Our Supplier Code Of Conduct Share OUR SUPPLIER CODE OF CONDUCT PARTNERING WITH PRINCIPLED COMPANIES The spirit of The Five Principles is present in almost every aspect of the Mars Supplier Code of Conduct — spreading our way of doing business around the world. By holding our suppliers accountable to these standards, we make sure we only partner with principled companies. Our Code includes commitments in each of the following areas: Child labor Voluntary employment/forced labor and human trafficking Migrant labor Abuse, harassment, disciplinary action Fair and equal treatment/non-discrimination Compensation and benefits Working hours Freedom of association and collective bargaining Health and Safety Environment Ethical business practices REFRESHING OUR CODE OF CONDUCT We revise our Code every two years to make sure we’re on track with new legislation, best practice and stakeholder expectations. Read our most recent Supplier Code of Conduct. CONTINUOUS REVIEW AND ENHANCEMENT At Mars, we’re also committed to making sure both our operations and our suppliers’ are living up to regulations and international standards. By continually reviewing and improving our Code, we’re able to keep doing business in markets with evolving regulatory frameworks — all while staying true to The Five Principles. Through our legal team’s efforts and in-depth country risk assessments, we keep track of legislative developments and update our policies in response. We regularly revisit and revise our Supplier Code of Conduct to reflect the conventions of the International Labour Organization and other recognized standards, such as the UN Global Compact, SA8000 and the OECD Guidelines for Multinational Enterprises. Our Code also follows the lead of the UK Bribery Act, US Foreign Corrupt Practices Act and The California Supply Chain Transparency Act. The due diligence process associated with our Code is also aligned with the United Nations Guiding Principles on Business and Human Rights. To make a real difference, we also constantly update our internal training and communications. All Associates who have contact with suppliers complete an online course covering the Supplier Code of Conduct. This includes a feature on key emerging risks relevant to responsible sourcing, such as access to water, land rights and women’s rights. Associates at our Center of Excellence work together with their peers across Mars to develop and draw on a range of case studies. These include spotlights on land rights, access to water and subcontracting, as well as best practice efforts to support women’s empowerment. We know that stakeholders are increasingly expecting companies to understand and actively address these issues in their supply chains, from the factory to farm level. ALIGNMENT WITH OUR CODE OF CONDUCT We work with nearly all of our direct and indirect suppliers to find the best solution to compliance problems in different legal and cultural environments. If one of our suppliers has an alternative approach to meeting our Code, we’re willing to examine it to see if it’s a better fit for them. Our Code acts as a benchmark, and we only ask for changes in areas where the supplier standard in place differs vastly from what’s required by our Code. When a supplier suggests an alternative commitment or has a code of its own, we begin a special rebuttal review process to make sure it lives up to our Supplier Code of Conduct. This process gives everyone involved an opportunity to align in addressing challenges, including risks that may present themselves at the producer level. It also gives us a unique opportunity to go deeper together in addressing the root causes of risk, such as poverty or lack of education. We recognize that many issues arise in further tiers of extended supply chains where many more suppliers are involved. That’s why it’s essential that our direct suppliers recognize the role they have to play in promoting responsible sourcing practices with their own suppliers, in ensuring that our principled approach is adopted, and that compliance monitoring takes place every step of the way. SUPPLY CHAIN TRACEABILITY An important aspect of our Supplier Code of Conduct is to encourage supply chain traceability. Updates made to our Code in 2014 require suppliers to disclose the location of facilities producing raw materials and the origin of the materials within their supply chains, if requested. MARS SUPPLIER POLICY See Our Supplier Code of Conduct