The Clorox Company

"Our Code details business practice standards for our direct suppliers of goods, service providers, consultants, distributors, licensees, joint ventures, contractors and temporary workers. It is based on the International Labour Organization (ILO) Declaration on Fundamental Principles...Prohibit harassment, discrimination or inhumane treatment: Business partners must provide a workplace free from discrimination, harassment, and abuse...Comply with laws protecting the rights of workers to freely associate...Forbid unlawful child labor...Prohibit human trafficking and slavery: Business partners must evaluate and mitigate risks of human trafficking and slavery in their operations, and must not produce goods or services for Clorox using forced, involuntary or compulsory labor"

"In 2019 Clorox joined the APT Steering Committee to have direct input on direction of the implementation of the APT Programme and targeting interventions supporting the APT Coalition, Norad, and other private sector supporters. This team through Earthworm Foundation in Indonesia mobilizes its resources and that of the local partners to support the decoupling of deforestation from supply chains in Aceh, the strengthening of NDPE policies and practices by commercial actors, and improvement of livelihood prospects by communities in two Leuser-connected APT landscapers. Key activities and KPIs are tracked and reported quarterly including government and multistakeholder capacity-building and coordination, eliminating deforestation inside palm oil concessions, reducing deforestation by palm oil smallholders, strengthening NDPE practices of plantations and mills, and robust data & monitoring to support interventions and communications."

"Suppliers’ compliance with the requirements of our Policy, Standard and all applicable laws is a material condition of continued business with Clorox. We will endeavor to work with our suppliers to address issues and implement remediation solutions, but in case of prolonged or excessive non-compliance, Clorox reserves the right to review business with our supplier, up to and including termination of the business relationship and any related contracts."

"All negotiations with regard to purchasing, leasing, extracting from or otherwise using property, natural resources or land, including the use of and transfers of such, must adhere to the principles of free, prior and informed consent, contract transparency and disclosure. Clorox has zero tolerance for land grabbing."

"In 2020 we confirmed that approximately 850 metric tons of our 2076 global volume was RSPO certified. This includes domestic (482/1078) and international (368/368) purchases."

"In Progress: 100% traceability to origin refiners for palm oil-derived ingredients from priority suppliers, with an objective for all identified origin refiners to provide transparency to all mills in their supply chains. We continue to engage our priority suppliers on traceability and have made strong progress against our milestone goals. In 2019, we achieved 99% traceability to the origin refiner and 89.3% to the mill with priority suppliers... September 2019 - Priority suppliers submitted relevant policies, procedures, commitments and/or action plans to demonstrate how they will materially comply with our palm oil sourcing requirements and The Clorox Company Business Partner Code of Conduct".

"Suppliers should be able to demonstrate that they comply with the following: Comply with all RSPO Principles and Criteria and source only CSPO through RSPO physical supply chains by 2025. ; Have public sustainable palm oil commitments aligned with the RSPO Principles and Criteria, including what is commonly referred to as NDPE (No Deforestation, No Peat and No Exploitation): o No deforestation and no development of high conservation value or high carbon stock areas o No development on peat lands "

"Customers are included in our forest related risk assessments and we work with our strategic customers on key issues related to deforestation. We collaborate with our customers on important sustainability initiatives. Collaborating with our customers on sustainability-related initiatives is important because their support is needed to meet our commitment to working with all parts of our supply chain to address deforestation. An example of this collaboration is our involvement with Walmart’s Project Gigaton Initiative. Similarly, we are collaborating with Walmart, Ahold Delhaize, and Kroger on completing The Sustainability Index Survey (THESIS) each year. THESIS is designed to identify potential risks around ESG “hotspots” within specific product category sectors and create metrics to drive improvement. We also engage our suppliers on trial projects to address our forest-related risks. For example, we are working with one customer to pilot returnable containers designed to reduce the use of fiber in our tertiary packaging. Working with our customers to address forest-related risks has a positive impact on the supply chains of our forest-related commodities as well as positive brand and reputational benefits both for our company and our customers. [...] We have invested in partnerships through The Natural Resources Stewardship Circle, Earthworm Foundation, and AIM-Progress to engage our suppliers and collaborate within industry"

"In 2020, Clorox worked with our NGO partner to conduct a supply chain risk profile to better understand specific supplier and regional risks in detail. We have been able to do this because of our advanced traceability efforts outlined above. We will continue to focus on engaging suppliers utilizing the 2020 risk assessment to ensure transparent NDPE policies and work on specific transformation activities that support a positive influence through the supply chain."

"From time to time, Clorox or its third-party advisors may evaluate business partners’ compliance in areas relevant to the Code...Comply with all applicable laws: Business partners must ensure that they, their affiliates and their workers comply with all applicable laws and regulations when conducting business for Clorox"

"Our Code details business practice standards. No code of conduct can cover every business situation that may require legal or ethical guidance. We encourage our business partners to contact us with any questions about the Code or ethical or legal concerns arising from their relationship with us. In addition, anyone who becomes aware of any actual or potential violation of the Code or any applicable law by any Clorox business partner, or other misconduct, should immediately report such conduct to Clorox. Business partners, including their employees, may contact Clorox directly via either (1) the Clorox employee with whom they have a working relationship or (2) the Clorox Compliance Hotline, which allows for confidential reporting where permitted by law. The Clorox Compliance Hotline can be reached using the contact information below. Business partners are expected to comply with all applicable data privacy laws when using the hotline. We will in turn comply with applicable requirements upon receipt"

In the 2020 RSPO ACOP report, Clorox Co reported a total of 2076.0 metric tonnes of palm oil of which 850.0 was RSPO certified.

"Clorox may periodically request business partners and their workers to attend trainings on legal or compliance topics conducted by Clorox or on Clorox’s behalf. Failure to make reasonable efforts to participate in such trainings upon request is a violation of the Code....Business partners are expected to designate one or more members of management staff to be responsible for assessing and monitoring its compliance with the Code. From time to time, and consistent with our business partners’ obligation to comply with the Code, we may ask business partners to execute certifications of their compliance with the principles in the Code. To manage risk in the supply chain, we use various third-party audit criteria to help evaluate suppliers’ overall compliance in areas such as, responsible sourcing, quality, safety and environmental compliance. From time to time, Clorox or its third-party advisors may evaluate business partners’ compliance in areas relevant to the Code, such as financial books and records, responsible sourcing, quality, safety and environmental compliance. All Clorox business partners are expected to cooperate with reasonable requests from Clorox or its advisors in connection with performing these reviews or audits."

"We review all suppliers annually to asses risk for third-party auditing. We implemented into our annual review the use of the new Sedex Radar Tool. In addition, the Sedex Radar Risk Tool is used to prescreen potential suppliers for risk and review biodiversity impact at supplier locations. The biodiversity impact will be reviewed annually starting in 2020 for all high risk global suppliers in our supply chain to determine if an audit is required each year and understand potential risks and action plans."

"Where an audit identifies non-compliance with our requirements, we will require the supplier to identify corrective actions and timeframes for completing those actions. • The auditor will need confirmation that corrective actions have been completed in order for the supplier to achieve compliance. Depending upon the nature of the issue, the auditor may need to make a follow-up site visit within 90 days of the initial audit. Any critical incidents found will require no longer than a sevenday corrective action plan. • Our Clorox’s SMETA trained quality team may support verification of corrective actions on site... We will endeavor to work with our suppliers to address issues and implement remediation solutions, but in case of prolonged or excessive non-compliance, Clorox reserves the right to review business with our supplier, up to and including termination of the business relationship and any related contracts."

In their 2020 CDP report, Clorox Co. reports that between 81-90% of suppliers were engaged.

"Our Code details business practice standards for our direct suppliers of goods, service providers, consultants, distributors, licensees, joint ventures, contractors and temporary workers. It is based on the International Labour Organization (ILO) Declaration on Fundamental Principles...Prohibit harassment, discrimination or inhumane treatment: Business partners must provide a workplace free from discrimination, harassment, and abuse...Comply with laws protecting the rights of workers to freely associate...Forbid unlawful child labor...Prohibit human trafficking and slavery: Business partners must evaluate and mitigate risks of human trafficking and slavery in their operations, and must not produce goods or services for Clorox using forced, involuntary or compulsory labor"

"Suppliers’ compliance with the requirements of our Policy, Standard and all applicable laws is a material condition of continued business with Clorox. We will endeavor to work with our suppliers to address issues and implement remediation solutions, but in case of prolonged or excessive non-compliance, Clorox reserves the right to review business with our supplier, up to and including termination of the business relationship and any related contracts."

"All negotiations with regard to purchasing, leasing, extracting from or otherwise using property, natural resources or land, including the use of and transfers of such, must adhere to the principles of free, prior and informed consent, contract transparency and disclosure. Clorox has zero tolerance for land grabbing."

In their 2021 Forests CDP Report Clorox Company report that 99% of total production/ consumption volume of timber products is traceable to country of origin.

"Almost 99% of the fiber used in packaging we source is from supplier’s certified virgin or recycled sources. Across our approximately 152,939 metric tons fiber used in packaging materials we purchase, approximately 17% is SFI certified material, 29% is FSC certified material, 0.3% is PEFC certified material, and 1% is virgin material that is not certified. The remaining 53% is recycled fiber.

"When virgin fiber is required, we seek to ensure our suppliers source from sustainable forests and that responsible forestry practices have been followed."

"As a member of the Sustainable Packaging Coalition, we helped to bring standardized recycling labeling instructions to packaging. We’ve also been active participants in efforts by the American Society for Testing and Materials (ASTM) to develop and test biodegradable plastics."

"Comply with all applicable laws: Business partners must ensure that they, their affiliates and their workers comply with all applicable laws and regulations when conducting business for Clorox".

"• Suppliers must have systems in place to enable anonymous grievance reporting and management. Grievance mechanisms must be continuously monitored, records must be maintained and appropriate actions taken in a confidential manner. Workers must be informed of how to access grievance mechanisms. • In addition, anyone who becomes aware of any actual or potential violation by any Clorox supplier of our Policy, Standard, our BPCoC or any applicable law or other misconduct, should immediately report such conduct to Clorox. Suppliers, including their employees, may contact Clorox directly via either (1) the Clorox employee with whom they have a working relationship or (2) the Clorox Compliance Hotline, which allows for confidential reporting where permitted by law. The Clorox Compliance Hotline can be reached using the contact information detailed in our BPCoC. Suppliers are expected to comply with all applicable data privacy laws when using the hotline."

Clorox Company report in their 2021 CDP Forests report that they consume 1,000,000 Metric Tons of timber including 56152 Metric Tons of certified timber by FSC and PEFC

"Clorox may periodically request business partners and their workers to attend trainings on legal or compliance topics conducted by Clorox or on Clorox’s behalf. Failure to make reasonable efforts to participate in such trainings upon request is a violation of the Code....Business partners are expected to designate one or more members of management staff to be responsible for assessing and monitoring its compliance with the Code. From time to time, and consistent with our business partners’ obligation to comply with the Code, we may ask business partners to execute certifications of their compliance with the principles in the Code. To manage risk in the supply chain, we use various third-party audit criteria to help evaluate suppliers’ overall compliance in areas such as, responsible sourcing, quality, safety and environmental compliance. From time to time, Clorox or its third-party advisors may evaluate business partners’ compliance in areas relevant to the Code, such as financial books and records, responsible sourcing, quality, safety and environmental compliance. All Clorox business partners are expected to cooperate with reasonable requests from Clorox or its advisors in connection with performing these reviews or audits."

"Business partners are expected to designate one or more members of management staff to be responsible for assessing and monitoring its compliance with the Code. From time to time, and consistent with our business partners’ obligation to comply with the Code, we may ask business partners to execute certifications of their compliance with the principles in the Code. To manage risk in the supply chain, we use various third-party audit criteria to help evaluate suppliers’ overall compliance in areas such as, responsible sourcing, quality, safety and environmental compliance. From time to time, Clorox or its third-party advisors may evaluate business partners’ compliance in areas relevant to the Code, such as financial books and records, responsible sourcing, quality, safety and environmental compliance. All Clorox business partners are expected to cooperate with reasonable requests from Clorox or its advisors in connection with performing these reviews or audits."

"Where an audit identifies non-compliance with our requirements, we will require the supplier to identify corrective actions and timeframes for completing those actions. • The auditor will need confirmation that corrective actions have been completed in order for the supplier to achieve compliance. Depending upon the nature of the issue, the auditor may need to make a follow-up site visit within 90 days of the initial audit. Any critical incidents found will require no longer than a sevenday corrective action plan. • Our Clorox’s SMETA trained quality team may support verification of corrective actions on site... We will endeavor to work with our suppliers to address issues and implement remediation solutions, but in case of prolonged or excessive non-compliance, Clorox reserves the right to review business with our supplier, up to and including termination of the business relationship and any related contracts."

"Our Code details business practice standards for our direct suppliers of goods, service providers, consultants, distributors, licensees, joint ventures, contractors and temporary workers. It is based on the International Labour Organization (ILO) Declaration on Fundamental Principles...Prohibit harassment, discrimination or inhumane treatment: Business partners must provide a workplace free from discrimination, harassment, and abuse...Comply with laws protecting the rights of workers to freely associate...Forbid unlawful child labor...Prohibit human trafficking and slavery: Business partners must evaluate and mitigate risks of human trafficking and slavery in their operations, and must not produce goods or services for Clorox using forced, involuntary or compulsory labor"

"Suppliers’ compliance with the requirements of our Policy, Standard and all applicable laws is a material condition of continued business with Clorox. We will endeavor to work with our suppliers to address issues and implement remediation solutions, but in case of prolonged or excessive non-compliance, Clorox reserves the right to review business with our supplier, up to and including termination of the business relationship and any related contracts."

"All negotiations with regard to purchasing, leasing, extracting from or otherwise using property, natural resources or land, including the use of and transfers of such, must adhere to the principles of free, prior and informed consent, contract transparency and disclosure. Clorox has zero tolerance for land grabbing."

"We use Soy bean oil in some of our Food product lines and cosmetics. The soy bean oil we purchase directly is produced in the US, with the vast majority made from soy beans grown in the US. For the fraction of soy bean oil we purchase that is made from soy beans grown outside the US (but oil produced in the US), we estimate the volume to be less than 1%, all of which is sourced from soy beans grown in Canada, all of which has low deforestation risk associated with it."

"We also require our suppliers to share our Policy, its associated standards, and our BPCoC with their upstream suppliers and ensure those suppliers adhere to our principles and requirements."[...]"When sourcing raw materials such as palm oil or wood-based fiber for our products and packaging, Clorox is committed to working with suppliers to ensure production does not cause a loss of natural ecosystems or biodiversity, deforestation or human rights infringements, among other environmental or social issues."

"In 2020, Clorox worked with our NGO partner to conduct a supply chain risk profile to better understand specific supplier and regional risks in detail. We have been able to do this because of our advanced traceability efforts outlined above. We will continue to focus on engaging suppliers utilizing the 2020 risk assessment to ensure transparent NDPE policies and work on specific transformation activities that support a positive influence through the supply chain."

"From time to time, Clorox or its third-party advisors may evaluate business partners’ compliance in areas relevant to the Code...Comply with all applicable laws: Business partners must ensure that they, their affiliates and their workers comply with all applicable laws and regulations when conducting business for Clorox"

"Our Code details business practice standards. No code of conduct can cover every business situation that may require legal or ethical guidance. We encourage our business partners to contact us with any questions about the Code or ethical or legal concerns arising from their relationship with us. In addition, anyone who becomes aware of any actual or potential violation of the Code or any applicable law by any Clorox business partner, or other misconduct, should immediately report such conduct to Clorox. Business partners, including their employees, may contact Clorox directly via either (1) the Clorox employee with whom they have a working relationship or (2) the Clorox Compliance Hotline, which allows for confidential reporting where permitted by law. The Clorox Compliance Hotline can be reached using the contact information below. Business partners are expected to comply with all applicable data privacy laws when using the hotline. We will in turn comply with applicable requirements upon receipt"

"Clorox may periodically request business partners and their workers to attend trainings on legal or compliance topics conducted by Clorox or on Clorox’s behalf. Failure to make reasonable efforts to participate in such trainings upon request is a violation of the Code....Business partners are expected to designate one or more members of management staff to be responsible for assessing and monitoring its compliance with the Code. From time to time, and consistent with our business partners’ obligation to comply with the Code, we may ask business partners to execute certifications of their compliance with the principles in the Code. To manage risk in the supply chain, we use various third-party audit criteria to help evaluate suppliers’ overall compliance in areas such as, responsible sourcing, quality, safety and environmental compliance. From time to time, Clorox or its third-party advisors may evaluate business partners’ compliance in areas relevant to the Code, such as financial books and records, responsible sourcing, quality, safety and environmental compliance. All Clorox business partners are expected to cooperate with reasonable requests from Clorox or its advisors in connection with performing these reviews or audits."