize action, including work on humanrights due diligence systems in the palm oil sector.

10Mars Human Rights Strategy in Action
Fish
In 2016, we launched our first Thai Fish Supply Chain Human Rights Action
Plan which includes key performance indicators and uses the CARE
Framework. As we advance this work, the sector continues to face complex
challenges. Nonetheless, we are making progress.
As we continue learning more about how best to collaborate with our
suppliers, how to form and activate the right partnerships and how tocontribute to driving industry-level change, we remain focused on driving
positive impact. Additional details on this work are available here.
In the first phase of our Human Rights Action Plan work, we focused onincreasing traceability, developing a better understanding of working
conditions in our supply chain and building relationships of trust across our
supply chain and the sector. We have mapped our Thai fish supply chain, andmost of our Tier 1 suppliers continue to participate in the Issara Institute’s
Inclusive Labor Monitoring (ILM) model, which includes access to a multilingual hotline and online application where workers can report issues andseek assistance as needed.
The Issara Institute, a local NGO with unique networks among vulnerable
migrant workers in the Thai fish industry, shares these findings with suppliermanagement and facilitates resolution of issues raised. In addition to thiswork with the Issara Institute, we are engaging with a range of partners inefforts to assess and improve conditions for workers.

Updates
In 2019, we issued an update on progress and outlined some of our next
steps, including:• Our support to direct suppliers as they strengthen their own supply chain
human rights management systems• Work underway with suppliers and partners to test new approaches toaddress human rights risks at the vessel level – identifying what works andcan be taken to scale– Including work with USAID Asia and Thailand CTIP projects, implemented byWinrock International, to test new approaches to promote connectivity at sea,address human rights risks, and promote fair and ethical recruitment practices.

• Working with partners in industry, government and civil society to better
identify and begin to address root causes.
We have hired an additional senior role with deep expertise in human rights,
who is based in Thailand and will lead implementation of the next phases.
This includes a focus on identifying effective remediation approaches andadvocating for structural changes needed in the migrant labor market,
together with other companies, civil society organizations and government.

Other Supply Chains
We are working to better understand the nature of human rights risks, including
forced labor, across other supply chains we rely on as a business and to identify
how we can play the most appropriate role in driving change.

Modern Slavery Statement 201912

Stakeholder Engagement

A key component of our approach to human rights is engaging with credible third-party experts andstakeholders, deepening our awareness and understanding of these complex issues and identifying partners todrive action. Our efforts include engaging workers and community members. The following are examples of our
stakeholder engagement with a focus on forced labor.
Verité: Global Strategic Partner

United Nations Global Compact (UNGC)

In 2017, we launched a long-term, strategic partnership with Verité –a leading nonprofit and global expert on labor rights with more than 20 years
working to ensure people worldwide are in safe, fair and legal working
conditions.

In 2015, Mars became a signatory of the Global Compact. We issue an annual
communication of progress that outlines our efforts across the Compact’s ten
principles, which include seeking to eliminate all forms of forced andcompulsory labor.

Our comprehensive partnership is designed to take action, foster new
insights, and lead dialogue on critical global human rights challenges.
Our work together includes a focus on forced labor, with collaboration on
initiatives across our full human rights program – in Mars operations, with our
first-tier suppliers and in high-risk extended supply chains.

Business for Inclusive Growth (B4IG)

Verité is advising Mars on our global human rights strategy, policies andpractices, and together we are gathering insights, generating new researchand promoting dialogue to inform action across the business and humanrights community. More information about our work together is available
here and in our first partnership update.

In 2019, Mars joined the Business for Inclusive Growth coalition, together
with 37 companies committed to taking action to ensure the benefits ofeconomic growth are shared far more widely. The coalition is focused on
advancing human rights in direct operations and supply chains; building
inclusive workplaces and strengthening inclusion in company value chainsand business ecosystems. Our CEO, Grant F. Reid, joined the coalition launchon the margins of the G7 Summit, and we are active members in designingpriority areas of focus and impact.

Institute on Human Rights and Business (IHRB)

Alliance 8.7
Alliance 8.7 encourages businesses and other stakeholders to act on United
Nations’ Sustainable Development Goal 8.7 to eliminate forced labor and theworst forms of child labor. Mars is a founding member of the ILO’s Child Labor
Platform and an early supporter of the Business Network on Forced Labor,
the two key business platforms of Alliance 8.7.
Modern Slavery Statement 2019

In 2017, we joined IHRB’s Leadership Group on Responsible Recruitment,
underscoring our commitment to this critical topic and recognizing that
recruitment fees paid by migrant workers are a key contributor to forcedlabor. Through our participation in this group, we’re joining collective action
toward the vision of eradicating worker fees over the next ten years.

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Stakeholder Engagement
The Consumer Goods Forum

Agricultural Supply Chain Forums and Certifications

For the past five years, we played a leadership role within CGF to champion
the importance of business action against forced labor. Grant F. Reid, our
President and CEO, serves on the CGF Board where he is co-chair of theGovernance Committee and co-sponsor of the Forest Positive Coalition.
He previously sponsored CGF’s Sustainability work. Barry Parkin, our Chief
Procurement & Sustainability Officer, previously co-chaired CGF’s
Sustainability Steering Committee, and we are active members of the Human
Rights Coalition – Working to End Forced Labor.

We participate in a number of multi-stakeholder forums whose mandates
include action on human rights and forced labor in global supply chains, suchas the World Cocoa Foundation, the Sustainable Seafood Taskforce, theRoundtable on Sustainable Palm Oil and others across our priority raw
materials. We also work closely with the major global certification
organizations: Rainforest Alliance and Fair Trade.

Members of CGF’s Human Rights Coalition will implement human rights due
diligence systems with a focus on forced labor risks, covering 100% of theirown operations by 2025. Additionally, members are working with selectedsuppliers in the palm oil sector to develop human rights due diligencesystems within their supply chain, from refinery to plantation level, by 2023.
In 2018, Grant F. Reid spoke at the Global Forum on Responsible Recruitment
and Employment in Singapore, continuing to champion focus and action
against forced labor. His remarks challenged business, government and civilsociety to focus on collaboration and demonstrate substantive progress to
end forced labor in global supply chains. In 2019, he reiterated this call toaction ahead of CGF’s Global Summit in Canada and stressed the urgency ofbusiness and governments to demonstrate results.

Modern Slavery Statement 201914

Update on 2019 Actions
In our third Modern Slavery Statement, we referenced specific next steps in our work to address forcedlabor risks. This is an update on our progress and a look ahead to some efforts currently underway.

Performance Measures: In 2019, we tested an emerging
KPI framework for our human rights work, to track andmeasure progress. We have strengthened the concept andbegun to pilot it in key supply chains.
Engaging Across Sectors: Mars convened a practitioner
dialogue on the work in palm oil that we supported,
involving Wilmar and Verité, bringing together brands,
retailers and palm oil producing companies to discuss
lessons learned. Together with Verité, we also led aworkshop on the CARE Framework and tested this tool withmore than 50 leaders from business, government and civilsociety.
Mars also participated in advocacy roundtables with the
Malaysian and Thai governments in 2019, together withmembers of the Consumer Goods Forum and the Institutefor Human Rights and Business, focused on responsible
recruitment.

Modern Slavery Statement 2019

Supplier Engagement: In 2019, we launched our new
Next Generation Supplier Program across 30 countries withmore than 500 suppliers.
Transparency: We continued to share our progress andchallenges, including our learnings from using the CARE
Framework and publication of supply chain details acrosscocoa and palm oil.
Training: Since the launch of the Next Generation Supplier
program, we have trained more than 350 Procurement
Associates. We now have a required internal training on our
Supplier Code of Conduct, as well as a training course on
the fundamentals of the Next Generation Supplier program.
We published a new, comprehensive training guide forsuppliers which includes suggestions for developing
management systems to identify, address and prevent
forced labor risks.

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Looking Ahead
Addressing forced labor, including modern slavery and human trafficking, will continue to requireconcerted action by businesses and close collaboration with government and civil society. We arecommitted to moving forward and to working closely with others to drive progress. As we advance thiswork in 2020, some of our key initiatives include a focus on:
Performance Measures: Continuing to develop a KPI
framework that aims to capture changes in management
systems and changes in key human rights risks, acrosspriority supplier and origin sites.
Progress in Priority Supply Chains:• Implementing our Cocoa for Generations strategy –scaling-up the coverage of child and forced labor
protection systems implemented by suppliers, while
also investing in education, income and women’s
empowerment to address the root causes of theseissues with partners like CARE.
• Implementing our Palm Positive plan, with the aim toengage in longer-term, in-depth supplier initiatives
focused on human rights, together with partners such as
Verité and others.

Supplier Engagement: Continuing to roll-out of our
Next Generation Supplier program and understand its
impact. Engaging our direct suppliers in new ways todrive change – evolving our worker voice and on-site
tools as we learn more about what works.
Responsible Recruitment: Strengthening guidance tosuppliers on responsible recruitment – enhanced
practical steps outlining ways to apply the Priority
Industry Principles on Forced Labor.
Training: Continuing to deepen our training approachinternally, support our direct suppliers and into expand
extended supply chains – developing and deploying
new material that better equips teams to drive
meaningful change.

• Developing and implementing the next phase of ourwork on human rights issues in the Thai fish supply
chain, with a focus on effective remediation approaches
and advancing advocacy for structural changes in the
migrant labor market.
Modern Slavery Statement 201916

This statement constitutes the modern slavery andhuman trafficking statement for the financial year
ending December 31, 2019 of Mars, Incorporated andall its applicable subsidiaries which fall within thescope of section 54(2) of the UK Modern Slavery Act
2015, including Mars Wrigley Confectionery UK
Limited, Mars Petcare UK and Mars Food UK Limited.
The statement is signed by the Chief Executive Officer
of Mars, Incorporated and approved by the boards of
directors of its relevant UK subsidiaries, pursuant tosection 54(2).

Grant F. Reid
Chief Executive Officer
Office of the President
Mars, Incorporated
June 2020

Modern Slavery Statement 2019

To learn more about our
Human Rights approachand Sustainability programs
please visit
www.mars.com/sustainable-plan