Kellogg Co.

"This Global Supplier Code of Conduct outlines the standards and business practices to which we require all of our direct and extended Suppliers to adhere...Suppliers must comply with all applicable laws and regulations, including treaties and international standards such as the UN Global Compact’s Ten Principles, UN Guiding Principles, Universal Declaration of Human Rights, International Bill of Human Rights, OECD Guidelines for Multinational Enterprises, and the ILO’s Core Labour Standards as codified in the 8 core conventions....No Forced Labor...Suppliers shall not employ anyone under the age of 15...Suppliers shall comply with all applicable laws and regulations, or collective agreements, regarding maximum working hours...Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination...Suppliers must respect the rights of their Employees to freely associate, organize, and bargain collectively,"

"Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination (Employment and Occupation) and make employment decisions including hiring, payment, benefits, advancement, termination, and retirement based on ability, qualifications, and achievements without preference or exclusion based on age, color, race, ethnicity, disability, family or marital status, gender identity, gender expression"[...]"Identify areas within Kellogg's supply chain with a high prevalence of women farmers and workers and develop programs to provide resources and education that improve the livelihoods of these women, their families and their communities."

"If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues."

"In addition to these new engagement models, we will continue to execute the foundational parts of our current supply chain management and risk mitigation programs, including requiring suppliers to:  Adhere to Free, Prior and Informed Consent of Indigenous Peoples"

"Legal Compliance Suppliers must comply with all applicable laws and regulations within the countries that the Supplier operates. For Service Providers, the location of service delivery shall take precedence. Suppliers shall also comply with all treaties and international standards and regulations such as those related to international trade (including sanctions, export controls, and reporting obligations) data protection and data transfer rules, and antitrust competition laws. [...] Suppliers should review both owned operations and the operations of those supply chain partners that provide goods and services to Kellogg to verify compliance with this Code. This includes ensuring that the Code is available and communicated to all Employees in their primary language. Suppliers will cooperate with, and allow, Kellogg or an authorized third party to conduct audits (including social accountability audits) to verify compliance. If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues. If issues are not sufficiently resolved, Kellogg reserves the right to remove the Supplier from the supply chain. "

"The Kellogg Ethics Hot Line offers a confidential way for employees, suppliers, contractors and the general public to ask questions and report concerns about ethics, compliance or any other requirements in our Global Code of Ethics and Supplier Code. The Hot Line, which is operated by a third-party, confidential reporting company, is available immediately and anonymously 24 hours a day, 7 days a week via telephone, internet or mobile app in 21 countries and in local languages. The operator will listen to concerns or inquiries and provide a written summary to our Office of Ethics and Compliance for investigation and further action, as appropriate." [...] "Kellogg Company is committed to maintaining a culture of integrity and compliance – a culture that does what is legal, ethical, and responsible.We encourage you to report any misconduct concerns immediately. You may discuss your concerns with your manager, or you may use our Ethics Line which provides telephonic and web reporting with 24 hours a day, 7 days a week availability. When using our Ethics Line, know that all concerns are handled confidentially, and you have an option to report concerns anonymously. The Ethics Line’s telephonic and web reporting is managed by our independent third party vendor, NAVEX, not by Kellogg employees."

"This Global Supplier Code of Conduct outlines the standards and business practices to which we require all of our direct and extended Suppliers to adhere...Suppliers must comply with all applicable laws and regulations, including treaties and international standards such as the UN Global Compact’s Ten Principles, UN Guiding Principles, Universal Declaration of Human Rights, International Bill of Human Rights, OECD Guidelines for Multinational Enterprises, and the ILO’s Core Labour Standards as codified in the 8 core conventions....No Forced Labor...Suppliers shall not employ anyone under the age of 15...Suppliers shall comply with all applicable laws and regulations, or collective agreements, regarding maximum working hours...Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination...Suppliers must respect the rights of their Employees to freely associate, organize, and bargain collectively,"

"Impact Incubator – Smallholders and forest communities contribute 40% of the global palm oil supply but are under-supported in many supply-chain programs. We seek to invest in programs on the ground to support smallholder livelihoods, increase market access through certification support and provide training on regenerative agricultural production techniques. For example, in July 2002, we developed an “Impact Incubator” to support smallholders and forest communities, in recognition that current certification and supply chain models have not been effectively inclusive in these groups. Through this incubator, we partnered with Wild Asia as part of their Wild Asia Group Scheme (WAGS) in West Mayalysia enabling smallholder palm oil producers to protect forests and secure market access through RSPO certification and training in sustainable agriculture"

"Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination (Employment and Occupation) and make employment decisions including hiring, payment, benefits, advancement, termination, and retirement based on ability, qualifications, and achievements without preference or exclusion based on age, color, race, ethnicity, disability, family or marital status, gender identity, gender expression"[...]"Identify areas within Kellogg's supply chain with a high prevalence of women farmers and workers and develop programs to provide resources and education that improve the livelihoods of these women, their families and their communities."

"If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues."

"In addition to these new engagement models, we will continue to execute the foundational parts of our current supply chain management and risk mitigation programs, including requiring suppliers to:  Adhere to Free, Prior and Informed Consent of Indigenous Peoples"

"Suppliers shall work with their supply chains to halt any and all new development of High Conservation Value and High Carbon Stock areas. Any products that have been sourced from HCV or HCS areas developed after December 31, 2015 will be considered in violation of this Code and Kellogg reserves the right to take action to address or remove non-compliant entities from its supply chain. Additional requirements regarding forest protection can be found in the Kellogg Global Sustainable Palm Policy. "

"Industry Engagement – We are working on multiple fronts to make sustainable palm oil the norm, not the exception. Kellogg is an active member of the Palm Oil Transparency Coalition (POTC), the Consumer Goods Forum Human Rights Coalition Palm Oil workgroup, the Palm Oil Collaboration Group, and is a founding member of the North American Sustainable Palm Oil Network. We participate in several other palm oil related industry group workstreams and maintain relationships with global and local NGOs"

"Kellogg should complete a risk assessment per region and per crop. Red flags should be raised in this risk assessment when identified. The verifier should discuss the risks outlined in the risk assessment with the supplier, and if/how they are present in the supply chain or not. Additionally, the verifier should call on their own knowledge of issues in the region/crop and identify potential high-risk areas, and address these during the verification. •High Value Conservation Areas should not be within the vicinity. • The risk assessment needs to be representative of the sourcing area and provide information on a provincial/community level. •Deforestation, Global Forest Watch (compare GIS imagery from 10 years ago with current GIS imagery)•If deforestation was found in the supply chain, post December 31, 2015, the supply chain cannot be verified as responsibly sourced. • In case the risk of deforestation is high, a statement in de supplier code of conduct and/or a self-declaration on the farmers level is required stating that there has been no forest on the utilized land for the past 10 years (see section 2.2.2)"

"Legal Compliance Suppliers must comply with all applicable laws and regulations within the countries that the Supplier operates. For Service Providers, the location of service delivery shall take precedence. Suppliers shall also comply with all treaties and international standards and regulations such as those related to international trade (including sanctions, export controls, and reporting obligations) data protection and data transfer rules, and antitrust competition laws. [...] Suppliers should review both owned operations and the operations of those supply chain partners that provide goods and services to Kellogg to verify compliance with this Code. This includes ensuring that the Code is available and communicated to all Employees in their primary language. Suppliers will cooperate with, and allow, Kellogg or an authorized third party to conduct audits (including social accountability audits) to verify compliance. If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues. If issues are not sufficiently resolved, Kellogg reserves the right to remove the Supplier from the supply chain. "

"The Kellogg Ethics Hot Line offers a confidential way for employees, suppliers, contractors and the general public to ask questions and report concerns about ethics, compliance or any other requirements in our Global Code of Ethics and Supplier Code. The Hot Line, which is operated by a third-party, confidential reporting company, is available immediately and anonymously 24 hours a day, 7 days a week via telephone, internet or mobile app in 21 countries and in local languages. The operator will listen to concerns or inquiries and provide a written summary to our Office of Ethics and Compliance for investigation and further action, as appropriate." [...] "Kellogg Company is committed to maintaining a culture of integrity and compliance – a culture that does what is legal, ethical, and responsible. We encourage you to report any misconduct concerns immediately. You may discuss your concerns with your manager, or you may use our Ethics Line which provides telephonic and web reporting with 24 hours a day, 7 days a week availability. When using our Ethics Line, know that all concerns are handled confidentially, and you have an option to report concerns anonymously. The Ethics Line’s telephonic and web reporting is managed by our independent third party vendor, NAVEX, not by Kellogg employees."

In their 2020 RSPO ACOP report Kellogg's state they consumed a total volume of 65233.0 Metric Tonnes of palm oil.

Kelloggs provide a mill list and a list of the direct supplier who own the mills.

"Kellogg, the suppliers, and the farmers should work together to ensure that the criteria are met by all parties involved in the supply chain. The verifier will check the processes and documents related to each indicator to ensure accurate data is being gathered, and check whether the process has been implemented reliably." "The Criteria require certain levels of compliance from all actors involved. The four indicators that must be met by all farmers (which represent all the acres necessary for the ingredient-specific claim) involved in the project are: 1. 100% No deforestation 2. 100% implementing an integrated pest management plan 3. 100% legal right to farm the lands 4. 100% have access to regular health and safety training" "Deforestation, Global Forest Watch (compare GIS imagery from 10 years ago with current GIS imagery) [...] If deforestation was found in the supply chain, post December 31, 2015, the supply chain cannot be verified as responsibly sourced.[...] The external verifier is responsible for checking documentation related to the KPIs set by Kellogg at different levels, to ensure the accuracy of the data gathered from the field, as well as the quality of the processes during and after the data has been gathered."

"If during the verification visit, no red flags are raised, but the data shows that a KPI has not been met, a corrective action plan should be developed by the supplier, Kellogg and/or the farmers involved".[...] "Suppliers shall adopt and implement their own commitments and policies to monitor and remediate adverse environmental and/or societal impacts of deforestation as a result of sourcing activities throughout their supply chain. Suppliers shall work with their supply chains to halt any and all new development of High Conservation Value and High Carbon Stock areas. Any products that have been sourced from HCV or HCS areas developed after December 31, 2015 will be considered in violation of this Code and Kellogg reserves the right to take action to address or remove non-compliant entities from its supply chain. Additional requirements regarding forest protection can be found in the Kellogg Global Sustainable Palm Policy. [...] Suppliers will cooperate with, and allow, Kellogg or an authorized third party to conduct audits (including social accountability audits) to verify compliance. If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues. If issues are not sufficiently resolved, Kellogg reserves the right to remove the Supplier from the supply chain."

Kellogg has a "live grievance tracker" where current and past engagements and actions are listed against suppliers and their violations. Kellogg also indicate within this document if the supplier was excluded on the basis on non-compliance.

"This Global Supplier Code of Conduct outlines the standards and business practices to which we require all of our direct and extended Suppliers to adhere...Suppliers must comply with all applicable laws and regulations, including treaties and international standards such as the UN Global Compact’s Ten Principles, UN Guiding Principles, Universal Declaration of Human Rights, International Bill of Human Rights, OECD Guidelines for Multinational Enterprises, and the ILO’s Core Labour Standards as codified in the 8 core conventions....No Forced Labor...Suppliers shall not employ anyone under the age of 15...Suppliers shall comply with all applicable laws and regulations, or collective agreements, regarding maximum working hours...Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination...Suppliers must respect the rights of their Employees to freely associate, organize, and bargain collectively,"

"We acknowledge that past and current supply chain models have not adequately allowed for the participation, input and support of independent smallholders and forest reliant communities. Lack of access to resources such as fertilizer, high quality plants and best practice cultivation techniques has meant that the majority of independent smallholder operations are not achieving their full yield potential. This has led to additional land conversions and, at times, illegal deforestation13 . By addressing the root causes of deforestation activities and supporting community-based interventions, we hope to provide access to high quality inputs and best practice farming techniques to increase yields of existing plots and integrate smallholders into supply chains more directly."

"Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination (Employment and Occupation) and make employment decisions including hiring, payment, benefits, advancement, termination, and retirement based on ability, qualifications, and achievements without preference or exclusion based on age, color, race, ethnicity, disability, family or marital status, gender identity, gender expression"[...]"Identify areas within Kellogg's supply chain with a high prevalence of women farmers and workers and develop programs to provide resources and education that improve the livelihoods of these women, their families and their communities."

"If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues."

"In addition to these new engagement models, we will continue to execute the foundational parts of our current supply chain management and risk mitigation programs, including requiring suppliers to:  Adhere to Free, Prior and Informed Consent of Indigenous Peoples"

"Suppliers shall work with their supply chains to halt any and all new development of High Conservation Value and High Carbon Stock areas. Any products that have been sourced from HCV or HCS areas developed after December 31, 2015 will be considered in violation of this Code and Kellogg reserves the right to take action to address or remove non-compliant entities from its supply chain. Additional requirements regarding forest protection can be found in the Kellogg Global Sustainable Palm Policy. "

"Kellogg should complete a risk assessment per region and per crop. Red flags should be raised in this risk assessment when identified. The verifier should discuss the risks outlined in the risk assessment with the supplier, and if/how they are present in the supply chain or not. Additionally, the verifier should call on their own knowledge of issues in the region/crop and identify potential high-risk areas, and address these during the verification. •High Value Conservation Areas should not be within the vicinity. • The risk assessment needs to be representative of the sourcing area and provide information on a provincial/community level. •Deforestation, Global Forest Watch (compare GIS imagery from 10 years ago with current GIS imagery)•If deforestation was found in the supply chain, post December 31, 2015, the supply chain cannot be verified as responsibly sourced. • In case the risk of deforestation is high, a statement in de supplier code of conduct and/or a self-declaration on the farmers level is required stating that there has been no forest on the utilized land for the past 10 years (see section 2.2.2)"

"Legal Compliance Suppliers must comply with all applicable laws and regulations within the countries that the Supplier operates. For Service Providers, the location of service delivery shall take precedence. Suppliers shall also comply with all treaties and international standards and regulations such as those related to international trade (including sanctions, export controls, and reporting obligations) data protection and data transfer rules, and antitrust competition laws. [...] Suppliers should review both owned operations and the operations of those supply chain partners that provide goods and services to Kellogg to verify compliance with this Code. This includes ensuring that the Code is available and communicated to all Employees in their primary language. Suppliers will cooperate with, and allow, Kellogg or an authorized third party to conduct audits (including social accountability audits) to verify compliance. If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues. If issues are not sufficiently resolved, Kellogg reserves the right to remove the Supplier from the supply chain. "

"The Kellogg Ethics Hot Line offers a confidential way for employees, suppliers, contractors and the general public to ask questions and report concerns about ethics, compliance or any other requirements in our Global Code of Ethics and Supplier Code. The Hot Line, which is operated by a third-party, confidential reporting company, is available immediately and anonymously 24 hours a day, 7 days a week via telephone, internet or mobile app in 21 countries and in local languages. The operator will listen to concerns or inquiries and provide a written summary to our Office of Ethics and Compliance for investigation and further action, as appropriate." [...] "Kellogg Company is committed to maintaining a culture of integrity and compliance – a culture that does what is legal, ethical, and responsible. We encourage you to report any misconduct concerns immediately. You may discuss your concerns with your manager, or you may use our Ethics Line which provides telephonic and web reporting with 24 hours a day, 7 days a week availability. When using our Ethics Line, know that all concerns are handled confidentially, and you have an option to report concerns anonymously. The Ethics Line’s telephonic and web reporting is managed by our independent third party vendor, NAVEX, not by Kellogg employees."

"Kellogg, the suppliers, and the farmers should work together to ensure that the criteria are met by all parties involved in the supply chain. The verifier will check the processes and documents related to each indicator to ensure accurate data is being gathered, and check whether the process has been implemented reliably." "The Criteria require certain levels of compliance from all actors involved. The four indicators that must be met by all farmers (which represent all the acres necessary for the ingredient-specific claim) involved in the project are: 1. 100% No deforestation 2. 100% implementing an integrated pest management plan 3. 100% legal right to farm the lands 4. 100% have access to regular health and safety training" "Deforestation, Global Forest Watch (compare GIS imagery from 10 years ago with current GIS imagery) [...] If deforestation was found in the supply chain, post December 31, 2015, the supply chain cannot be verified as responsibly sourced.[...] The external verifier is responsible for checking documentation related to the KPIs set by Kellogg at different levels, to ensure the accuracy of the data gathered from the field, as well as the quality of the processes during and after the data has been gathered."

"If during the verification visit, no red flags are raised, but the data shows that a KPI has not been met, a corrective action plan should be developed by the supplier, Kellogg and/or the farmers involved".[...] "Suppliers shall adopt and implement their own commitments and policies to monitor and remediate adverse environmental and/or societal impacts of deforestation as a result of sourcing activities throughout their supply chain. Suppliers shall work with their supply chains to halt any and all new development of High Conservation Value and High Carbon Stock areas. Any products that have been sourced from HCV or HCS areas developed after December 31, 2015 will be considered in violation of this Code and Kellogg reserves the right to take action to address or remove non-compliant entities from its supply chain. Additional requirements regarding forest protection can be found in the Kellogg Global Sustainable Palm Policy. [...] Suppliers will cooperate with, and allow, Kellogg or an authorized third party to conduct audits (including social accountability audits) to verify compliance. If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues. If issues are not sufficiently resolved, Kellogg reserves the right to remove the Supplier from the supply chain."

"This Global Supplier Code of Conduct outlines the standards and business practices to which we require all of our direct and extended Suppliers to adhere...Suppliers must comply with all applicable laws and regulations, including treaties and international standards such as the UN Global Compact’s Ten Principles, UN Guiding Principles, Universal Declaration of Human Rights, International Bill of Human Rights, OECD Guidelines for Multinational Enterprises, and the ILO’s Core Labour Standards as codified in the 8 core conventions....No Forced Labor...Suppliers shall not employ anyone under the age of 15...Suppliers shall comply with all applicable laws and regulations, or collective agreements, regarding maximum working hours...Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination...Suppliers must respect the rights of their Employees to freely associate, organize, and bargain collectively,"

"We acknowledge that past and current supply chain models have not adequately allowed for the participation, input and support of independent smallholders and forest reliant communities. Lack of access to resources such as fertilizer, high quality plants and best practice cultivation techniques has meant that the majority of independent smallholder operations are not achieving their full yield potential. This has led to additional land conversions and, at times, illegal deforestation13 . By addressing the root causes of deforestation activities and supporting community-based interventions, we hope to provide access to high quality inputs and best practice farming techniques to increase yields of existing plots and integrate smallholders into supply chains more directly."

"Suppliers shall act in accordance with ILO Convention No. 111 on Discrimination (Employment and Occupation) and make employment decisions including hiring, payment, benefits, advancement, termination, and retirement based on ability, qualifications, and achievements without preference or exclusion based on age, color, race, ethnicity, disability, family or marital status, gender identity, gender expression"[...]"Identify areas within Kellogg's supply chain with a high prevalence of women farmers and workers and develop programs to provide resources and education that improve the livelihoods of these women, their families and their communities."

"If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues."

"In addition to these new engagement models, we will continue to execute the foundational parts of our current supply chain management and risk mitigation programs, including requiring suppliers to:  Adhere to Free, Prior and Informed Consent of Indigenous Peoples"

"Suppliers shall work with their supply chains to halt any and all new development of High Conservation Value and High Carbon Stock areas. Any products that have been sourced from HCV or HCS areas developed after December 31, 2015 will be considered in violation of this Code and Kellogg reserves the right to take action to address or remove non-compliant entities from its supply chain. Additional requirements regarding forest protection can be found in the Kellogg Global Sustainable Palm Policy. "

"Farmers in Madhya Pradesh, a province located in Central India, have been impacted by ongoing drought conditions. In January 2015, Kellogg and Techno Serve launched a project to provide these farmers with climate smart agriculture hands-on training in wheat, corn, and soy, as well as increased access to markets to sell their crops. This project was completed in 2018 and reached 12,190 farmers, 38% of who were women. This project was supported by the Kellogg Company 25 Year Employees' Fund and recognized by the US Chamber of Commerce's 2019 Corporate Citizens Awards as the Best Economic Empowerment Program.

"Kellogg should complete a risk assessment per region and per crop. Red flags should be raised in this risk assessment when identified. The verifier should discuss the risks outlined in the risk assessment with the supplier, and if/how they are present in the supply chain or not. Additionally, the verifier should call on their own knowledge of issues in the region/crop and identify potential high-risk areas, and address these during the verification. •High Value Conservation Areas should not be within the vicinity. • The risk assessment needs to be representative of the sourcing area and provide information on a provincial/community level. •Deforestation, Global Forest Watch (compare GIS imagery from 10 years ago with current GIS imagery)•If deforestation was found in the supply chain, post December 31, 2015, the supply chain cannot be verified as responsibly sourced. • In case the risk of deforestation is high, a statement in de supplier code of conduct and/or a self-declaration on the farmers level is required stating that there has been no forest on the utilized land for the past 10 years (see section 2.2.2)"

"Legal Compliance Suppliers must comply with all applicable laws and regulations within the countries that the Supplier operates. For Service Providers, the location of service delivery shall take precedence. Suppliers shall also comply with all treaties and international standards and regulations such as those related to international trade (including sanctions, export controls, and reporting obligations) data protection and data transfer rules, and antitrust competition laws. [...] Suppliers should review both owned operations and the operations of those supply chain partners that provide goods and services to Kellogg to verify compliance with this Code. This includes ensuring that the Code is available and communicated to all Employees in their primary language. Suppliers will cooperate with, and allow, Kellogg or an authorized third party to conduct audits (including social accountability audits) to verify compliance. If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues. If issues are not sufficiently resolved, Kellogg reserves the right to remove the Supplier from the supply chain. "

"The Kellogg Ethics Hot Line offers a confidential way for employees, suppliers, contractors and the general public to ask questions and report concerns about ethics, compliance or any other requirements in our Global Code of Ethics and Supplier Code. The Hot Line, which is operated by a third-party, confidential reporting company, is available immediately and anonymously 24 hours a day, 7 days a week via telephone, internet or mobile app in 21 countries and in local languages. The operator will listen to concerns or inquiries and provide a written summary to our Office of Ethics and Compliance for investigation and further action, as appropriate." [...] "Kellogg Company is committed to maintaining a culture of integrity and compliance – a culture that does what is legal, ethical, and responsible.We encourage you to report any misconduct concerns immediately. You may discuss your concerns with your manager, or you may use our Ethics Line which provides telephonic and web reporting with 24 hours a day, 7 days a week availability. When using our Ethics Line, know that all concerns are handled confidentially, and you have an option to report concerns anonymously. The Ethics Line’s telephonic and web reporting is managed by our independent third party vendor, NAVEX, not by Kellogg employees."

"Kellogg, the suppliers, and the farmers should work together to ensure that the criteria are met by all parties involved in the supply chain. The verifier will check the processes and documents related to each indicator to ensure accurate data is being gathered, and check whether the process has been implemented reliably." "The Criteria require certain levels of compliance from all actors involved. The four indicators that must be met by all farmers (which represent all the acres necessary for the ingredient-specific claim) involved in the project are: 1. 100% No deforestation 2. 100% implementing an integrated pest management plan 3. 100% legal right to farm the lands 4. 100% have access to regular health and safety training" "Deforestation, Global Forest Watch (compare GIS imagery from 10 years ago with current GIS imagery) [...] If deforestation was found in the supply chain, post December 31, 2015, the supply chain cannot be verified as responsibly sourced.[...] The external verifier is responsible for checking documentation related to the KPIs set by Kellogg at different levels, to ensure the accuracy of the data gathered from the field, as well as the quality of the processes during and after the data has been gathered."

"If during the verification visit, no red flags are raised, but the data shows that a KPI has not been met, a corrective action plan should be developed by the supplier, Kellogg and/or the farmers involved".[...] "Suppliers shall adopt and implement their own commitments and policies to monitor and remediate adverse environmental and/or societal impacts of deforestation as a result of sourcing activities throughout their supply chain. Suppliers shall work with their supply chains to halt any and all new development of High Conservation Value and High Carbon Stock areas. Any products that have been sourced from HCV or HCS areas developed after December 31, 2015 will be considered in violation of this Code and Kellogg reserves the right to take action to address or remove non-compliant entities from its supply chain. Additional requirements regarding forest protection can be found in the Kellogg Global Sustainable Palm Policy. [...] Suppliers will cooperate with, and allow, Kellogg or an authorized third party to conduct audits (including social accountability audits) to verify compliance. If Kellogg identifies violations with this Code, Kellogg will work with the supplier to remediate issues. If issues are not sufficiently resolved, Kellogg reserves the right to remove the Supplier from the supply chain."