Supplier Code of ConductOur business philosophy, which is deeply rooted in the Mars Five Principles, leads us to work with suppliers
who are willing to meet our standards and specifications and are committed to values that are compatible
with our own.
Our Supplier Code of Conduct is informed by the International Bill of Human Rights, the principles set forthin the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work,and the United Nations Guiding Principles on Business and Human Rights.
This document, and related guidance, establishes expectations of Mars’s suppliers with regard to businesspractices, including their approach to human rights, the environment, and ethical practices alignedwith legal requirements, the Mars, Incorporated Human Rights Policy, other relevant Mars policies, andinternational good practice.
All Mars suppliers, defined as third parties with whom Mars has active commercial relationships for thesupply of goods or services, are expected to apply this Supplier Code of Conduct as follows:Child Labor• All forms of unlawful employment or exploitationof children are prohibited.
• No individuals are hired under age 16 or under thelegal age of work or compulsory schooling,whichever is higher. This guidance is subject to
exceptions recognized by the International Labour
Organization.
• Individuals under 18 years of age are not hired for
positions that include hazardous work or thatinterfere with normal educational activities.
• Where applicable, child protection measures are inplace to ensure that children suffer no harm,
exploitation, or abuse as a result of the activities ofworkers in the workplace or in employer-provided
housing or transport.

Compensation & Benefits• All legally mandated wages and benefits areprovided.

• Pregnancy, maternity and lactation benefits,including relevant protections, leave, andaccommodations, are provided in accordancewith the law.

Discrimination• Discrimination or harassment in hiring, pay,promotion, or in the workplace on the basis ofrace, color, sex, national or social origin, religion,age, disability, sexual orientation, marital status,
pregnancy status, gender identity or any otherstatus protected by applicable law is prohibited.
• All forms of abuse or harassment in the workplaceis prohibited.

Environment• Compliance with applicable environmental laws,particularly with regard to waste, air and water.
• All required environmental permits for use anddisposal of water and waste are obtained.

• Payment is made on time and on at least amonthly basis.

• Legal title to or a legal lease for its land is obtained,
and there are no indications that the supplier’s rightto own or lease that land is contested.

• Deductions are not taken from pay as punishment.

Ethics• Itemized records are maintained, consistent withthis standard, and transparent pay information isprovided in a timely manner.

• The supplier complies with all applicable laws,including those pertaining to bribery, corruption, or
any type of fraudulent business practice.
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Supplier Code of ConductForced Labor• Employer-provided housing, transportation andfood must be sanitary and safe.

• All forms of forced labor are prohibited, including
any form of prison, trafficked, indentured orbonded labor.

Issue Reporting• Original personal identification and travel
documents are not retained, and freedom ofmovement is not restricted.
• Workers are not charged or required to pay feesor deposits to obtain or maintain employment.
Pay is not withheld, and no conditions are present
that constrain a worker’s ability to freely chooseemployment.
• Accurate and understandable information
regarding the nature of work, compensation,
work hours, and benefits is provided in writing in
advance of employment.

Freedom of Association• The right to join, not join, or form a labor union inaccordance with the law is respected without fearof reprisal, intimidation, or harassment.
• Where workers are represented by a legally
recognized union, the supplier is committed
to establishing a constructive dialogue withthe union’s freely chosen representatives andbargaining in good faith with such representatives.

• Workers will be aware of, and have access to, a
supplier-provided complaints mechanism that istransparent, responsive, anonymous, unbiased,
and confidential through which they can raisequestions about or report violations of supplier
policies, expectations contained in this Supplier
Code of Conduct, other workplace grievances,or legal or ethical violations.
• Retaliation against workers reporting violations
or cooperating in investigations is prohibited.

Work Hours• Regular and overtime working hours are incompliance with the law and take into accountworker safety, and overtime is voluntary.
• 24 consecutive hours of rest are provided inevery 7 day work period. If allowed by law, 48
consecutive hours of rest in every 14 day work
period are permitted.

Health & Safety• A safe and hygienic workplace is provided incompliance with the law, and systems are in place
to detect and manage potential risks to workers.
• Workers undertake health and safety training,hazardous materials and chemicals are properly
stored, and workers are provided with theappropriate personal protective equipment.
• Health and hygiene of workers is provided for asrelevant at the site, including toilet facilities,
access to drinking water and food safety.
• Unreasonable restrictions are not be placed on
workers’ toilet, rest or lactation breaks.
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Supplier Code of Conduct

Mars Code of Conduct
All suppliers to Mars are expected, at a minimum, to comply with applicable laws and regulations.
If the Supplier Code of Conduct establishes a higher standard than is required by applicable law, Mars
expects its suppliers to apply the Supplier Code of Conduct. Where alignment with the Supplier Code of
Conduct could lead to a conflict with or a violation of applicable laws or regulations, the supplier will notify
Mars of the situation and explain how it intends to operate in a responsible manner.
Suppliers will have in place appropriate policies, management systems, procedures, and staffing to meetthe expectations in the Supplier Code of Conduct. Suppliers will communicate to workers the standards
to which the supplier is committed, as well as relevant laws, regulations and protections. Suppliers will
notify Mars of any actual or suspected legal infractions, including any legal actions against the supplierby the authorities for violations of human rights, environmental laws, or anti-corruption or bribery laws.
Mars reserves the right to request and receive additional information from the supplier with regard to its
management of relevant issues.
If Mars suppliers are distributors, brokers, and agents, they are expected to assure that their first-tiersuppliers supplying goods for Mars also apply these standards, and to provide this assurance to Mars uponrequest. Suppliers to Mars are expected to provide these partners with assistance in complying with these
expectations as needed.
Suppliers are not permitted to sub-contract the production of goods and services for Mars without first
informing Mars in writing and receiving written agreement that this is acceptable to Mars. If Mars has
approved sub-contracting, the sub-contracted workplaces are expected to meet the Supplier Code ofConduct expectations.
Suppliers are expected to assure that all vendors providing them with services in their workplace, includingthe provision of workers, also apply these standards, and to provide this assurance to Mars upon request.
Suppliers are expected to provide their vendors with assistance in complying with these expectations
as needed.
To identify whether a supplier is in compliance with the Supplier Code of Conduct, Mars reserves the rightto request suppliers to complete self-assessments, disclose relevant policies or procedures, or to be subject
to announced and unannounced on-site direct and/or third-party audits or evaluations of the supplier’sfacilities, including housing provided by the supplier or labor providers, and workplaces to which thesupplier has sub-contracted production of Mars-procured products. Mars reserves the right to audit theoperations, records, policies, and procedures of the aforementioned entities and to conduct confidential
worker interviews in connection with such audits or evaluations as appropriate and as agreed. Upon request,
distributors, brokers and agents supplying to Mars will also provide Mars with access to the workplaces,
records, policies, procedures, and workers of their first-tier suppliers. If Mars identifies areas of noncompliance, Mars reserves the right to request suppliers to make the necessary investments in systems andconditions improvements to ensure compliance.
Mars encourages its suppliers to understand, and take appropriate steps to address, human rights,
environmental and ethics issues in their supply chains. Upon request, Mars expects its suppliers to sharewith Mars information regarding their relevant supply chain policies and practices, conditions or risks in their
supply chains, and how such conditions or risks are being prevented or addressed. If requested by Mars,suppliers will disclose to Mars information related to their supply chain, including countries of origin ofmaterials used in products supplied to Mars – Mars reserves the right to disclose this information publically.
Mars, in its sole discretion, reserves the right to not initiate, to suspend or to terminate its relationship with asupplier if the supplier refuses to consent to the Supplier Code of Conduct or to take the appropriate steps
to come into compliance with the Supplier Code of Conduct.
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Supplier Code of Conduct