Reckitt Benckiser Group PLC

"As a supplier to RB, we expect you to comply with three sets of requirements, which form a standard part of our contracts: 1. Our Code of Business Conduct 2. Our Global Manufacturing Standard for responsible production (‘GMS’) 3. Our Policy & Standard for the responsible sourcing of natural raw materials [...] The seven principles of our GMS are underpinned by detailed requirements. These are in line with the International Labour Organisation’s (ILO) Fundamental Conventions (no forced labour, no child labour, freedom of association and no discrimination) and industry standards."

"Some of the places our natural raw materials come from have less formal supply chains, dominated by smallholder farms [...] we can also help support farmers’ livelihoods where we need to. We currently back programmes for smallholder farmers in Malaysia, Indonesia and Thailand." [...] "Recognising our commodities are sourced from local communities we want to work with these communities to improve smallholder livelihoods We support Earthworm Foundation’s ‘Rurality’ programmes, which are focused on improving livelihoods of smallholders, one of most vulnerable groups in palm oil supply chains. Operating in Thailand, Indonesia and Malaysia, the Rurality programmes we support will be centred on enabling smallholders in our supply chains to overcome pressing social, economic and environmental challenges, enabling them to both benefit from and contribute to an NDPE approach. The programme enables us to bring this vulnerable group in to our risk assessment process, helping us to understand the risks that smallholder action poses to the forests we want to preserve and how we can work with them to mitigate these risks."

" No discrimination. Equal opportunities / rights What is discrimination? Discrimination means unfairly treating a worker. Discrimination can be based on many factors, including race, colour, language, caste, national origin, indigenous status, religion, disability, gender, marital status, sexual orientation, union membership, political affiliation, and age. It can occur across all work activities including hiring, remuneration and professional development. Why is this important? Discrimination violates a worker’s human rights. It creates divisions within the workforce and dissatisfaction among workers. It exposes employers to risks of prosecution and damage to reputation."

"We’ve come a long way since setting our targets since 2012. We’ve built specific standards, monitoring activities and remediation programmes for key natural raw materials, and we still have a long way to go."

"Suppliers must have a policy in place to reach free, prior and informed consent (FPIC)vii of the local communities impacted by new plantations. Plus have a systematic process to facilitate and demonstrate FPIC"

"Traceability As we procure processed derivatives of palm oil, traceability remains challenging given the scale of palm oil production landscapes and the extent of processing undertaken. To understand supply chain risks and focus areas, we work with partners to identify the farms, plantations and processing mills that supply the palm oil used in the derivatives we procure. We continue to make progress in improving supply chain traceability, achieving 88% traceability to mills. In partnership with suppliers, we also improved visibility of mill supply chains, achieving 11% traceability to farms and plantations in 2020. Mill List - We update and publish annually a list of the palm oil processing mills identified within our supply chain, their location, certification status and ownership. Our 2020 list can be found here."

"Reckitt’s Responsible Sourcing Standard details Reckitt commitment to sourcing Palm Oil against the 6 principles. As a priority commodity to Reckitt the standard sets out specific criteria for Palm Oil which Reckitt expects its suppliers to comply with. The specific criteria for palm oil is: Understanding production origin - Supply chain traceability to mill and producers by GPS/ownership provided on a quarterly basis. Supply Chain Monitoring for NDP - systems are in place and used to engage mills regularly to assess and monitor the extent to which they are committed to and achieving NDPE commitments Grievance Management - Formal policy and time-bound process is in place to evaluate, monitor and resolve reported actions that go against the requirements set out in Reckitt's standard. Safeguarding workers and communities – Policies aligned to Reckitt’s Framework for Human Rights and Responsible Business are in place with attention to migrate workers, children, women and smallholders. Programmes are in place to monitor and report on these areas. Protecting ecosystems - NDPE policy in place to ensure FFB is not sourced from land cleared after 2015 that was previously designated as HCS, HCV or peat land; on-going monitoring of compliance against this commitment and/or use of RSPO certification Reducing Environmental impacts - Policy and up-stream assessments and/or programmes focused on measuring and reducing water use, waste outputs, energy use and GHG. Delivery through Partnerships - Evidence of partnerships that can achieve measurable success in areas closely aligned to Reckitt’s Responsible Sourcing Standard. All direct suppliers of palm-derived products should be members of the Round Table on Responsible Palm Oil. Reckitt’s Responsible Sourcing team along with Procurement and Marketing actively work with suppliers to work towards compliance of the standard. The outcome of any assessment or discussion on the 6 principles with suppliers can inform purchasing decisions. Reckitt aim to work with suppliers to work towards compliance with the standard via regular discussion and action plans. In the case of a supplier found to be noncompliant Reckitt will work with the supplier to agree a time bound plan to resolve any concerns. In the unlikely case a solution cannot be agreed up to or found Reckitt may suspend our business relationship with the supplier."

"Observation of a forest conversion cut-off date of 31 December 2015 We believe this date should represent the point from which clearance of HCV and HCS areas is judged as incompatible with NDPE commitments. We work closely with our supply chains to ensure this is acted on. • Comply with all applicable environmental, labour, health & safety laws and regulations, and adherence to the International Labour Organisation’s (ILO) Fundamental Conventions in our supply chains on. "

"We’re part of Production and Protection Beyond Concessions (PPBC), a working group of the Palm Oil Collaboration Group (POCG), which is made up of a variety of producer, trader, FMCG and retailer companies looking at how to protect forests that are being cleared outside of legally sanctioned concession areas for oil palm. It’s estimated that over 40% of deforestation happens in those areas. So we’re working with suppliers and the PPBC group to create common ways of working and take action with supply chain partners to address the risk of further deforestation and illegal land use" [...] "Industry collaboration – We are active members of the Consumer Goods Forum’s Forest Positive and Human Rights Coalitions of Action to remove deforestation and forced labour from our collective supply chains. As part of this we are engaging key palm oil suppliers to develop and deploy a human rights due diligence system from refinery to plantation."

"Sabah’s announcement in 2015 to certify all of its palm oil output to the standards of the Roundtable of Sustainable Palm Oil (RSPO) by 2025 as a pilot for the jurisdictional approach, enabled companies to coordinate their efforts at the state level and allowed them to profile their initiatives in support of this vision. These companies include Wilmar International, Sime Darby Plantation, AAK, Unilever, Reckitt and Walmart."[...]"Another initiative in building smallholder capacity was led by Earthworm Foundation in the Beluran, Kinabatangan and Lahad Datu districts, supported by companies including Reckitt, Nestle, ADM Cares, Givaudan, Groupe Rocher and IJM Plantations since 2015."

"Our partnership with Earthworm continued to monitor suppliers to prevent instances of deforestation in our palm oil supply chain. We do this through Starling, a platform provided by Airbus and Earthworm Foundation that uses satellites to understand the impact of our supply chains on deforestation. Satellite imagery from the system shows how land use changes over time, highlights at-risk areas and how close mills in our supply network are to them. It also helps to predict deforestation patterns so we can work with suppliers to eliminate deforestation."[...]"• Public supply chain traceability and transparency We published a full list of mills in our supply chains in 2018 and piloted the use of Starling satellite monitoring technology to map mill locations against High Conservation Value (HCV) and High Carbon Stock (HCS) areas."

"Our minimum standards Our standards require that: • Suppliers of natural raw materials and packaging materials comply with all applicable environmental, health & safety, labour and social laws and regulations (including applicable land tenure and use rights)...We have introduced a new process to help ensure all suppliers meet our expectations. This builds on our existing compliance process, which previously affected only some suppliers. The process consists of self-assessment, RB risk assessment, audit and corrective action..... Annual self assessment: The annual self assessment process is monitored by our Global Supply Leadership Team, which includes RB’s EVP Supply (a member of RB’s Executive Committee) and SVP Purchasing. 2. Risk assessment We will review the Self Assessment Questionnaire responses to classify the selected suppliers as high, medium or low risk. Classification will also take account of the results from any previous audits shared with RB and the inherent risks associated with the supplier’s specific location and business activities. 3. External audit programme Each year selected high risk suppliers will be required to undertake an independent external audit.

"The policy is designed to enable all RB employees and Others to “Speak Up” and raise concerns internally and at a senior level and to disclose information which the individual believes shows malpractice or impropriety within the Group. These concerns could include: ▪ Financial malpractice or impropriety or fraud ▪ Failure to comply with legal obligations ▪ Dangers to health and safety or the environment ▪ Criminal activity ▪ Improper conduct or unethical behaviour ▪ Significant breaches of the Code of Conduct and associated policies or procedures ▪ Failure to comply with an applicable industry code to which RB has subscribed ▪ Attempts to conceal any of the above once they have occurred However, this is not intended to be an exhaustive list."

They disclose in their RSPO ACOP Report 2020 that they produced 190,669metric tonnes of palm oil that year.

"Auditing our suppliers We audited 232 suppliers in 2021, with around 61% achieving a ‘pass’ rating. This is lower than the 67% pass rate achieved in 2020 due to the expansion of our audit programme to a further 115 raw and packaging material suppliers. For some of them, this was the first time they had undergone an ethical audit to assess their on-site labour, health and safety, and environmental practices. This might be because they are a small and so less visible part of global value chains, or potentially because local regulatory frameworks are limited or not routinely inspected. Consequently, many of these suppliers don’t have mature sustainability processes and we will support them to build these as we move forward."

Reckitt provide a supplier list with their suppliers from tier to tier 6

"Each year we complete a risk assessment of all natural raw materials used within our products. We use an external company to assess a range of social and environmental criteria to grade the materials we use from low to high priority. The results of this assessment ensure we continue to focus our efforts on the highest priority materials. Specific due diligence is then performed for materials deemed to be of a higher priority. Our compliance monitoring programme includes suppliers of key natural raw materials, all of whom must comply with our policy which is an integral part of our commercial contracts. Our compliance monitoring activities include: • In-depth responsible sourcing programmes • Traceability and compliance questionnaires • Supplier engagement including visits, meetings and assessments • Independent audits"

"Reckitt partner with Earthworm Foundation and utilise Staring Satellite Monitoring to report on deforestation or conversion in its supply chain. Reports developed from Starling highlight at a landscape level where deforestation and conversion is happening in Reckitt supply chain. The reports link to Reckitt direct suppliers enabling Reckitt to have constructive discussion with suppliers to tackle deforestation and conversation. Since the 2015 cut off date Starling has highlighted 54’096.70 ha of deforestation inside concessions linked to Reckitt’s supply chain and in 2021 the number was 2’560.8 ha. The figures concern the Malaysia and Indonesian supply."

"All direct suppliers of palm-derived products should be members of the Round Table on Responsible Palm Oil. Reckitt’s Responsible Sourcing team along with Procurement and Marketing actively work with suppliers to work towards compliance of the standard. The outcome of any assessment or discussion on the 6 principles with suppliers can inform purchasing decisions. Reckitt aim to work with suppliers to work towards compliance with the standard via regular discussion and action plans. In the case of a supplier found to be noncompliant Reckitt will work with the supplier to agree a time bound plan to resolve any concerns. In the unlikely case a solution cannot be agreed up to or found Reckitt may suspend our business relationship with the supplier. "

"As a supplier to RB, we expect you to comply with three sets of requirements, which form a standard part of our contracts: 1. Our Code of Business Conduct 2. Our Global Manufacturing Standard for responsible production (‘GMS’) 3. Our Policy & Standard for the responsible sourcing of natural raw materials [...] The seven principles of our GMS are underpinned by detailed requirements. These are in line with the International Labour Organisation’s (ILO) Fundamental Conventions (no forced labour, no child labour, freedom of association and no discrimination) and industry standards."

" No discrimination. Equal opportunities / rights What is discrimination? Discrimination means unfairly treating a worker. Discrimination can be based on many factors, including race, colour, language, caste, national origin, indigenous status, religion, disability, gender, marital status, sexual orientation, union membership, political affiliation, and age. It can occur across all work activities including hiring, remuneration and professional development. Why is this important? Discrimination violates a worker’s human rights. It creates divisions within the workforce and dissatisfaction among workers. It exposes employers to risks of prosecution and damage to reputation."

"We’ve come a long way since setting our targets since 2012. We’ve built specific standards, monitoring activities and remediation programmes for key natural raw materials, and we still have a long way to go."

"Suppliers must have a policy in place to reach free, prior and informed consent (FPIC)vii of the local communities impacted by new plantations. Plus have a systematic process to facilitate and demonstrate FPIC"

"Timber Product Traceability : Reckitt’s Responsible Sourcing Standard sets out criteria on traceability for all commodities Reckitt purchase. The criteria is: Suppliers should know the locations and ownership of primary producers and processors in their natural raw material supply chains and be capable of monitoring the extent to which these are able to adhere to the standard. They should also be aware of the communities living and working within these supply chains and the issues that face Systems are in place to enable suppliers to regularly assess and monitor the extent to which producers and processors are aligned to the standard; time-bound plans are in place to close any gaps... In addition, Reckitt set a 2025 goal for all paper and board to come from either certified (FSC/PEFC) or recycled sources which will allow us to increase our levels of traceability of our paper and board year on year. All paper & board suppliers are required to disclose annually their country, volume of recycled and of FSC / PEFC certified content (and where applicable certification number) to us. Through this target and regular communication with our suppliers an internal database is maintained where a record of country of origin is kept. The database is update on an annual basis and Reckitt are working towards more granular detail for the origin of this commodity...'Forest Risk Commodity: Timber Products Point to which commodity is traceable: Country: Total production/consumption volume traceable 98% [...]" We’re now applying stronger measures for better traceability and data. Our paper traceability is now up to 99% and we still expect to reach our goal for 100% of our paper and board to be from certified or recycled sources by 2025 or before."

"In 2020 98% of paper and board came from certified or recycled sources (excluding copackers). To break this figure down Reckitt purchase 16% virgin certified from FSC/PEFC and 82% is recycled/mixed sources."

"Sourcing of natural raw materials can have significant effects on environment, local communities and other stakeholders across the value chain. Reckitt is committed to responsible business conduct, including ensuring natural raw materials used in products are produced in a manner that meets or goes beyond applicable laws and regulations, respects human rights, safeguards health and safety, protects the environment, does not cause deforestation and generally supports contribution of business to achieving sustainable development. Our Responsible Sourcing Standard sets out 6 principles to continue to achieve Reckitt’s commitments. The scope is all-natural raw materials and it is applicable to up-stream from supplier facilities to primary producer lever. 1. Understanding production origins 2. Safeguarding workers and communities 3. Protecting ecosystems 4. Reducing Environmental impacts 5. Protecting Animal Welfare 6. Delivery through Partnerships Reckitt commitment to sourcing all paper and board packaging materials from certified or recycled sources. The responsible sourcing standard states: ‘Forests from which paper and board originates should be certified by the Forestry Stewardship Council (FSC) or the Programme for the Endorsement of Forest Certification (PEFC), scheme formally endorsed by these bodies or equivalent national forest certification systems Processors and end manufacturers of these materials should also be certified by these bodies and comply with requirements that allow Reckitt’s use of these organisations onpack/consumer logos if required. Paper and board that is certified post-consumer recycled can be used as an alternative to the above’ The Responsible Sourcing Standard is reviewed annually. Reckitt’s Responsible Sourcing team along with Procurement and Marketing actively work with suppliers to work towards compliance of the standard. The outcome of any assessment or discussion on the 6 principles with suppliers can inform purchasing decisions. Reckitt aim to work with suppliers to work towards compliance with the standard via regular discussion and action plans. In the case of a supplier found to be noncompliant Reckitt will work with the supplier to agree a time bound plan to resolve any concerns. In the unlikely case a solution cannot be agreed up to or found Reckitt may suspend our business relationship with the supplier."

In their 2021 CDP Reckitt Benckiser Group PLC state that their cut-off date is is 1993-1997. 100% of their of total production/ consumption covered by commitment

"Our minimum standards Our standards require that: • Suppliers of natural raw materials and packaging materials comply with all applicable environmental, health & safety, labour and social laws and regulations (including applicable land tenure and use rights)...We have introduced a new process to help ensure all suppliers meet our expectations. This builds on our existing compliance process, which previously affected only some suppliers. The process consists of self-assessment, RB risk assessment, audit and corrective action..... Annual self assessment: The annual self assessment process is monitored by our Global Supply Leadership Team, which includes RB’s EVP Supply (a member of RB’s Executive Committee) and SVP Purchasing. 2. Risk assessment We will review the Self Assessment Questionnaire responses to classify the selected suppliers as high, medium or low risk. Classification will also take account of the results from any previous audits shared with RB and the inherent risks associated with the supplier’s specific location and business activities. 3. External audit programme Each year selected high risk suppliers will be required to undertake an independent external audit.

"The policy is designed to enable all RB employees and Others to “Speak Up” and raise concerns internally and at a senior level and to disclose information which the individual believes shows malpractice or impropriety within the Group. These concerns could include: ▪ Financial malpractice or impropriety or fraud ▪ Failure to comply with legal obligations ▪ Dangers to health and safety or the environment ▪ Criminal activity ▪ Improper conduct or unethical behaviour ▪ Significant breaches of the Code of Conduct and associated policies or procedures ▪ Failure to comply with an applicable industry code to which RB has subscribed ▪ Attempts to conceal any of the above once they have occurred However, this is not intended to be an exhaustive list."

"Total Weight (metric tonnes) Paper and board 227,567"

"Auditing our suppliers We audited 232 suppliers in 2021, with around 61% achieving a ‘pass’ rating. This is lower than the 67% pass rate achieved in 2020 due to the expansion of our audit programme to a further 115 raw and packaging material suppliers. For some of them, this was the first time they had undergone an ethical audit to assess their on-site labour, health and safety, and environmental practices. This might be because they are a small and so less visible part of global value chains, or potentially because local regulatory frameworks are limited or not routinely inspected. Consequently, many of these suppliers don’t have mature sustainability processes and we will support them to build these as we move forward."

"Each year we complete a risk assessment of all natural raw materials used within our products. We use an external company to assess a range of social and environmental criteria to grade the materials we use from low to high priority. The results of this assessment ensure we continue to focus our efforts on the highest priority materials. Specific due diligence is then performed for materials deemed to be of a higher priority. Our compliance monitoring programme includes suppliers of key natural raw materials, all of whom must comply with our policy which is an integral part of our commercial contracts. Our compliance monitoring activities include: • In-depth responsible sourcing programmes • Traceability and compliance questionnaires • Supplier engagement including visits, meetings and assessments • Independent audits"

"4. Corrective action Where the audit finds non-compliances we will require the supplier to identify corrective actions and timescales for completing these actions. The auditor will need confirmation that the corrective actions have been completed to achieve compliance. Depending on the nature of the issue, the auditor may need to make a follow-up site visit. Natural raw materials suppliers We may carry out additional visits to suppliers of natural raw materials to discuss how they meet our minimum requirements. We may also require these suppliers to provide sourcing information to help us better understand the origins of the materials they supply. Flexibility We value an open and honest approach to any instances of non-compliance, and a genuine commitment to correct those non-compliances in an appropriate time frame. We are committed to working with our suppliers to address any issues. We recognise that in some regions or countries, particularly where there are complex and informal supply chains, reliably confirming compliance may be a difficult, complex and lengthy process. We recognise that working with suppliers while they address non-compliance by their own suppliers or internally may be a better long-term solution than immediately de-listing them. However, if mutually acceptable solutions cannot be reached we may be required to suspend our business relationship until a satisfactory solution can be found"

"As a supplier to RB, we expect you to comply with three sets of requirements, which form a standard part of our contracts: 1. Our Code of Business Conduct 2. Our Global Manufacturing Standard for responsible production (‘GMS’) 3. Our Policy & Standard for the responsible sourcing of natural raw materials [...] The seven principles of our GMS are underpinned by detailed requirements. These are in line with the International Labour Organisation’s (ILO) Fundamental Conventions (no forced labour, no child labour, freedom of association and no discrimination) and industry standards."

" No discrimination. Equal opportunities / rights What is discrimination? Discrimination means unfairly treating a worker. Discrimination can be based on many factors, including race, colour, language, caste, national origin, indigenous status, religion, disability, gender, marital status, sexual orientation, union membership, political affiliation, and age. It can occur across all work activities including hiring, remuneration and professional development. Why is this important? Discrimination violates a worker’s human rights. It creates divisions within the workforce and dissatisfaction among workers. It exposes employers to risks of prosecution and damage to reputation."

"We’ve come a long way since setting our targets since 2012. We’ve built specific standards, monitoring activities and remediation programmes for key natural raw materials, and we still have a long way to go."

"Suppliers must have a policy in place to reach free, prior and informed consent (FPIC)vii of the local communities impacted by new plantations. Plus have a systematic process to facilitate and demonstrate FPIC"

"We requested all suppliers of soy, or products containing soy, to complete a compliance review, through this process we established that all our raw soya originates from low-risk countries such as the USA"

"Our minimum standards Our standards require that: • Suppliers of natural raw materials and packaging materials comply with all applicable environmental, health & safety, labour and social laws and regulations (including applicable land tenure and use rights)...We have introduced a new process to help ensure all suppliers meet our expectations. This builds on our existing compliance process, which previously affected only some suppliers. The process consists of self-assessment, RB risk assessment, audit and corrective action..... Annual self assessment: The annual self assessment process is monitored by our Global Supply Leadership Team, which includes RB’s EVP Supply (a member of RB’s Executive Committee) and SVP Purchasing. 2. Risk assessment We will review the Self Assessment Questionnaire responses to classify the selected suppliers as high, medium or low risk. Classification will also take account of the results from any previous audits shared with RB and the inherent risks associated with the supplier’s specific location and business activities. 3. External audit programme Each year selected high risk suppliers will be required to undertake an independent external audit.

"The policy is designed to enable all RB employees and Others to “Speak Up” and raise concerns internally and at a senior level and to disclose information which the individual believes shows malpractice or impropriety within the Group. These concerns could include: ▪ Financial malpractice or impropriety or fraud ▪ Failure to comply with legal obligations ▪ Dangers to health and safety or the environment ▪ Criminal activity ▪ Improper conduct or unethical behaviour ▪ Significant breaches of the Code of Conduct and associated policies or procedures ▪ Failure to comply with an applicable industry code to which RB has subscribed ▪ Attempts to conceal any of the above once they have occurred However, this is not intended to be an exhaustive list."

"Auditing our suppliers We audited 232 suppliers in 2021, with around 61% achieving a ‘pass’ rating. This is lower than the 67% pass rate achieved in 2020 due to the expansion of our audit programme to a further 115 raw and packaging material suppliers. For some of them, this was the first time they had undergone an ethical audit to assess their on-site labour, health and safety, and environmental practices. This might be because they are a small and so less visible part of global value chains, or potentially because local regulatory frameworks are limited or not routinely inspected. Consequently, many of these suppliers don’t have mature sustainability processes and we will support them to build these as we move forward."

"Each year we complete a risk assessment of all natural raw materials used within our products. We use an external company to assess a range of social and environmental criteria to grade the materials we use from low to high priority. The results of this assessment ensure we continue to focus our efforts on the highest priority materials. Specific due diligence is then performed for materials deemed to be of a higher priority. Our compliance monitoring programme includes suppliers of key natural raw materials, all of whom must comply with our policy which is an integral part of our commercial contracts. Our compliance monitoring activities include: • In-depth responsible sourcing programmes • Traceability and compliance questionnaires • Supplier engagement including visits, meetings and assessments • Independent audits"

"Where the audit finds non-compliances we will require the supplier to identify corrective actions and timescales for completing these actions. The auditor will need confirmation that the corrective actions have been completed to achieve compliance. Depending on the nature of the issue, the auditor may need to make a follow-up site visit. [...] We value an open and honest approach to any instances of non-compliance, and a genuine commitment to correct those non-compliances in an appropriate time frame. We are committed to working with our suppliers to address any issues. [...] We recognise that working with suppliers while they address non-compliance by their own suppliers or internally may be a better long-term solution than immediately de-listing them. However, if mutually acceptable solutions cannot be reached we may be required to suspend our business relationship until a satisfactory solution can be found."