DANONE POLICYON ADVOCACY

PUBLICATION DATE: December 2023

Version

5.0

History

December 2023 – version 5
July 2020 – version 4
December 2019 – version 3
June 2017 – version 22011 – version 1

Approval procedure

Approved by the General Secretary of Danone-

Target Group

Danone employees of all companies controlled
by Danone’s affiliates and subsidiaries;
Employees of all agencies contracted byDanone and its affiliates who conduct lobbying
and/or advocacy and who are in contact withauthorities, organizations and policymakers
worldwide on behalf of Danone.

Document Owner

Danone’s Public Affairs and Compliance Departments

Level of Confidentiality

External Use

Number of Pages

22

Languages

English©Danone 2023 – No reproduction allowed.

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TABLE OF CONTENTS
01. DANONE'S VISION OF ADVOCACY

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02. DANONE'S ADVOCACY IN ACTION

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2.1 Who this policy applies to
2.2 Advocacy and our stakeholders
2.3 Topics we advocate on
2.4 Channels we use for advocacy
2.5 Our professionals’ behavior
2.6 Governance of our advocacy
2.7 External reporting on our practices

03. APPENDIX
Appendix 1a: Danone’s memberships of global and regional tradeassociations, multi-stakeholder coalitions and business platforms
Appendix 1b: Danone’s trade association memberships in the field ofmaternal, infant & young children nutrition
Appendix 2: The EU Transparency Register
Appendix 3: The United States’ Lobbying Disclosure Act

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01 DANONE’S VISION OF ADVOCACY
HOW WE DEFINE ADVOCACY AND WHY IT IS IMPORTANT FOR DANONEFor over fifty years, Danone has advocated that businesses need to take responsibility for the
impact they have on society and their ecosystem. As early as 1972, our founder Antoine Riboud
outlined the fundamental interdependence between performance and sustainability in a pioneeringspeech – which became Danone’s “dual project”. Today, as the responsibility of business is under
scrutiny like never before, we continue to act and advocate, convinced that companies can andshould contribute to positive change.
We believe companies like ours can use our reach and scale for positive impact, creating bothshareholder and stakeholder value. If we are honored a seat at the table, we can provide ourexpertise for more informed decision-making, in a collaborative and transparent environment withdecision-makers and other relevant stakeholders.
Danone believes that the purpose of advocacy is to build common ground, driving engagement andaction between stakeholders with a view to developing common solutions to some of the challenges
facing our society. This is in line with the UK House of Commons Public Administration SelectCommittee’s views on the topic1: “Lobbying is essentially the activity of those in a democracy
making representations to government on issues of concern. The Government is committed toprotecting this right from improper use while at the same time seeking to avoid any unnecessary
regulation or restriction. As well as being essential to the health of our democracy, its free andproper exercise is an important feature of good government. Those who work within government
should have no monopoly on the advice that Ministers use to make their decisions. The moreindividuals and groups outside government engage with the policy-making process and the broader
the base of advice and evidence used to take decisions, the better those decisions tend to be.”We have a shared interest – and responsibility – in finding solutions to the public health, social andenvironmental challenges the world is currently facing. Our business will not succeed if we don’t
work with policymakers and engage with other stakeholders in our common mission to bring healththrough food to as many people as possible. We cannot deliver and share growth sustainably if wecannot source the ingredients we need, or if the communities we operate in are struggling. Our
business success depends clearly on our ability to meet society’s expectations.
To ensure that we can work collectively with others to have a positive impact on public health,social and environmental challenges – and to retain our seat at the table – we fundamentally
believe in the importance of accountability, integrity and responsibility in our advocacy activities.

Cf. the UK House of Commons Public Administration Select Committee’s report on “Lobbying: Access and influence in Whitehall:
Government Response to the Committee's First Report of Session 2008–09”,
https://publications.parliament.uk/pa/cm200809/cmselect/cmpubadm/1058/1058.pdf
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We are committed to sustainable lobbying and advocacy practices that:
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Recognize the central role of governments in policymaking.
Support an inclusive and democratic process for decision-making, recognizing andsupporting others’ability and right to advocate and participate.
Respect lobbying legal frameworks and codes of conducts of the countries we operate in.
Support evidence-based policymaking based on peer-reviewed science – in our work, welook for consensus scientific positions and expert panel opinions.
Respect planetary boundaries – in accordance with the objectives laid out in oursustainability strategy, the Danone Impact Journey, as well as our commitments under our
status as a“Société à Mission”and a growing B Corp.

We are convinced that, when done with integrity and accountability, corporate advocacy can help
support good policymaking and lead to improved outcomes for all stakeholders. This is why, beyond
respecting lobbying legal frameworks and codes of conducts in the countries we operate in, we
advocate and strive for higher transparency and accountability standards.

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02 DANONE’S ADVOCACY IN ACTION
2.1. WHO THIS POLICY APPLIES TO
This policy applies equally to all Danone employees of all companies controlled by Danone’s
affiliates and subsidiaries, as well as to contracted partners who conduct lobbying, influence or
advocacy and who are in contact with authorities, organizations and policymakers worldwide on
behalf of Danone.
Nothing in this policy shall however be construed as limiting theability of Danone employees to exercise their rights to express
their personal opinions, or support, financially or otherwise, thepolitical candidates of their choice in accordance with Danone’s
Code of Business Conduct.
Danone employees and agencies acting on their behalf will notshare views, information and facts concerning Danone withgovernment officials and policymakers unless they are explicitly
authorized to do so by the appropriate Danone entity.

This policy is part of acontinuous learning process,built on our experience since wepublished our first advocacy
policy in 2011.
The content of this policy will be
reviewed and updated as andwhen required.

Avoiding conflicts of interest for public sector recruitment
When recruiting employees from the public sector, Danone ensures that the right balance is struck
between the benefits from such recruitment and avoiding potential conflicts of interest withprevious employer(s). As such, when hiring an employee from the public sector, Danone will follow
the company procedures for handling conflicts of interest and commits to:
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carefully review each individual situation with regards to the new position and previous
responsibilities of the employee in the public sector to avoid any potential conflicts ofinterest.
check any existing contractual confidentiality and restrictive covenants and to comply withthose covenants, if any.
check any existing prohibitions stemming from an individual’s ethic commitment under aprevious government position and to comply with those commitments, if any.
when circumstances require, adapt/restrict the job of the employee coming from the public
sector for a certain period of time. The restriction could consist of forbidding the new
employee to contact his/her former colleagues for a defined period of time for professional
reasons.

2.2 ADVOCACY AND OUR STAKEHOLDERS
When referring to lobbying, influence or advocacy activities, Danone interacts with various
stakeholders including governments and regulators, scientific societies, trade associations,experts, non-governmental organizations (NGOs) and other businesses (both in and out of the foodsector).
It is indeed our conviction that policy-shaping no longer belongs solely to politics but includes awide range of actors. Our dialogue with this multitude and variety of stakeholders helps us to build
comprehensive positions and implement pertinent solutions with impact.
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On top of regular conversations with these stakeholders, we conduct a periodical materiality
assessment2 that helps us refine our understanding of their needs and interests, and therefore
better define and address key challenges.

2.3 TOPICS WE ADVOCATE ON
Danone participates in policy development as a company or industry member in order to fulfill its
mission of “bringing health through food to as many people as possible”.
All key topics we engage on are captured in our materiality assessment3. Our participation in policy
discussions is varied, covering macro-topics like agriculture, circular economy or climate change,
through to more detailed topics such as information to consumers, nutritional care as part of cancer
care or product quality and safety standards. We proactively publish many of our policies andexternal positions on topics on our advocacy agenda, as well as consultation inputs to authorities
or policymakers, made available on Danone’s website.
Sustainability and Climate
We advocate and partner with others on several sustainability topics which are fundamental to ourbusiness’ long-term success and to people, society and the environment.
This includes climate change, regenerative agriculture, watershed preservation and restoration,
circular economy and waste reduction.
We are committed to conducting our advocacy in line with the Paris Agreement and in line with our
climate policy goals outlined above, notably to restrict global temperature rise to 1.5C. Our 2023
Position on Climate Advocacy sets out our commitments, public policy positions and governance on
this important issue.
Nutrition and Health
We are committed to lobbying only in support of measures to improve health and nutrition,
consistent with the public interest and nutrition. We want to and can have a positive impact onnutrition and health, helping to meet public health goals (including tackling obesity, mal- or undernutrition). Our products are consumed regularly by millions of people across the world. We arebuilding on decades of research and scientific expertise to help consumers and patients maintainand support their health through nutritious food and sustainable healthier eating and drinking
choices.
We support evidence-based policymaking based on peer-reviewed science, including for topics suchas interpretive nutritional labelling and fiscal health measures.

According to the Global Reporting Initiative (GRI), ‘materiality’ are “those topics that have a direct or indirect impact on an organization’s
ability to create, preserve or erode economic, environmental and social value for itself, its stakeholders and society at large”. A materiality
assessment is thus a method to identify and prioritize the issues that are most important to an organization and its stakeholders.
3
Danone’s materiality matrix is published in the company’s annual Reference Document, also available on www.danone.com
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Infant and Maternal HealthAs part of its Specialized Nutrition business, Danone is specifically committed to the health andnutrition of mothers and infants from the youngest age. Most importantly, we support the World
Health Organization’s view of the importance of breastfeeding for infant health, namely thenutritional recommendation for exclusive breastfeeding for the first six months of age andcontinued breastfeeding up to two years and beyond, combined with the safe introduction of
appropriate complementary foods. We believe Danone has a role to play in supporting thisrecommendation while empowering parents and caregivers to make informed feeding decisions fortheir babies. Having researched the science of breastmilk and breastfeeding as well as its benefits
for the health of both mother and child for over 50 years, we are convinced that breastfeeding gives
babies the best nutritional start in life.
We are thus committed to fostering a proactive, constructive and evidence-based dialogue
supporting breastfeeding around the world – not undermining public policy frameworks that serve
this purpose – while endorsing the principles of openness, transparency and integrity in our
advocacy activities. Danone is indeed decided to support the design and implementation of
advocacy initiatives in every country where it operates that will contribute to creating anenvironment where all parents feel informed and supported on all questions of infant nutrition. As
this is a shared goal, we aim to work with the UN, governments, civil society organizations, as wellas paediatric / medical societies to develop an evidence-based, shared policy agenda focused onincreasing breastfeeding rates, supporting parents and the improved nutritional health of infants
and mothers. We are ready to take a leadership role, mobilizing industry engagement. As a first step
we will support the adoption, implementation and, critically, enforcement of national legislation tomeet the needs of each market in line with the above nutritional commitments and commitments,
to create a level-playing field.
Higher transparency and accountability advocacy standards
Danone also works across the industry, governments, and civil society to promote and support
higher transparency and accountability standards around advocacy. In particular, Danone
supports the International Food & Beverage Alliance’s Guiding Principles for Multi-stakeholder
Engagement. These principles, developed in May 2019, include mutual & shared benefit;
environment of integrity, respect and trust; and accountability and transparency, amongst others.
Danone is part of the OECD Trusted Dialogue on Getting Influence Right developed as part of the
Global Initiative to Galvanize the Private Sector as Partners to Combat Corruption. This dialogue
brings together a diverse community of government and business representatives to discuss key
political engagement challenges facing relevant sectors, identify core principles of responsible
corporate political engagement, and develop implementation guidelines on responsible politicalengagement for the private sector.
Additionally, we exchange regularly with experts and NGOs on corporate political engagement to
inform our positions and adopt best practice, including with the not-for-profit The Good Lobby. We
assessed our commitments and practices against The Good Lobby Tracker, the first systematic
assessment of virtually all major corporate political responsibility reporting initiatives, fromsustainability frameworks to ESG ratings.

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2.4. CHANNELS WE USE FOR ADVOCACY
Danone’s advocacy can take the form of stand-alone activities, engagement through tradeassociations or through multi-stakeholder coalitions.

a) Danone stand-alone activities
This includes traditional bilateral or multilateral meetings or events that Danone organizes and/or
attends with various stakeholders, with the objective of conveying its position on a given topic.

b) Trade associations
Danone is a member of numerous trade associations, which can be industry sector-based or topicbased, at local, national4, regional or international levels. The company’s participation varies also
depending on our level of engagement (e.g. member of the Board of the trade association,
involvement in a specific working group, etc).
Danone employees playing an active role as members of these trade associations must havesufficient seniority and authority to participate actively in discussions within the association.
Particular care is given to their training to ensure that they comply with Danone’s internal
standards on trade association memberships, and most importantly do not engage into any anticompetitive activities. When representing the trade association in meetings with government
officials or policymakers, Danone employees must also make it clear that they are Danone
employees and not employees of the association whose views they are representing.
Danone will not tolerate any governance conflict of interest within its different trade associations’activities and is fully compliant with the competition law rules its trade associations are subject to.
We are conscious of the importance of alignment between our own public positions on topics andthose of the trade associations we are a member of. As outlined in the Governance section of thispolicy, we have developed internal guidance and training for our teams to detect and address any
occasions of misalignment.
In the spirit of transparency, we have published a list of Danone’s memberships of tradeassociations, organizations, multi-stakeholder coalitions and business platforms which can befound in Appendix 1. This list is updated annually, and accurate to the best of our knowledge at thetime of update.

c) Multi-stakeholder coalitions
Our impact is collective. For over 50 years, since the launch of the Danone dual project, we havebeen working with and through a growing ecosystem of impact platforms and partners.
Multi-stakeholder coalitions bring together diverse parties united by a common vision and policy
ambition, ensuring we are focused on the right issues and deploying our resources in the right ways
to maximize the scale of impact.

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In the United States for example, Danone is a member of both state-level trade associations, as well as US/federal-level associations.

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We seek to build multi-stakeholder coalitions that:Are thematic, not sectorial
Are inclusive, bringing together actors from all backgrounds (policymakers, peers and otherbusinesses, NGOs, academia…)
share a common policy ambition and drive business commitments
have a flexible organization, which is not necessarily formalized into a legal entity.

Examples of multi-stakeholder coalitions built by Danone include the Food Reform for Sustainabilityand Health (FReSH), the One Planet Business for Biodiversity coalition, the Business for Inclusive
Growth Platform (B4IG). Danone is also engaged in multi-stakeholder coalitions around circular
economy, including the Global Commitment on Plastics, spearheaded by the Ellen MacArthur
Foundation in collaboration with the United Nations Environment Program, and the BusinessCoalition for a Global Plastics Treaty, convened by the Ellen MacArthur Foundation and WWF, in
collaboration with aligned businesses and supported by strategic NGO partners.
Training targeted at employees carrying out advocacy is delivered to ensure that they comply with
Danone’s internal standards when interacting within multi-stakeholder coalitions, and mostimportantly do not engage in any anti-competitive activities and fully comply with all applicableanti-trust laws and regulations when and where they exist.

2.5. OUR PROFESSIONALS’ BEHAVIOR
It is of great importance to ensure that our behavior doesn’t undercut trust and the credibility of ourcompany. When and where we engage in advocacy activities, this will therefore be conducted in atransparent, legitimate and ethical manner.
As is true for everything we do, any action undertaken in the context of advocacy activities mustcomply with Danone’s Code of Business Conduct, Danone’s Code of Conduct for Business Partners,
Danone’s Integrity Policy, Danone’s Policy for the Marketing of Breast-Milk Substitutes, Danone’s
Health Care Systems (HCS) Policy and other relevant internal policies such as Danone’s
Competition Policy and Danone’s Data Privacy Policy.
Furthermore, any lobbying or advocacy activity conducted by Danone employees, or agencies or
consultants working on behalf of Danone, must fully comply with all applicable national andinternational laws and regulations at all times, and in particular with any and all laws relating tocompetition and anti-trust behavior. Where local laws and regulations are less stringent than theabove policies, the company policies always prevail.
Whenever Danone employees are in direct contact with government officials and policymakers,
they must clearly describe their role within Danone. In their relationships with government officials
and policymakers, Danone employees will act in an honest, fair and transparent way at all times
using good judgement and common sense. They will ensure that the information they impart iscorrect and accurate and is presented in a way that is not misleading. Whenever they share
information that is an opinion rather that hard facts, they make this perfectly clear to the recipientof the information. Employees will never use dishonest means to obtain information or a decision,
nor will they induce government authorities or any other officials to violate applicable rules andstandards of behavior.

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Employees must also act with integrity at all times. Never must they, neither directly or indirectly or
through intermediaries, offer or promise any personal or improper financial or other advantage toan official of a government, a government-controlled entity or any other relevant key opinion leader,
as well as their families, for the purpose of obtaining information or influencing decision-making.
Moreover, Danone employees must refrain from any activity or behavior that could give rise to theappearance or suspicion of such conduct or the attempt thereof. On the contrary, employees should
foster an open dialogue and convince by using factually accurate information, compelling evidence
and robust arguments.
Further information can be found in Danone’s Business Code of Conduct, Danone’s Code of Conduct
for Business Partners, Danone’s Integrity policy, Danone’s Policy for the Marketing of Breast Milk
Substitutes, and Danone’s Health Care Systems (HCS) policy.

2.6. GOVERNANCE OF OUR ADVOCACY
Danone’s Public Affairs and Compliance Departments are co-responsible for overseeing theworldwide implementation of our company’s advocacy policies. Local Public Affairs managers areheld accountable for their advocacy activities. Regular trainings are rolled-out by both thecompliance and public affairs teams to ensure professionals are trained on the practice of
advocacy, and that they understand and apply our advocacy goals and positions on specific topics.
Advocacy is under the governance of Danone’s General Secretary, part of Danone’s leadershipteam and member of the Executive Committee.
All group policies and positions, including on topics around health, environment and social, arereviewed by the Corporate Policies and Positions Committee, which meets bi-monthly under theleadership of the General Secretary and the Chief Research, Innovation, Quality and Food Safety
Officer. An update on all of our policies on health, environment and social issues is presented
annually at the CSR Committee, which is a specialized Committee of the Board.
Advocacy and engagement activities are reviewed by the Global Engagement Committee, whichbrings together representatives of investor relations, sustainable finance, communications, publicaffairs, legal and sustainability on a bi-monthly basis.
Danone follows the principles of the AA1000 Stakeholder Engagement Standard to structure its
stakeholder engagement. This methodology is known and shared with all Danone global, regional
and local Public Affairs professionals.
Compliance controls and Due Diligence
Practical controls are carried out by the Compliance function and by Danone’s internal audit teamindependently as per DICE (the Danone Internal Control Evaluation framework) and reported in
DanGo (the Danone Governance & Operating Tool).
Third parties used in the course of advocacy campaigns, such as Public Affairs consultants, must
be approved and administered in compliance with Danone’s internal Third-Party Vetting rules.
Advocacy is identified as high risk and third parties within this category are subject to additional
due diligence and compliance review.

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Stakeholder governance
Stakeholder governance is creating a structure that is more amenable to building value for all
stakeholders over the long term through dialogue, enhanced accountability and transparency. The
stakeholder governance model is a key aspect of B Lab’s vision for sustainable and future-proof
businesses, one that Danone shares. It enables companies to collect and listen to concerns andfeedbacks from their partners, ensuring all voices are heard and taken into consideration in thedecision-making process. At Danone, we believe that a robust stakeholder governance makes us
stronger, more resilient and responsible as a business. We seek feedback from stakeholders whendeveloping policies, positions and commitments on key topics, for example on climate change orhuman rights. This feedback informs our positions and action plans, which are regularly discussed
and reviewed by Danone’s executive leadership. This belief in the importance of creating sharedvalue and building collective action with stakeholders is also why we became a “Société à Mission”
and are working to become a B Corp.
Governance through B Corp TM and our “Société à Mission” Status
As part of its objective to become fully certified B CorpTM by 2025, Danone’s subsidiaries are
currently individually undergoing the rigorous and independent B Impact Assessment, a thoroughquestionnaire evaluating how their operations and business model impact their workers,
governance, community, environment, and customers5. Among the topics assessed, Danone’s
advocacy practices are examined carefully and credit is awarded for efforts to advocate for
improved social and environmental standards and policy.
Danone’s adoption of the status of a “Société à Mission”6 in June 2020 also required specific bylaws
on our health, social and environmental goals and a new governance framework to monitor the
execution of such goals. Danone’s independent Mission Committee, composed of eight highly
qualified experts, mainly from international organizations, and including one independent Director
and one employee, is responsible for reviewing the company’s progress towards statutory key
health, social and environmental objectives. Every year, its report is presented at Danone’s annual
general meeting. An audit of progress is also conducted every two years by an independent third
party and published within the Mission Committee's report.
More specifically, when it comes to Specialized Nutrition, every year Danone engages with qualified
third-party experts to undertake external audits on compliance with its Policy for the Marketing ofBreast-Milk Substitutes and publishes their results7. Any allegation of potential non-compliance iscentrally logged, followed-up until closure and allegation reports published on Danone’s website8.
Danone is also proud to be included in the FTSE4Good Index Series. FTSE Russell (the trading nameof FTSE International Limited and Frank Russell Company) confirms that Danone has been
independently assessed according to the FTSE4Good criteria and has satisfied the requirements tobecome a constituent of the FTSE4Good Index Series.

More information on Danone’s B Corp certification journey in the company’s Universal Registration Document:
https://www.danone.com/investor-relations/publications-events/registrations-documents.html
6Introduced in France in 2019 with the “Pacte” law, a “sociétéà mission” is defined as a company whose purpose and whose social, societal
and environmental objectives are set out in its Articles of Association. Danone is the first listed company to have adopted such a status.
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The reports are published on this webpage: https://www.danone.com/brands/specialized-nutrition/supporting-breastfeeding.html
8Idem, the reports are published on this webpage: https://www.danone.com/brands/specialized-nutrition/supporting-breastfeeding.html
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Danone Policy on Political Contributions
Danone does not engage in political contributions to political parties, elected representatives andpolitical candidates seeking office, or associations or foundations owned or controlled by such. This
includes prohibiting donations, loans, sponsorships, retainers or purchase of tickets/events. It also
includes a ban on in-kind contributions including goods and services such as advertising, use of
facilities, design and printing, and donation of equipment. Beyond not making any politicalcontributions, Danone does not support political parties, candidates or any groups that promote a
political party’s interests in any other form.
Compliance is ensured via DICE (the Danone Internal Control Evaluation framework) where
donations are monitored and controlled annually by internal control and subject to internal audits
on a periodic basis. All donations are subject to our Integrity Policy, HealthCare Compliance Policy
and our Third-Party Vetting Policy, with any donations classified as ‘high risk’ undergoingcompliance review.
Advocacy expenses
Danone’s contributions and spendings for lobbyists or lobbying organizations, trade associations
and other tax-exempt groups9 are managed at the different levels of the company (both locally by
the subsidiaries and at worldwide business unit level). There is therefore no full consolidation of thetotal spending at company level.
Danone’s external reporting on advocacy expenses is subject to the local regulation in place, forexample in Europe through the EU Transparency Register, in France through French High Authority
for Transparency in Public Life (“Haute Autorité Française pour la Transparence de la Vie Publique– HATVP")’s, and in the United States through the US Lobbying Disclosure Act (LDA).
Addressing misalignment to ensure positive collective action
As noted in the above advocacy and stakeholders’ section, we work with a number of different
partners – including trade associations – to have a greater impact through collective action. We
recognize that such groups can be a strong catalyst for positive collective action, but also risk beinga barrier to ambitious positions and commitments. As such, we are putting in place internal
guidelines and training to help ensure alignment between our positions on key topics and those of
our trade associations. This will cover internal guidance on governance of our trade association
membership, rules governing our participation, and best practice to ensure alignment (for example,
for a topic like climate change, ensuring there is alignment between the Paris Agreement, Danone’s
position and the trade association’s position).
Our guidelines also advise on how to address any misalignment including: verbalizing our position,
ensuring any disagreement is noted in the official minutes of the meeting, sending a formal letter tothe Secretariat of the trade association outlining our position and the point of disagreement, and –if applicable – considering our own submission to a public consultation. We are also persuaded that
continued dialogue and engagement with misaligned parties is fundamental in order to improve
trade associations’ positions and to create a positive movement to achieve positive policy
outcomes.

For tax-exempt groups, we are here referring to donations from Danone or its brands to non-profit organizations that take part in advocacy. The donation
itself will not likely support a specific activity or an expected service in return, but it will support general advocacy.
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As part of our annual disclosure to the CDP, we already evaluate alignment between the Paris
Agreement, our own advocacy and the advocacy of the trade associations and coalitions with thegreatest influence over climate policy.
Addressing conflict of interest and whistleblowing
Danone has a clear whistleblowing policy, part of its Compliance Framework Policy, which
encourages all employees, anonymously if they wish, to raise a concern of any wrongdoing. The
Danone Ethics Line (DEL) is available to anyone – employees, suppliers, or any third party – to reporttheir concerns, anonymously, if necessary, via the web or phone hotline.
The scope of whistleblowing for Danone includes any alleged violations of our Code of BusinessConduct, the Integrity Policy, any of our other Compliance Policies, including this Policy, or any nonethical conduct. It also covers any unlawful behavior, financial malpractice and any activity which
poses or is likely to pose a danger to the environment or to anyone working for Danone.
The Danone Ethics Line is accessible via the ‘Contact Us’ section of Danone’s corporate website
and is available in 52 languages. The Danone Ethics Line is also communicated to all employees on
an ongoing basis via posters, the intranet, the group’s policies and through a targetedcommunication campaign every year.
Should any Danone employee have a concern, they should promptly contact their supervisor /manager, HR, Finance and/or Compliance Manager or alternatively report on the Danone Ethics
Line. Employees are encouraged to speak up, reassured that they can do so safely, confidentiallyand anonymously through the Danone Ethics Line. Raising a concern in good faith will not expose
the person who raised it to any retaliation.
All concerns will be impartially and objectively examined and, if relevant, investigations, mitigationplans and sanctions are put in place under the governance of the Danone Ethics Line Committee
and local management. This Committee is made up of the Chief Compliance Officer, Global Integrity
Director, Global Head of Internal Audit, Global Human Resources Compliance and Labor Law
Director, Global Compliance Director – Ethics Line and a senior representative from the Security
function.
Mitigation plans can involve process improvements, disciplinary action, training andcommunication, and enhanced monitoring from the compliance team in the form of a steeringcommittee responsible for overseeing the implementation of corrective measures.
Details on internal investigations are provided in the Internal Investigations Policy and the Internal
Investigations Guidelines. Every year, Danone discloses the number of reports made through theDanone Ethics Line and also the type of violation category witnessed in its Registration Document10.
Danone has additional procedures in place to identify and mitigate conflict of interest. Procedures
include employee disclosure which are reviewed by Human Resources and/or Compliance. If
appropriate, mitigation plans are then put in place. When a conflict cannot be mitigated, theemployee will be informed and asked to take necessary action.

Danone’s annual Registration Document is public and can be found here : https://www.danone.com/investor-relations/publicationsevents/registrations-documents.html
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2.7. EXTERNAL REPORTING ON OUR PRACTICES
External reporting on advocacy is subject to the local regulation in place. Amongst others: Danone has signed the so-called “EU Transparency Register” (TR ID number: 6574484616889) created through an Agreement between the European Parliament and the European
Commission on the establishment of a publicly available transparency register fororganizations and self-employed individuals engaged in EU policy-making and policy
implementation. Registrants commit themselves to abide by a Code of Conduct covering all
relations and contacts with the EU institutions.
 In France, the 2016 Sapin II Law on transparency, the fight against corruption, themodernization of the economy sets new standards of transparency and reporting, including
the creation of a national electronic register of representatives of interests with which
Danone complies.
 Lobbying in the United States is governed, at federal level, by the Lobbying Disclosure Act(LDA); each state may also have its own requirements and laws. The key elements of the
LDA are included in the Appendix.

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03 APPENDIX
APPENDIX 1A: DANONE’S MEMBERSHIPS IN GLOBAL AND REGIONAL TRADEASSOCIATIONS, MULTI-STAKEHOLDER COALITIONS AND BUSINESS PLATFORMS*Forums where Danone is a Board Member

Global
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B4IG – Business for Inclusive Growth
BIAC - Business at OECD
B Movement Builders
Business for Nature
CFA – Cool Farm Alliance
CGF – Consumer Goods Forum*
Ellen McArthur Foundation
GEDSA – Global Enteral Device Supplier Association*
Global Dairy Platform
ICBWA – International Council of Bottled Water Associations* (indirect membership)
ICC – International Chamber of Commerce
IDF – International Dairy Forum (indirect membership)
ISDI – International Special Dietary Foods Industries*
MNI - Medical Nutrition International Industry*
OP2B – One Planet Business for Biodiversity*
OECD G7 SSCI – Sustainably Supply Chain Initiative
SAI – Sustainable Agriculture Initiative Platform*
SBTN – Science Based Targets Network
TNFD - Task Force on Nature-related Financial Disclosures
TONZ - Transform to Net Zero framework initiative
UN Global Compact
We Mean Business
WBCSD – World Business Council for Sustainable Development*
WFA – World Federation of Advertisers*

Regional
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AFBA – ASEAN Food and Beverage*
AIM – European Brands Association*
APIYCNA – Asia Pacific Infant and Young Child Nutrition Association*
CPA - Circular Packaging Association*
EDA – European Dairy Association* (indirect membership)
EFDC – European Food & Drink Coalition*
ENSA – European Plant-Based Foods Association*
EUROPEN – European Organization for Packaging and the Environment
EU ASEAN Business Council*
FEPALE – Federacion Panamericana de Lecheria (indirect membership)
FIA – Food Industry Asia*
FDE – FoodDrinkEurope
ILSI Europe
ILSI NorAndino*
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Latin American branch of the Consumer Goods Forum*
LABIP – The Lactic Acid Bacteria Industrial Platform*
MCBG – Multinational Companies Business Group)*
NMWE – Natural Mineral Waters Europe*
SNE – Specialised Nutrition Europe*
UAE Food & Beverages Manufacturers*
UNESDA – Union of European Beverages Association*

APPENDIX 1B: DANONE’S TRADE ASSOCIATION MEMBERSHIPS IN THE FIELD OF
MATERNAL, INFANT & YOUNG CHILDREN NUTRITION (UPDATED DECEMBER 2023)
Here below a list of Danone trade association memberships in the field of maternal, infant & young
children nutrition. When such a dedicated trade association does not exist, we have specified theoverarching food association of which Danone is a member.

International•••

International Special Dietary Foods Industries (ISDI)
Medical Nutrition International Industry (MNI)
Global Enteral Device Supplier Association (GEDSA)Regional
Asia•

Asia Pacific Infant and Young Child Nutrition Association (APIYCNA)

Europe•Specialized Nutrition Europe (SNE)

Latam

•

ILSI NorAndino

Austria••

Fachverband der Lebensmittelindustrie – Kindernährmittel
Arbeitsgemeinschaft für klinische Ernährung (AKE)

Belgium••

Babynutrition.be
Bemedtech

Czech Republic••

Association of Czech Branded Products
Czech Food Chamber

Finland•Finnish Baby food association (part of Elintarvikeliitto, the Finnish Food andDrink Industries’ Federation

France•••Syndicat Français de la Nutrition Spécialisée
Secteur Français des Aliments de l’EnfanceSyndicat National de l'Industrie des Technologies Médicales

Germany•

Diätverband

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Greece•Federation of Greek Baby Food Industries (SEPTEDE)

Hungary•

Magyar Dietetikusok Országos Szövetsége

Ireland•

Dairy Industry Ireland (IBEC)

Italy

•

Unione Italiana Food

Netherlands•

De Vereniging van Nederlandse Fabrikanten van Kinder- en
Dieetvoedingsmiddelen (VNFKD)•

Polska Federacja Producentów Żywności (Polish Federation of Producers ofFood)
Farmacja Polska (Chamber of Commerce Polish Pharmacy)

Poland•Portugal•

Associação Nacional da Indústria de Alimentação Infantil e Nutrição
Especial (ANID)

Romania•

Asociatia Romana a Industriei Produselor Alimentare cu Destinatie
Nutritionala Speciala (ARIPAD)

Slovakia•

Slovak Association of Branded Products (SZZV)

Spain

•
•

Asociación Nacional de fabricantes de productos de Dietética infantil (ANDI)
Asociación Española de Fabricantes y Distribuidores de Productos de
Nutrición Enteral (AENE)

Switzerland•

Swiss Infant Nutrition Association

UK•

British Specialist Nutrition Association (BSNA)

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Asia & Oceania
Australia•

Infant Nutrition Council

Cambodia••

EuroCham Cambodia
Cambodia Chamber of Commerce

China

•
•

China Nutrition and Health Food Association
China Dairy Industry Association

India

•
•

Confederation of Indian Industry (CII)
Confederation of Indian Food Trade and Industry (CIFTI)

Indonesia•

Association of Companies with Nutritional Products for Mothers and Children(APPNIA)

Malaysia•

Infant Formula Ethical Committee (FIFEC)New Zealand•

Dairy Companies Association of New ZealandSingapore•

Singapore Infant Food Industry (SIFI)

Thailand•Pediatric Nutrition Manufacturer Association (PNMA)

Argentina•

Asociación de empresas de Nutrición Infantil

Brazil••Associacao Brasileira das Indústrias de Alimentos (ABIA)
Associação Brasileira da Indústria de Alimentos para Fins Especiais eCongêneres (ABIAD)

Mexico•La Cámara Nacional de Industriales de la Leche (CANILEC)

AmericasMiddle East & Africa
Association des fabricants et distributeurs des aliments infantiles (AFDAI-CI)*

Côte d’Ivoire

•

Kenya

•

Kenya Association of Manufacturers

Middle East••

Multinational Companies Business GroupUAE Food & Beverage Manufacturers

Morocco•Association Marocaine de la Nutrition Infantile (AMNI)*creation in progress

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Nigeria•

Association of Infant Food Manufactures & Marketers in Nigeria (AIFMMN)**registration on-going

South Africa•

Infant Feeding Association of South Africa

Turkey•Tüm Gıda İthalatçıları Derneği (TUGIDER)

APPENDIX 2: THE EU TRANSPARENCY REGISTERThe EU Transparency Register is a database that lists organizations that try to influence the lawmaking and policy implementation process of the EU institutions. The register makes visible what
interests are being pursued, by whom and with what budgets. In this way, the register allows for
public scrutiny, giving citizens and other interest groups the possibility to track the activities oflobbyists.
SEARCH THE REGISTER:
https://ec.europa.eu/transparencyregister/public/consultation/search.do?locale=en&reset=
SEE DANONE REGISTRATION:
https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=657448461
68-89
MEETINGS WITH INTEREST REPRESENTATIVES:
As part of the Commission’s commitment to transparency, Commissioners, their cabinet members
and Directors-General publish information on meetings held with organizations or self-employedindividuals.
Meetings relating to policy-making and implementation in the EU can only take place if the interest
representatives are registered in the EU transparency register.
For details, please see the Commission decisions of November 2014:
https://ec.europa.eu/info/about-european-union/principles-andvalues/transparency/transparency-register_en20

DANONE POLICY ON ADVOCACYAPPENDIX 3: THE UNITED STATES’ LOBBYING DISCLOSURE ACT
PUBLIC REGISTRATION AND DATABASE:
https://lobbyingdisclosure.house.gov/lookup.asp
DEFINITIONS: Lobbyist – The LDA specifies that a “lobbyist” is anyone who is employed for services that
include, over a three-month period. Anyone who:
(1) More than one lobbying contact for a client (or, an in-house employee, for the employer)
and(2) for whom lobbying activities account for at least 20 percent of the time he or she spends
providing services to the employer/client.
 Lobbying Activities – lobbying contacts and efforts in support of such contacts, including
preparation and planning activities, research and other background work if it is intended, at thetime it is performed, for use in lobbying contacts (including by others).
 Lobbying Contact – a communication (oral, written or electronic) with a covered legislative or
executive branch official with regard to:(1) the formulation of Federal legislation, rules, regulations, an Executive Order or policy;(2) the administration of a Federal program or policy, including the negotiation or award of
a Federal contract, grant, loan, permit, program or license; or(3) the nomination of anyone subject to Senate confirmation.
 Covered Legislative Branch Official – essentially anyone working in Congress, including all
Members of Congress, and any staff person working for a Member of Congress or a
Congressional Committee.
 Covered Executive Branch Official – includes:(1) any employees in the Executive Office of the President, including the President and VicePresident;(2) any “schedule C” political appointee;(3) any member of the uniformed services serving at pay grade 0-7 or above (Brigadier
General or Rear Admiral and above), and(4) other high-level officials (those paid at levels I-IV of the Executive Schedule). In general,
officials of this rank include cabinet-level officials (agency Secretaries), Deputy
Secretaries, and in some cases lower-level political appointees, such as Under orAssistant Secretaries.

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AS PART OF DANONE’S POLITICAL CONTRIBUTIONS POLICY:
No funds or other assets of Danone may be used to make a contribution to: any federal, state, or local political party or candidate for elected office; any 527 group, political action committee, or an independent-expenditure-onlycommittee;
 any 501(c)(4) organization to be used for political contributions or independent
expenditures; or any trade association or 501(c)(6) organization to be used for political contributions or
independent expenditures.
Danone’s policy prohibits corporate political contributions of all forms including in-kind
contributions. No funds or other assets of Danone may be used to make any independent
expenditure in support of, or in opposition to, any political party or candidate.
While Danone employees may participate as individual citizens in the political process, decisions
to do so are entirely personal and voluntary. Employees engaging in political campaign activities
are expected to do so as private citizens, and must at all times make clear that their views andactions are their own, and not those of Danone.

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