ConAgra Brands Inc

"Conagra Brands supports corporate responsibility to respect human rights in accordance with the UN Guiding Principles on Business and Human Rights...The responsibility of business enterprises to respect human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work...Conagra Brands require compliance with relevant human rights policies throughout our supply chain, including: No Forced or Compulsory Labor ; No Child Labor; Suppliers’ employees shall not work beyond the maximum working hours permitted by applicable law; Freedom of Association ; Non-Discrimination ; Suppliers must insure that they have a safe and healthy working environment to include appropriate controls, safe procedures, preventative maintenance and appropriate protective equipment in compliance with all applicable laws and regulations."

"All conditions of employment must be based on an individual’s ability to do the job, not on the basis of personal characteristics or beliefs. Conagra Brands suppliers must not discriminate in hiring and employment practices based on race, color, gender, gender identity or expression, religion, age, nationality, sexual orientation, social or ethnic origin, disability, pregnancy, political affiliation, veteran status, union membership or marital status."[...]"Conagra Brands' Supplier Diversity program is designed to promote the inclusion of various qualified and certified businesses. We consider Minority-owned Business Enterprises (MBE), Women-owned Business Enterprises (WBE)"

"Conagra Brands sources palm oil from RSPO-certified suppliers complying with relevant RSPO ecosystem management standards, and from suppliers adhering to WWF’s Palm Oil Buyers’ Scorecard requirements, which include ecosystem preservation measures such as: implementation of the RSPO New Plantings Procedure excluding cultivation on peat soils and clearance of high carbon stock areas; restoration of any plantations on peat at the end of the current rotation"

"Respect for land tenure rights, including the rights of indigenous and local communities to give or withhold their free, prior and informed consent to all new development or operations on lands to which they hold legal, communal or customary rights. Prevention and resolution of social and/or land conflicts through an open, transparent and consultative process."

"100% of our palm oil buy is covered by Roundtable on Sustainable Palm Oil (RSPO) Mass Balance certification."

On pg 33 of their 2021 CDP ConAgra give 2008 as their Palm Oil cut off date

"Does your organization undertake a forests-related risk assessment?Yes, forests-related risks are assessed: Our landscape assessment leverages data from third-party research and reports including the Ceres’ Engage the Chain, which provides an overview of the environmental and social risks and impacts of agricultural commodities, including palm oil. We chose this tool as a method to understand and identify forests-related risks in our supply chain because Ceres is a reputable, third-party non-profit. Ceres’ risks outlined in the Engage the Chain tool were incorporated into our commodity risk assessment. Identified risks are also monitored and reassessed during major acquisitions or at a minimum of every three to five years. Conagra Brands uses these tools and assessments to support prioritization of materials and inform the policies needed to mitigate those risks. Ultimately, we will use this information to develop commodityspecific responsible sourcing goals and/or procurement policies. In addition to reviewing internal and external factors, Conagra brands rates our largest suppliers, representing 60% of ingredient spend, within our Supplier Excellence program on sustainability performance, based on a review of annual sustainability reports and related documents and supplemented by a quarterly risk review for violations of our Code of Conduct. We deem suppliers that score a 0 out of 4 on sustainability in our Supplier Excellence Program to be high-risk from a sustainability perspective"

"Compliance with Applicable Laws, Regulations and Practices Suppliers are required to act in accordance with all applicable federal, state and local laws and regulations. Where applicable, suppliers must comply with relevant international laws such as those related to international trade (including export controls, sanctions, and reporting obligations) data protection and data transfer rules, and anti-trust competition laws."

Conagra report in their RSPO ACOP report a total volume of 75670 Metric Tonnes of palm oil.

"All suppliers – within the Supplier Excellence program and outside of it - are required to comply with our Supplier Code of Conduct. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations, and who have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. Our purchases of commodities are managed by a dedicated procurement officer who conducts ongoing sustainability and deforestation issues tracking via news sources. For example, in recent years, this tracking identified emerging deforestation issues with a supplier being targeted by NGO campaigns. We subsequently met with the supplier’s sustainability manager and were able to gather adequate information about how deforestation risks were being measured and mitigated."

"100% of our suppliers are required to comply with our Supplier Code of Conduct, which was implemented prior to 2017 and remains in effect on a continuous basis into the foreseeable future. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations and have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Each requirement within our Code of Conduct must be absolutely and continuously met with documentation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. At the highest level, governance for responsible sourcing is managed through our Supplier Code of Conduct, outlining the basic expectations for doing business with Conagra Brands. For products and regions where we source ingredients with high deforestation risks, we implement context-specific sourcing policies to minimize impacts, such as sourcing only certified product or avoiding high-risk geographies. When taking action on ingredient or packaging material specific issues, we take a collaborative approach, with our technical experts working hand-in-hand with category managers in Enterprise Procurement. We tailor our management approach to compliment the influence and relationships we have in our supply chain. For example, where we have direct relationships with suppliers, we work with each individually to enact change. In instances where we’re managing responsible sourcing issues embedded further in our supply chain, we often leverage the expertise and influence of NGO or industry associations to drive change in the marketplace"

"Conagra Brands supports corporate responsibility to respect human rights in accordance with the UN Guiding Principles on Business and Human Rights...The responsibility of business enterprises to respect human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work...Conagra Brands require compliance with relevant human rights policies throughout our supply chain, including: No Forced or Compulsory Labor ; No Child Labor; Suppliers’ employees shall not work beyond the maximum working hours permitted by applicable law; Freedom of Association ; Non-Discrimination ; Suppliers must insure that they have a safe and healthy working environment to include appropriate controls, safe procedures, preventative maintenance and appropriate protective equipment in compliance with all applicable laws and regulations."

"All conditions of employment must be based on an individual’s ability to do the job, not on the basis of personal characteristics or beliefs. Conagra Brands suppliers must not discriminate in hiring and employment practices based on race, color, gender, gender identity or expression, religion, age, nationality, sexual orientation, social or ethnic origin, disability, pregnancy, political affiliation, veteran status, union membership or marital status."[...]"Conagra Brands' Supplier Diversity program is designed to promote the inclusion of various qualified and certified businesses. We consider Minority-owned Business Enterprises (MBE), Women-owned Business Enterprises (WBE)"

"100% of our fiber packaging is sourced from suppliers in the U.S. and Canada, which are not forest risk countries"

Timber products Cutoff date 2008

"Conagra Brands' Sr. director responsible for sustainability strategy represents the company at AMERIPEN to help drive industry discussions and action around sustainable packaging issues. We have access to SFI and FSC certified materials via our supplier based and have engaged in multiple stakeholder discussions related to sustainable forestry. Conagra Brands is a member of the Sustainable Packaging Coalition, and we are one of the largest users of the How2Recycle label program."

"Conagra Brands considers several internal and external factors in identifying and assessing soy-related risks. Our internal Responsible Sourcing Materiality Matrix leverages input from our procurement commodity buyers, technical category leads, and subject matter experts. Internal risk factors considered include annual spend percentage, risks to business continuity and brand disruption, drivers in the food industry such as customer demand and investor pressure, and known environmental and social issues. Our landscape assessment leverages data from third-party research and reports including Ceres’ Engage the Chain, which provides an overview of the environmental and social risks and impacts of agricultural commodities, including soy. We chose this tool as a method to understand and identify forests-related risks in our supply chain because Ceres is a reputable, third-party non-profit. Ceres’ risks outlined in the Engage the Chain tool were incorporated into our commodity risk assessment. Identified risks are also monitored and reassessed during major acquisitions or at a minimum of every three to five years. Conagra Brands uses these tools and assessments to support prioritization of materials and inform the policies needed to mitigate those risks. Ultimately, we will use this information to develop commodityspecific responsible sourcing goals and/or procurement policies. In addition to reviewing internal and external factors, Conagra brands rates our largest suppliers, representing ~60% of ingredient spend, within our Supplier Excellence program on sustainability performance, based on a review of annual sustainability reports and related documents and supplemented by a quarterly risk review for violations of our Code of Conduct."

"Compliance with Applicable Laws, Regulations and Practices Suppliers are required to act in accordance with all applicable federal, state and local laws and regulations. Where applicable, suppliers must comply with relevant international laws such as those related to international trade (including export controls, sanctions, and reporting obligations) data protection and data transfer rules, and anti-trust competition laws."

Conagra outline volumes in their CDP report.

""All suppliers – within the Supplier Excellence program and outside of it - are required to comply with our Supplier Code of Conduct. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations, and who have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. Our purchases of commodities are managed by a dedicated procurement officer who conducts ongoing sustainability and deforestation issues tracking via news sources. For example, in recent years, this tracking identified emerging deforestation issues with a supplier being targeted by NGO campaigns. We subsequently met with the supplier’s sustainability manager and were able to gather adequate information about how deforestation risks were being measured and mitigated. [...] Conagra Brands assesses key suppliers quarterly on sustainability performance and disclosure as part of our Supplier Excellence Program. The program comprises approximately 8 fiberbased packaging suppliers covering approximately 98% of our procured volume for this commodity"

"100% of our suppliers are required to comply with our Supplier Code of Conduct, which was implemented prior to 2017 and remains in effect on a continuous basis into the foreseeable future. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations and have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Each requirement within our Code of Conduct must be absolutely and continuously met with documentation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. At the highest level, governance for responsible sourcing is managed through our Supplier Code of Conduct, outlining the basic expectations for doing business with Conagra Brands. For products and regions where we source ingredients with high deforestation risks, we implement context-specific sourcing policies to minimize impacts, such as sourcing only certified product or avoiding high-risk geographies. When taking action on ingredient or packaging material specific issues, we take a collaborative approach, with our technical experts working hand-in-hand with category managers in Enterprise Procurement. We tailor our management approach to compliment the influence and relationships we have in our supply chain. For example, where we have direct relationships with suppliers, we work with each individually to enact change. In instances where we’re managing responsible sourcing issues embedded further in our supply chain, we often leverage the expertise and influence of NGO or industry associations to drive change in the marketplace"

"Conagra Brands supports corporate responsibility to respect human rights in accordance with the UN Guiding Principles on Business and Human Rights...The responsibility of business enterprises to respect human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work...Conagra Brands require compliance with relevant human rights policies throughout our supply chain, including: No Forced or Compulsory Labor ; No Child Labor; Suppliers’ employees shall not work beyond the maximum working hours permitted by applicable law; Freedom of Association ; Non-Discrimination ; Suppliers must insure that they have a safe and healthy working environment to include appropriate controls, safe procedures, preventative maintenance and appropriate protective equipment in compliance with all applicable laws and regulations."

"All conditions of employment must be based on an individual’s ability to do the job, not on the basis of personal characteristics or beliefs. Conagra Brands suppliers must not discriminate in hiring and employment practices based on race, color, gender, gender identity or expression, religion, age, nationality, sexual orientation, social or ethnic origin, disability, pregnancy, political affiliation, veteran status, union membership or marital status."[...]"Conagra Brands' Supplier Diversity program is designed to promote the inclusion of various qualified and certified businesses. We consider Minority-owned Business Enterprises (MBE), Women-owned Business Enterprises (WBE)"

As published in their CDP report: Forest Risk Commodity: Soy Point to which commodity is traceable: Mill % of total production/consumption volume traceable 100%

ConAgra state in their 2021 CDP report as having a cut off date for Soy as 2008

"Conagra Brands considers several internal and external factors in identifying and assessing soy-related risks. Our internal Responsible Sourcing Materiality Matrix leverages input from our procurement commodity buyers, technical category leads, and subject matter experts. Internal risk factors considered include annual spend percentage, risks to business continuity and brand disruption, drivers in the food industry such as customer demand and investor pressure, and known environmental and social issues. Our landscape assessment leverages data from third-party research and reports including Ceres’ Engage the Chain, which provides an overview of the environmental and social risks and impacts of agricultural commodities, including soy. We chose this tool as a method to understand and identify forests-related risks in our supply chain because Ceres is a reputable, third-party non-profit. Ceres’ risks outlined in the Engage the Chain tool were incorporated into our commodity risk assessment. Identified risks are also monitored and reassessed during major acquisitions or at a minimum of every three to five years. Conagra Brands uses these tools and assessments to support prioritization of materials and inform the policies needed to mitigate those risks. Ultimately, we will use this information to develop commodityspecific responsible sourcing goals and/or procurement policies. In addition to reviewing internal and external factors, Conagra brands rates our largest suppliers, representing ~60% of ingredient spend, within our Supplier Excellence program on sustainability performance, based on a review of annual sustainability reports and related documents and supplemented by a quarterly risk review for violations of our Code of Conduct."

"Compliance with Applicable Laws, Regulations and Practices Suppliers are required to act in accordance with all applicable federal, state and local laws and regulations. Where applicable, suppliers must comply with relevant international laws such as those related to international trade (including export controls, sanctions, and reporting obligations) data protection and data transfer rules, and anti-trust competition laws."

In their 2021 Forests CDP ConAgra Brands Inc state that their total use of Soy is 261999985 lbs. 100% of our soy products relevant to this disclosure are sourced from the U.S.

""All suppliers – within the Supplier Excellence program and outside of it - are required to comply with our Supplier Code of Conduct. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations, and who have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. Our purchases of commodities are managed by a dedicated procurement officer who conducts ongoing sustainability and deforestation issues tracking via news sources. For example, in recent years, this tracking identified emerging deforestation issues with a supplier being targeted by NGO campaigns. We subsequently met with the supplier’s sustainability manager and were able to gather adequate information about how deforestation risks were being measured and mitigated."

"100% of our suppliers are required to comply with our Supplier Code of Conduct, which was implemented prior to 2017 and remains in effect on a continuous basis into the foreseeable future. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations and have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Each requirement within our Code of Conduct must be absolutely and continuously met with documentation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. At the highest level, governance for responsible sourcing is managed through our Supplier Code of Conduct, outlining the basic expectations for doing business with Conagra Brands. For products and regions where we source ingredients with high deforestation risks, we implement context-specific sourcing policies to minimize impacts, such as sourcing only certified product or avoiding high-risk geographies. When taking action on ingredient or packaging material specific issues, we take a collaborative approach, with our technical experts working hand-in-hand with category managers in Enterprise Procurement. We tailor our management approach to compliment the influence and relationships we have in our supply chain. For example, where we have direct relationships with suppliers, we work with each individually to enact change. In instances where we’re managing responsible sourcing issues embedded further in our supply chain, we often leverage the expertise and influence of NGO or industry associations to drive change in the marketplace"

"Conagra Brands supports corporate responsibility to respect human rights in accordance with the UN Guiding Principles on Business and Human Rights...The responsibility of business enterprises to respect human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work...Conagra Brands require compliance with relevant human rights policies throughout our supply chain, including: No Forced or Compulsory Labor ; No Child Labor; Suppliers’ employees shall not work beyond the maximum working hours permitted by applicable law; Freedom of Association ; Non-Discrimination ; Suppliers must insure that they have a safe and healthy working environment to include appropriate controls, safe procedures, preventative maintenance and appropriate protective equipment in compliance with all applicable laws and regulations."

"All conditions of employment must be based on an individual’s ability to do the job, not on the basis of personal characteristics or beliefs. Conagra Brands suppliers must not discriminate in hiring and employment practices based on race, color, gender, gender identity or expression, religion, age, nationality, sexual orientation, social or ethnic origin, disability, pregnancy, political affiliation, veteran status, union membership or marital status."[...]"Conagra Brands' Supplier Diversity program is designed to promote the inclusion of various qualified and certified businesses. We consider Minority-owned Business Enterprises (MBE), Women-owned Business Enterprises (WBE)"

In their 2021 Forests CDP ConAgra Brands Inc give 2008 as a deforestation cut-off date

"Conagra Brands considers several internal and external factors in identifying and assessing soy-related risks. Our internal Responsible Sourcing Materiality Matrix leverages input from our procurement commodity buyers, technical category leads, and subject matter experts. Internal risk factors considered include annual spend percentage, risks to business continuity and brand disruption, drivers in the food industry such as customer demand and investor pressure, and known environmental and social issues. Our landscape assessment leverages data from third-party research and reports including Ceres’ Engage the Chain, which provides an overview of the environmental and social risks and impacts of agricultural commodities, including soy. We chose this tool as a method to understand and identify forests-related risks in our supply chain because Ceres is a reputable, third-party non-profit. Ceres’ risks outlined in the Engage the Chain tool were incorporated into our commodity risk assessment. Identified risks are also monitored and reassessed during major acquisitions or at a minimum of every three to five years. Conagra Brands uses these tools and assessments to support prioritization of materials and inform the policies needed to mitigate those risks. Ultimately, we will use this information to develop commodityspecific responsible sourcing goals and/or procurement policies. In addition to reviewing internal and external factors, Conagra brands rates our largest suppliers, representing ~60% of ingredient spend, within our Supplier Excellence program on sustainability performance, based on a review of annual sustainability reports and related documents and supplemented by a quarterly risk review for violations of our Code of Conduct."

"Compliance with Applicable Laws, Regulations and Practices Suppliers are required to act in accordance with all applicable federal, state and local laws and regulations. Where applicable, suppliers must comply with relevant international laws such as those related to international trade (including export controls, sanctions, and reporting obligations) data protection and data transfer rules, and anti-trust competition laws."

"Suppliers concerned about potential violations of this Code of Conduct for Suppliers should call 866.567.CODE (2633) or log on to www.ethicspoint.com"

Report in their 2021 CDP Report usage of 222253519 Ibs of beef

""All suppliers – within the Supplier Excellence program and outside of it - are required to comply with our Supplier Code of Conduct. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations, and who have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. Our purchases of commodities are managed by a dedicated procurement officer who conducts ongoing sustainability and deforestation issues tracking via news sources. For example, in recent years, this tracking identified emerging deforestation issues with a supplier being targeted by NGO campaigns. We subsequently met with the supplier’s sustainability manager and were able to gather adequate information about how deforestation risks were being measured and mitigated. [...] The program comprises approximately 4 beef suppliers covering approximately 70% of our procured volume for this commodity."

"100% of our suppliers are required to comply with our Supplier Code of Conduct, which was implemented prior to 2017 and remains in effect on a continuous basis into the foreseeable future. The Code states: suppliers will act in an environmentally responsible manner. At minimum, this means suppliers who follow applicable environmental laws and regulations and have the commitment as well as the ability to remediate any environmental problems they may cause. This includes compliance with regulations related to managing deforestation. Each requirement within our Code of Conduct must be absolutely and continuously met with documentation. Our procurement team maintains continuous communication with direct suppliers via monthly calls and other touchpoints to discuss any issues. We maintain the right to inspect production facilities or review of the applicable documentation to ensure compliance with our Code. We provide guidance to our suppliers regarding sub-contracting and require suppliers to replicate these standards down their supply chains. At the highest level, governance for responsible sourcing is managed through our Supplier Code of Conduct, outlining the basic expectations for doing business with Conagra Brands. For products and regions where we source ingredients with high deforestation risks, we implement context-specific sourcing policies to minimize impacts, such as sourcing only certified product or avoiding high-risk geographies. When taking action on ingredient or packaging material specific issues, we take a collaborative approach, with our technical experts working hand-in-hand with category managers in Enterprise Procurement. We tailor our management approach to compliment the influence and relationships we have in our supply chain. For example, where we have direct relationships with suppliers, we work with each individually to enact change. In instances where we’re managing responsible sourcing issues embedded further in our supply chain, we often leverage the expertise and influence of NGO or industry associations to drive change in the marketplace"