Hershey Co.

"Our Supplier Code, updated in November 2019, and as may be amended from time to time (the “Supplier Code”), outlines Hershey’s expectations and guidelines with respect to responsible sourcing including our commitments to human rights, the environment, health and safety, business ethics and the development of a diverse and sustainable supply chain. The Supplier Code is aligned with the International Bill of Human Rights, The ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights (UNGPs) and the Ten Principles of the UN Global Compact."

"Hershey does not tolerate any form of discrimination in the workplace. We are committed to diversity and inclusion in the work environment. • Discrimination in the workplace that is based on the grounds of an individual’s race; color; gender[...]Hiring and employment decisions, including those relating to compensation, benefits, promotion, training and development, discipline, and termination are based solely on the worker’s skill, ability, experience and performance."

Hershey's supplier requirements: "Respect and uphold land tenure rights of individuals, Indigenous Peoples and local communities. All forms of land grabbing are prohibited. Adherence to the requirements for the fulfillment of respecting rights for Indigenous Peoples and local communities to give Free, Prior and Informed Consent is required in all engagement to seek consent for undertaking any studies, and negotiations, and/or developments on property or land to which they hold legal, communal or customary rights, including the use of and transfers of it"

"Supply Chain Transparency & Stakeholder Engagement [...] Resolve any complaints and conflicts, including land rights disputes, and remediate policy violations in a timely manner through a transparent, responsive and effective grievance mechanism that allows workers and other stakeholders impacted by supply chain operations to report concerns and violations confidentially and anonymously without fear of retaliation or retribution8"

"Zero tolerance for harassment, intimidation, criminalization or violence toward human rights, environmental and land defenders"

"In 2021, we maintained our commitment to source 100% Roundtable on Sustainable Palm Oil (RSPO)-certified mass balance palm oil and achieved 100% traceability to the mill level. We remain committed to achieving 100% plantation level traceability and expect to do this by 2025. We recognize achieving this goal is complex due to the realities of the palm supply chain, including challenges associated with mapping smallholders. We established a new commitment to achieve a verified deforestation-free (VDF) palm supply chain while respecting and protecting the human rights of individuals by 2025. Based on mill lists from mid-year 2020 to mid-year 2021, we verified 51% of the volume as deforestationfree through Airbus and Earthworm Foundation’s Starling satellite. Through the Starling satellite with Earthworm Foundation, Hershey aims to improve our verified deforestation score and monitors the supply chains of our highest volume suppliers, which accounted for approximately 79% of our volume in 2021."

"Hershey works with suppliers that share our values and actively monitor, verify, and implement action plans to help eliminate deforestation and potential human rights violations in agricultural supply chains.[...]Suppliers must establish forest and peatland/natural ecosystem monitoring and response and human rights due diligence systems, non-compliance and grievance procedures, credible independent verification systems and training programs to uphold the requirements set forth in this No Deforestation Policy within their own business operations, third party suppliers and raw material producers."

"Hershey requires our suppliers to adhere to the following:[...] For areas which were developed (cleared, drained, and/or planted) peatlands, HCV areas, or HCS forests after the cut-off date of December 31, 2015, suppliers must implement an adequate Recovery Plan commensurate with the scale of their non-compliant development."

"Partnering with Earthworm Foundation to support our palm oil supply chain, including co-sponsoring and participating on the coalition level of the Areas for Priority Transformation project in the Southern Aceh and Aceh Tamiang landscapes to support capacity building of palm producing communities around topics of labor exploitation, opportunities for supplementary livelihoods and deforestation"

"Hershey is committed to reducing our environmental impact across our supply chain and to supporting sustainable operational and agricultural production practices [...] • Operations fully comply with all federal and local environmental laws and regulations [...] The Hershey Company reserves the right to verify compliance with this Supplier Code through internal and external assessment mechanisms, such as self-assessment questionnaires, announced and unannounced on-site independent third party audits, and worker well-being surveys. Such audits may inspect Suppliers’ facilities, operations, books and records, and supplier-provided housing, and may include confidential worker interviews. If non-compliances are observed, the supplier will be required to take corrective actions."

"If a supplier is not in compliance with our Palm Policy, we follow our Palm Oil Grievance Procedure which may result in their suspension or removal from our palm oil supply chain and disclosed in our Palm Oil Grievance Log" [...] "This log records grievances Hershey receives that are in direct violation of our Responsible Palm Oil Sourcing Policy and occur in our palm oil supply chain. The log will be updated on our website each month. The grievances listed are reported based on Hershey’s awareness at the time of publication."

"5 According to the volume information you have provided in Question 2.2 and Question 2.4, your company's certified palm oil and palm oil products uptake is: 100.00%[...] 2 Total volume of uncertified and certified palmoil, palmkernel oil and related products purchased for use in your company's own-brand and third-party brand products Total 32566.0"

"Hershey is committed to achieving a traceable and sustainable palm oil supply chain with no deforestation, no peatland development and no exploitation of workers (NDPE) in line with our Responsible Palm Oil Sourcing Policy. [...] Hershey takes any reported grievances regarding [...] exploitation in our palm oil supply chain seriously. If our direct suppliers and their parent and sister companies at the corporate-group level fail to uphold our commitments, they may be removed or suspended from our supply chain in accordance with our sourcing policy. Listings of grievances and suspended palm companies are disclosed in our Palm Oil Grievance Log, updated on a monthly basis. We bi-annually map our supply chain and monitor and ensure these suspensions are effectively implemented. Suspensions remain in place until we see acceptable, timebound corrective action plans with proven progress that leads to a resolution. We also encourage our suppliers to remain engaged with these suspended parties to push for meaningful and decisive correction action plans and establishment of a timeline and progress report." [...] "FPIC violations logged in The Hershey Company’s Palm Oil Grievance Log: "March 2022: Friends of the Earth US (FOE) and WALHI report shares allegations of PT AAL subsidiaries, PT Agro Nusa Abadi, PT Lestari Tana Teladan and PT Mamuang being involved in land conflict. The allegations indicate that the three subsidiaries have not received FPIC of the local communities to operate. Hershey is following up with suppliers on this case." [...] "Additionally, we maintained our 100% completion rate of The Hershey Company human rights training by all procurement professionals and expanded the requirement to global supply chain, licensing, and The Hershey Experience."

"This mill list contains the names of all palm oil mills engaged by Hershey suppliers – whether for products intended for Hershey or other customers of the suppliers – during the July through December 2021 time period. This list of mills, therefore, goes beyond Hershey’s physical supply chain."

"We expect all of our palm oil sourcing partners (including subcontractors) to be compliant with our Supplier Code of Conduct, uphold our Responsible Palm Oil Sourcing Policy and No Deforestation Policy, and remain compliant to our NDPE position at the corporate-group level."[...]"Suppliers must establish forest and peatland/natural ecosystem monitoring and response and human rights due diligence systems, non-compliance and grievance procedures, credible independent verification systems and training programs to uphold the requirements set forth in this No Deforestation Policy within their own business operations, third party suppliers and raw material producers."[...]"As outlined in our Palm Oil Grievance Procedure, Hershey takes any reported grievances regarding deforestation, peatland development and exploitation in our palm oil supply chain seriously. If our direct suppliers and their parent and sister companies at the corporate-group level fail to uphold our commitments, they may be removed or suspended from our supply chain in accordance with our sourcing policy.Listings of grievances and suspended palm companies are disclosed in our Palm Oil Grievance Log, updated on a monthly basis.We bi-annually map our supply chain and monitor and ensure these suspensions are effectively implemented. Suspensions remain in place until we see acceptable, timebound corrective action plans with proven progress that leads to a resolution. We also encourage our suppliers to remain engaged with these suspended parties to push for meaningful and decisive correction action plans and establishment of a timeline and progress report."

"As outlined in our Palm Oil Grievance Procedure, Hershey takes any reported grievances regarding deforestation, peatland development and exploitation in our palm oil supply chain seriously. If our direct suppliers and their parent and sister companies at the corporate-group level fail to uphold our commitments, they may be removed or suspended from our supply chain in accordance with our sourcing policy. [...] Suspensions remain in place until we see acceptable, timebound corrective action plans with proven progress that leads to a resolution. We also encourage our suppliers to remain engaged with these suspended parties to push for meaningful and decisive correction action plans and establishment of a timeline and progress report."

"this log records grievances Hershey receives that are in direct violation of our Responsible Palm Oil Sourcing Policy and occur in our palm oil supply chain. The log will be updated on our website each month. The grievances listed are reported based on Hershey’s awareness at the time of publication." ; "Following our Palm Oil Grievance Process, we continue to publicly disclose our Palm Oil Grievance Log with monthly updates to increase transparency on NDPE violations found within our supply chain. As of March 2022, we have suspended 18 suppliers in our upstream supply chain for NDPE violations, none of whom supplied us directly. We have not yet granted re-entry to any of these suppliers. In 2021, we suspended three indirect palm oil operations from our supply chain due to allegations of potential negative environmental impacts."

"Our Supplier Code, updated in November 2019, and as may be amended from time to time (the “Supplier Code”), outlines Hershey’s expectations and guidelines with respect to responsible sourcing including our commitments to human rights, the environment, health and safety, business ethics and the development of a diverse and sustainable supply chain. The Supplier Code is aligned with the International Bill of Human Rights, The ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights (UNGPs) and the Ten Principles of the UN Global Compact."

"Hershey does not tolerate any form of discrimination in the workplace. We are committed to diversity and inclusion in the work environment. • Discrimination in the workplace that is based on the grounds of an individual’s race; color; gender[...]Hiring and employment decisions, including those relating to compensation, benefits, promotion, training and development, discipline, and termination are based solely on the worker’s skill, ability, experience and performance."

Hershey's supplier requirements: "Respect and uphold land tenure rights of individuals, Indigenous Peoples and local communities. All forms of land grabbing are prohibited. Adherence to the principles of Free, Prior and Informed Consent of Indigenous Peoples is required in all engagement to seek consent for undertaking HCSA assessments and negotiations for developments on property or land to which they hold legal, communal or customary rights, including the use of and transfers of it."

"Supply Chain Transparency & Stakeholder Engagement [...] Resolve any complaints and conflicts, including land rights disputes, and remediate policy violations in a timely manner through a transparent, responsive and effective grievance mechanism that allows workers and other stakeholders impacted by supply chain operations to report concerns and violations confidentially and anonymously without fear of retaliation or retribution8"

"Zero tolerance for harassment, intimidation, criminalization or violence toward human rights, environmental and land defenders"

They do use certification for paper from the rest of the world, but for an unknown quantity/proportion - "Source pulp and paper packaging (by volume) from recycled or certified sources globally5 100% by 2025 68.5%[...]By 2025, Hershey’s goals for our global supply chain are to: • Responsibly source 100% of our pulp and paper packaging from recycled or certified sources. Acceptable certification standards include Forest Stewardship Council (FSC), Programme for the Endorsement of Forest Certification (PEFC), and Sustainable Forestry Initiative (SFI). • Trace 100% of the virgin pulp and paper packaging we source back to the country of harvest"[...]"No Deforestation and No Peatland Development • No deforestation or conversion of High Conservation Value (HCV)2 areas or High Carbon Stock (HCS)3 forests • No new development on peat, regardless of depth"[...]

"Hershey works with suppliers that share our values and actively monitor, verify, and implement action plans to help eliminate deforestation and potential human rights violations in agricultural supply chains.[...]Suppliers must establish forest and peatland/natural ecosystem monitoring and response and human rights due diligence systems, non-compliance and grievance procedures, credible independent verification systems and training programs to uphold the requirements set forth in this No Deforestation Policy within their own business operations, third party suppliers and raw material producers."

"Cut-off dates are as follows: cocoa as of February 2018; palm oil as of December 31, 2015; pulp & paper and soy as of January 1, 2020"

"Hershey is committed to reducing our environmental impact across our supply chain and to supporting sustainable operational and agricultural production practices [...] • Operations fully comply with all federal and local environmental laws and regulations [...] The Hershey Company reserves the right to verify compliance with this Supplier Code through internal and external assessment mechanisms, such as self-assessment questionnaires, announced and unannounced on-site independent third party audits, and worker well-being surveys. Such audits may inspect Suppliers’ facilities, operations, books and records, and supplier-provided housing, and may include confidential worker interviews. If non-compliances are observed, the supplier will be required to take corrective actions."

"Hershey expects Suppliers to provide grievance mechanisms that are transparent, responsive, anonymous, unbiased and confidential to workers and other parties across the value chain. [...] The Hershey Company is notified if any concerns or violations are reported through the grievance mechanism that are in direct violation of this Supplier Code. Violations and concerns may also be reported directly to The Hershey Company’s Concern Line1, a third-party monitored, independent service available 24/7 in 10 languages via phone and internet to employees, business partners and other parties."

"Hershey works with suppliers that share our values and actively monitor, verify, and implement action plans to help eliminate deforestation and potential human rights violations in agricultural supply chains. We require our suppliers to publish the policies and procedures they use to help prevent deforestation, peatland loss, and potential human rights violations, as well as the rights for Indigenous Peoples and local communities to give or withhold their Free, Prior and Informed Consent (FPIC) to development on their lands in their supply chains and operations. Suppliers must meet and communicate these requirements throughout their supply chains at a corporate group level to ensure compliance by direct and indirect suppliers and raw material producers. Suppliers must establish forest and peatland/natural ecosystem monitoring and response and human rights due diligence systems, non-compliance and grievance procedures, credible independent verification systems and training programs to uphold the requirements set forth in this No Deforestation Policy within their own business operations, third party suppliers and raw material producers. [...] If a supplier is not compliant with our No Deforestation Policy in any of their operations at a corporate group level, we reserve the right to suspend or remove the supplier." [...] "Additionally, we maintained our 100% completion rate of The Hershey Company human rights training by all procurement professionals and expanded the requirement to global supply chain, licensing, and The Hershey Experience."

Hershey provides a list of suppliers and country of origin for where they sourced pulp and paper materials for the period between January and December 2021

"If a supplier is not in compliance with our Pulp & Paper Policy, Hershey may suspend or remove the pulp & paper supplier from our supply chain until corrective action plans have been implemented. Hershey intends to work with pulp & paper suppliers that not only share our values and are willing to develop action plans to adhere to this Pulp & Paper Policy, but are also committed to collaborating, investing and working towards protecting the environment and native habitats, ensuring legal recognition and rights of Indigenous Peoples, and building resilient communities through the sustainable transformation of the pulp and paper oil sector."

"Our Supplier Code, updated in November 2019, and as may be amended from time to time (the “Supplier Code”), outlines Hershey’s expectations and guidelines with respect to responsible sourcing including our commitments to human rights, the environment, health and safety, business ethics and the development of a diverse and sustainable supply chain. The Supplier Code is aligned with the International Bill of Human Rights, The ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights (UNGPs) and the Ten Principles of the UN Global Compact."

"Hershey does not tolerate any form of discrimination in the workplace. We are committed to diversity and inclusion in the work environment. • Discrimination in the workplace that is based on the grounds of an individual’s race; color; gender[...]Hiring and employment decisions, including those relating to compensation, benefits, promotion, training and development, discipline, and termination are based solely on the worker’s skill, ability, experience and performance."

Hershey's supplier requirements: "Respect and uphold land tenure rights of individuals, Indigenous Peoples and local communities. All forms of land grabbing are prohibited. Adherence to the requirements for the fulfillment of respecting rights for Indigenous Peoples and local communities to give Free, Prior and Informed Consent is required in all engagement to seek consent for undertaking any studies, and negotiations, and/or developments on property or land to which they hold legal, communal or customary rights, including the use of and transfers of it"

"Supply Chain Transparency & Stakeholder Engagement [...] Resolve any complaints and conflicts, including land rights disputes, and remediate policy violations in a timely manner through a transparent, responsive and effective grievance mechanism that allows workers and other stakeholders impacted by supply chain operations to report concerns and violations confidentially and anonymously without fear of retaliation or retribution8"

"Zero tolerance for harassment, intimidation, criminalization or violence toward human rights, environmental and land defenders"

NA

"Hershey works with suppliers that share our values and actively monitor, verify, and implement action plans to help eliminate deforestation and potential human rights violations in agricultural supply chains.[...]Suppliers must establish forest and peatland/natural ecosystem monitoring and response and human rights due diligence systems, non-compliance and grievance procedures, credible independent verification systems and training programs to uphold the requirements set forth in this No Deforestation Policy within their own business operations, third party suppliers and raw material producers."

"For areas which were developed (cleared, drained, and/or planted) peatlands, HCV areas, or HCS forests from the specified cut-off date, suppliers must implement an adequate Recovery Plan commensurate with the scale of their noncompliant development [...] Cut-off dates are as follows: Soy January 1, 2020"

"Hershey is committed to reducing our environmental impact across our supply chain and to supporting sustainable operational and agricultural production practices [...] • Operations fully comply with all federal and local environmental laws and regulations [...] The Hershey Company reserves the right to verify compliance with this Supplier Code through internal and external assessment mechanisms, such as self-assessment questionnaires, announced and unannounced on-site independent third party audits, and worker well-being surveys. Such audits may inspect Suppliers’ facilities, operations, books and records, and supplier-provided housing, and may include confidential worker interviews. If non-compliances are observed, the supplier will be required to take corrective actions."

"Hershey expects Suppliers to provide grievance mechanisms that are transparent, responsive, anonymous, unbiased and confidential to workers and other parties across the value chain. [...] The Hershey Company is notified if any concerns or violations are reported through the grievance mechanism that are in direct violation of this Supplier Code. Violations and concerns may also be reported directly to The Hershey Company’s Concern Line1, a third-party monitored, independent service available 24/7 in 10 languages via phone and internet to employees, business partners and other parties."

"Hershey works with suppliers that share our values and actively monitor, verify, and implement action plans to help eliminate deforestation and potential human rights violations in agricultural supply chains. We require our suppliers to publish the policies and procedures they use to help prevent deforestation, peatland loss, and potential human rights violations, as well as the rights for Indigenous Peoples and local communities to give or withhold their Free, Prior and Informed Consent (FPIC) to development on their lands in their supply chains and operations. Suppliers must meet and communicate these requirements throughout their supply chains at a corporate group level to ensure compliance by direct and indirect suppliers and raw material producers. Suppliers must establish forest and peatland/natural ecosystem monitoring and response and human rights due diligence systems, non-compliance and grievance procedures, credible independent verification systems and training programs to uphold the requirements set forth in this No Deforestation Policy within their own business operations, third party suppliers and raw material producers. [...] If a supplier is not compliant with our No Deforestation Policy in any of their operations at a corporate group level, we reserve the right to suspend or remove the supplier." [...] "Additionally, we maintained our 100% completion rate of The Hershey Company human rights training by all procurement professionals and expanded the requirement to global supply chain, licensing, and The Hershey Experience."

"If a supplier is not compliant with our No Deforestation Policy in any of their operations at a corporate group level, we reserve the right to suspend or remove the supplier"