Supplier Code of Conduct Table of Contents

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

Supplier Code of Conduct

Table of Contents

WELCOME

INTRODUCTION

SUPPLIER CODE REQUIREMENTS

a. Human and Labor Rights

b. Environment

c. Animal Welfare

d. Business Ethics & Integrity

e. Reporting on Breaches or Concerns

MANAGEMENT SYSTEMS AND DEMONSTRATION OF COMPLIANCE

GOVERNANCE

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

WELCOME

The Hershey Company (“Hershey”) is committed to our purpose of Making More Moments of Goodness for

our consumers today and for generations to come. For more than 125 years, we have operated with high ethical

business standards and integrity in the communities where we work and live.

This commitment began with our founder Milton Hershey, a purpose-driven businessman who believed we

could use chocolate to make more moments of goodness in the world for our consumers today and for many

generations to come. We continue to build on that legacy today through our global sustainability strategy: Our

Shared Goodness Promise.

Our Shared Goodness Promise guides how we empower the remarkable people who make and sell our

brands. It shapes how we invest in the farming communities and regions that grow our ingredients; deliver on

our commitments to consumers, customers and external stakeholders; protect the environment; and support

children, youth and communities.

Hershey recognizes that each step in our supply chain has an impact on people, communities and the planet.

As a result, we prioritize implementation of strong social, environmental and ethical business standards

throughout our supply chain. Ultimately, building a sustainable future is a shared responsibility.

To preserve the trust placed in us, we expect our suppliers across the globe to commit to and uphold the same

high standards to which we hold ourselves – standards of integrity, values and operating principles and to work

ethically and sustainably to provide great tasting, high-quality products to our consumers.

Our Supplier Code of Conduct reflects Hershey’s values and principles and describes our requirements of our

suppliers with whom we leverage a continuous improvement mindset, a collaborative approach, and a bias for

action. By working together in collaboration with industry, civil society, government, and communities, we can

have a much larger and longer lasting impact. We welcome your partnership to build more moments of shared

goodness and a bright future.

Sincerely,

Jason Reiman, Senior Vice President, Chief Supply Chain Ocer

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

INTRODUCTION

This 2023 version of our Supplier Code of Conduct (“Supplier Code”) replaces our 2019 version and outlines

Hershey’s requirements and expectations 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 informed by the International Bill of Human Rights, including the Universal Declaration

of Human Rights; The ILO Declaration on Fundamental Principles and Rights at Work; the OECD Guidelines

for Multinational Enterprises; the International Covenant on Civil and Political Rights; and the International

Covenant on Economic, Social, and Cultural Rights. We operate in accordance with our endorsement of the

UN Guiding Principles on Business and Human Rights (UNGPs) and our commitment to the Ten Principles of

the UN Global Compact and the Sustainable Development Goals.

We require all Suppliers to comply with this Supplier Code. “Suppliers” refers to any third party that provides

goods or services directly to Hershey for compensation including, but not limited to, our ingredient, material

and packaging Suppliers; contract manufacturers and contract packers; labor providers; logistic providers;

distributors; licensees; construction and real estate rms; maintenance, repair and operations (MRO) providers;

information systems providers; and marketing and advertising agencies, including their parent, subsidiary or

aliate entities. Suppliers, including sub-contractors or labor agencies of our Suppliers, are also required to

adhere to the Supplier Code.

The Supplier Code applies to all Suppliers’ workers, including permanent, temporary, directly or indirectly

hired contract workers through subcontractors or labor providers, foreign, or migrant workers (collectively,

“Workers”).

Our Suppliers shall communicate this Supplier Code or equivalent requirements in a language understood

by Workers in their own operations and to their Suppliers. Suppliers must adopt adequate and ecient

management systems, polices, procedures and training and conduct human rights and environmental due

diligence to uphold the standards and requirements set forth in this Supplier Code.

We require our Suppliers to abide by all applicable national, federal, state, provincial and local laws/regulations

in the markets where they operate; however, where local laws or standards dier from this Supplier Code, the

more stringent standards and principles apply.

Hershey recognizes the size and complexity of our global supply chain spanning from manufacturers,

distributors and processers to large-scale agricultural sites, family farms and smallholders. While it is not

currently feasible for us to monitor compliance of every Supplier in our global supply chain, we leverage a

risk-based approach to assessing compliance against our Supplier Code. We also understand that some key

contributors in our extended value chain , such as smallholder farmers, may not be able to meet all of our

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

outlined requirements today. When instances of non-compliances are identied in our extended value chain,

in the spirit of continuous improvement, Hershey is committed to working with and supporting our Suppliers to

meet, remediate and whenever possible, exceed, the requirements in this Supplier Code. We also encourage

our Suppliers to participate in industry eorts to drive continuous improvement throughout their supply chain.

By Supplier acceptance to provide goods or services directly to Hershey, the Supplier acknowledges its

acceptance of the Supplier Code and intention to comply with its requirements.

REQUIREMENTS AND EXPECTATIONS

HUMAN & LABOR RIGHTS

Hershey is committed to respecting human rights of individuals across our supply chain. We work with our

Suppliers to encourage and promote the principles of this policy throughout their networks as well as identify

human rights risks and issues, take appropriate actions to respond to potential human rights risks, and support

and provide access to remedy.

Child Labor:

Hershey does not tolerate child labor in our supply chain. We are committed to the elimination of the “worst

forms of child labor,” as dened by ILO Convention 182. Hershey requires our Suppliers, including their labor

agents/agencies, to prevent child labor in their operations and in their supply chain and encourages our

Suppliers to participate in industry eorts aimed at the elimination of such practices wherever they exist in the

supply chain.

Forced Labor & Human Tracking:

Hershey does not tolerate forced labor or human tracking in our supply chains. Hershey requires that all labor

in its supply chain be voluntary, and that Workers are allowed freedom of movement. All forms of forced labor

• No individuals are hired under 15 years of age, or 14 years of age where local law allows,

consistent with ILO Convention No. 138, or under the legal minimum age for employment in

the country, whichever is greatest.

• Any employment or utilization of Workers under the age of 18 must not interfere with

schooling or vocational education and/or expose children and young workers (between 15

and 18 years) to work that is mentally, physically, socially or morally dangerous.

• In instances where child labor is identied, remedial measures appropriate for the

situation will be implemented, including removing the child or young worker from the work

and ensuring their safety.

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

and human tracking are prohibited including but not limited to any form of prison, slave, bonded or forced

indentured labor.

In line with our Responsible Recruiting & Employment Policy, Hershey supports the Employer Pays Principle

and the Consumer Goods Forum’s Priority Industry Principles, and our Suppliers, including their labor agents/

agencies, are required to act in accordance with these Principles as well.

• The recruitment, transportation, transfer, harboring or receipt of persons, by means

of threat or use of force, coercion or other means, for the purpose of exploiting them is

prohibited.

• In advance of employment, Suppliers, including their labor agents/agencies, provide

Workers with written, accurate and understandable information in a language understood

and acknowledged by the Worker regarding the basic terms and conditions of their

employment clearly stating their rights and responsibilities as well as information on wages,

working hours, overtime, benets, leave and disciplinary procedures. Workers must receive

a copy of their employment terms and conditions. Any changes to their employment terms

and conditions are agreed in writing, in a language understood by the Worker, between

the Worker and Supplier. Verbal instead of written contracts may be acceptable only if they

create legally binding employment relationships under applicable law.

• Suppliers, including their labor agents/agencies, must not retain any personal

identication documents, travel documents, including passports, or wages of Workers

as conditions of their employment. Workers are free to leave work and terminate their

employment upon reasonable or legally required notice without penalty.

• The Employer Pays Principle: No Worker should pay for a job – the costs of recruitment

should be borne not by the Worker but rather by the employer.

• Priority Industry Principles: Every Worker should have freedom of movement; no Worker

should pay for a job; and no Worker should be indebted or coerced to work.

• Suppliers associated with recruitment or hiring for Hershey or for a Supplier of Hershey

shall not require Workers to pay recruitment fees or other related fees for their employment.

Prohibited fees may include but are not limited to skills tests, medical examinations,

passport and visa processing fees, travel and lodging, background checks, language

interpretation or translation fees, legal fees and uniforms. If any such fees are found to have

been paid by Workers, the fees must be repaid by the Supplier to the Workers concerned.

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

Freedom of Association & Collective Bargaining

Hershey respects the rights of Workers to freedom of association and collective bargaining across its

operations and supply chain.

Non-Discrimination

Hershey does not tolerate any form of discrimination in the workplace. We are committed to diversity, equity

and inclusion in the work environment and throughout our supply chain. Suppliers are required to commit to

the same principles and should pay particular attention to respecting the rights of vulnerable or marginalized

worker populations most at risk of discrimination.

• Workers have the right to lawfully form, voluntarily join or not form or join trade unions or

other organizations of their choosing and collectively bargain without fear of discrimination,

retaliation, harassment or intimidation.

• Workers have the right to freely elect their union or worker representative. Workers’

representatives must not be discriminated against, unfairly treated or disciplined based on

their representation activities. Representatives must have reasonable access to carry out

their functions in the workplace.

• In cases where freedom of association is restricted by local law, alternative means of

freedom of association, worker representation, and bargaining will not be obstructed

consistent with local law.

• Discrimination in the workplace that is based on the grounds of an individual’s race; color;

gender; age; national origin; religion; citizenship status; marital status; sexual orientation;

preventing Workers from engaging in, or refraining from engaging in, protected union

activity; gender identity; transgender status; physical or mental disability; protected veteran

status; genetic information; pregnancy (including childbirth and related medical conditions,

including medical conditions related to lactation); or other categories protected by national,

federal, state, provincial or local law goes against Hershey’s values and is strictly prohibited.

• Suppliers must not subject Workers or potential Workers to the use of medical tests,

including pregnancy tests or health exams in a discriminatory way. When health exams

are required by local law, the results cannot be used to dismiss Workers or otherwise

discriminate against them in a way inconsistent with applicable law.

• Hiring and employment decisions, including those relating to compensation, benets,

promotion, training and development, discipline, and termination are based solely on the

Worker’s skill, ability, experience and performance or otherwise consistent with local law.

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

Hershey Company is committed to promoting Diversity, Equity and Inclusion in our supply chain through

our Supplier Diversity Program. Suppliers are encouraged to adopt an inclusive procurement strategy and

increase the representation of, and expenditure with, companies owned by people of color (POC), women,

U.S. military veterans, people living with disabilities, LGBTQ+ individuals or other individuals that qualify as

socioeconomically disadvantaged. Quarterly reporting on diverse spend is encouraged and may be required.

Harassment

Hershey does not tolerate harassment in the workplace or in our supply chain. Hershey strictly prohibits any

harassment, intimidation, criminalization or violence towards human rights defenders or anyone who shares a

human rights concern, and we require the same of our Suppliers.

Working Hours, Wages & Benets

Hershey is committed to upholding applicable laws and collective bargaining agreements regarding working

hours, wages, benets and paid leave for individuals employed throughout the supply chain. Hershey pays

employees for all hours worked. We encourage our Suppliers to work toward paying a living wage or living

income that is sucient for Workers to aord a decent standard of living for their family in line with our Living

Wage and Income Position statement.

• All Workers will be treated with dignity and respect and will not be subject to a hostile

work environment consisting of threats or use of any form of unethical treatment, bullying

or intimidation, violence or corporal punishment, or other forms of physical, mental, or

sexual harassment or abuse.

• Disciplinary policies and procedures in support of these requirements are clearly dened

and communicated to all Workers. Disciplinary measures are appropriate and shall not

include physical, mental or psychological punishment. All disciplinary measures should be

fully documented.

• Wages and benets are paid to the Worker on time, regularly, and in full and at least equal

to the applicable legal minimum wage and any associated statutory benets.

• Working hours reflect applicable legal norms and overtime hours are paid at the legally

mandated premium or in line with the guidance provided by ILO Convention 1 (the rate of

pay for overtime shall not be less than one-and-one-quarter times the regular rate) if there

is no mandated premium.

• Deductions, deposits or withholding of wages must comply with applicable law, must not

reduce wages to below minimum legal wage, and must have express permission from the

Worker in a language they understand.

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

Worker Health & Safety

Hershey requires that all Workers be provided with a safe and healthy working environment.

• Deduction from wages as a disciplinary measure must not be excessive and must follow all

local legal requirements.

• Pay slips shall be provided to Workers for each pay period explaining their compensation,

including wages paid for regular and overtime hours worked (if Worker is paid hourly);

benets, bonuses and incentives; and any agreed or legally allowable deductions.

• Suppliers shall ensure that work schedules and rest periods are compliant with applicable

local legal requirements. Workers are entitled to meal and rest breaks, which, at a minimum,

must comply with local law. Work hours and schedules should not be excessive and

negatively impact employees’ health or safety. Suppliers should not use alternate forms of

labor arrangements, such as temporary labor arrangements, home-working or apprentice

schemes or other similar devices, to avoid obligations to Workers under labor or social

security laws and regulations.

• Suppliers must conduct health & safety risk assessments to identify, assess, and evaluate

potential risks to prevent, mitigate and reduce Worker’s exposure to hazards such as

occupational injury and illness, emergency situations and events, physically demanding and

repetitive tasks, and hazardous materials.

• Workers have the right to refuse and report unsafe or unhealthy working conditions

regardless of role, title or responsibility without fear of retaliation.

• Workers are trained on the appropriate occupational health and safety policies and

procedures, including emergency evacuation procedures, prior to employment and

then on a regular basis in language(s) understood by the Workers. Workers are provided

appropriate personal protective equipment at no cost to Workers and instructed on its

appropriate use.

• Free and potable drinking water is provided to all Workers.

• All Workers should have access to safe, adequate and clean sanitation facilities that

correspond to their gender identity. Sanitation facilities should include handwashing

stations and soap. Workers must be provided reasonable access to toilets or lactation

breaks that, at a minimum, comply with applicable law.

• Ventilation, light, temperature, and noise level must comply with local law requirements

and must be sucient for worker comfort.

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

Food Safety & Quality

Hershey is dedicated to providing safe, high-quality products and we expect our Suppliers to support this

commitment.

Land Rights

Hershey is committed to following the principles of Free, Prior and Informed Consent of Indigenous Peoples

for property or land negotiations. Any supplier involved in the using, leasing, and purchasing of land shall follow

these requirements. Hershey strictly prohibits harassment, intimidation, criminalization or violence towards

human rights, environmental and land defenders.

ENVIRONMENT

Hershey is committed to reducing our environmental impact across our supply chain and to supporting

sustainable operational and agricultural production practices. We work with our Suppliers who are critical

• If applicable, when living accommodation is provided for Workers, either by the Supplier,

a labor agent/agency of a Supplier, or other aliate, dormitories are clean, well maintained

and in compliance with safety regulations. Workers shall have freedom of movement in and

out of the dormitories.

• Products and services delivered must meet or exceed food safety and quality standards

required by applicable law and Hershey’s stringent quality standards as outlined in our

Supplier Quality Expectations Manual.

• Any concerns about product safety or quality must be reported to Hershey.

• All forms of land grabbing are prohibited.

• Supplier must respect and uphold land tenure rights of individuals, Indigenous Peoples

and local communities aected by sourcing practices, supply chains and operations.

• Women’s right to land ownership and tenure and access must be recognized and

respected.

• Adherence to the requirements for the fulllment 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.

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

partners in our eorts to responsibly and sustainably source our ingredients, packaging materials and other

goods and services in a way that will help reduce negative impacts and contribute to positive impacts on air,

land, water and biodiversity.

• Suppliers must conduct ongoing environmental due diligence to identify, assess, and

evaluate potential risks to prevent, mitigate and reduce negative impacts on air, land, water

and biodiversity.

• Operations must fully comply with applicable environmental laws and regulations

including those related to air pollution, greenhouse gas emissions, waste disposal,

hazardous waste, water use and wastewater, and biodiversity and protected areas.

• All required environmental permits (e.g., discharge and eluent monitoring records) are

obtained, maintained and kept current and any operational, registration and reporting

requirements shall be followed.

• Operations and work across supply chains shall not contribute to deforestation or loss

of biodiversity. Suppliers of forest-risk commodities, including cocoa, palm oil, paper and

board, and soy, shall comply with Hershey’s No Deforestation Policy and must implement

their own No Deforestation Policy and commitments to protecting High Conservation

Value and High Carbon Stock areas. Suppliers will only sell ingredients and materials that

are veried deforestation and conversion-free to Hershey, based on applicable cut-o

dates indicated in our No Deforestation Policy.

• Air emissions, wastewater and solid waste generated from operations are to be

characterized, monitored, controlled and treated as required prior to discharge or disposal.

Suppliers are encouraged to set GHG emission reduction goals across Scope 1, Scope 2 and

Scope 3 emissions.

• Suppliers are encouraged to actively measure, manage and disclose environmental

impacts in other areas such as non-GHG atmospheric emissions (e.g., nitrous oxides and

particulates), energy usage, water use, solid and water waste and biodiversity as well as

to set targets and implement action plans for reducing environmental impacts. Public

reporting on annual environmental performance is encouraged and may be required.

• Suppliers should reduce water consumption, especially those located in areas of high-

water stress as dened by the WRI Aqueduct Tool.

• Suppliers should practice good waste management processes, following the waste

management hierarchy.

• Suppliers producing or sourcing agricultural commodities should take appropriate steps

SUPPLIER CODE OF CONDUCT ©The Hershey Company 2023

ANIMAL WELFARE

Hershey is committed to improving farm animal welfare throughout our supply chain. Hershey recognizes the

internationally accepted “Five Freedoms of Animal Rights” established by the British Farm Animal Welfare

Council. We expect our suppliers of animal-derived materials to meet and communicate these expectations

throughout their supply chain.

BUSINESS ETHICS AND INTEGRITY

Integrity is one of our core values and is central to what we stand for. Operating as an ethical company is

fundamental to how we build trust with all our stakeholders. Hershey is committed to conducting business

ethically and lawfully in countries where we operate across our supply chain. Our Compliance Ambassador

program is a formal network of local “Compliance Champions” to drive a speak-up culture and increase

open reporting by establishing an additional condential and neutral channel for employees to raise ethics

and compliance concerns, including concerns related to Suppliers. We conduct business with Suppliers who

demonstrate a strong commitment to ethical behavior.

• Suppliers of animal-derived materials must comply with Hershey’s Farm Animal Welfare

Position and should implement their own policy recognizing the “Five Freedoms of Animal

Rights”:

• Freedom from hunger and thirst - by providing ready access to fresh water and a

diet to maintain full health and vigor.

• Freedom from discomfort - by providing an appropriate environment including

shelter and a comfortable resting area.

• Freedom from fear and distress – by ensuring conditions and treatment which

avoid mental suering.

• Freedom from pain, injury, and disease – by ensuring prevention or rapid diagnosis

and treatment.

• Freedom to express normal behavior – by providing sucient space, proper

facilities and company of the animal’s own kind.

to preserve soil and water quality and minimize their impacts on soil and water and are encouraged to reduce

use of chemical pesticides and fertilizers across their supply chain.

• Suppliers conduct their business in accordance with the highest ethical standards and to

have controls in place that prohibit and detect the misuse of company assets, corruption,

bribery, improper gifts, extortion, embezzlement and even the appearance of conflicts of

interest.

• Suppliers’ business dealings should be fair, legal and honest. Suppliers must not engage in

illegal cooperation with competitors including bid rigging, price xing, market allocations,

or any other prohibited conduct that limits free and fair competition. Suppliers and business

partners will also accurately reflect their business dealings in their books and records.

• Suppliers shall abide by all applicable anti-corruption and bribery laws and regulations of

the countries in which they operate, including the Foreign Corrupt Practices Act (FCPA)

and applicable international anti-corruption conventions.

• Suppliers will also accurately reflect their business dealings in their books and records.

Supplier shall comply with all applicable economic sanctions, anti-money laundering and

anti-tax evasion legislation and rules.

• Suppliers shall refrain from oering gifts and/or excessive hospitality to Hershey

employees or its designated representatives which may influence or be perceived to

influence decision making. All business courtesies extended to Hershey employees or

its designated representatives shall comply and abide by Hershey’s Gifts and Hospitality

policy.

• Suppliers and business partners with access to Hershey’s condential information should

not disclose such information to any other person without our advance written consent.

Condential information in the Supplier’s possession regarding Hershey shall not be used

to engage in or support insider trading, in violation of other laws or be used in a way that

negatively impacts Hershey. This obligation continues after our business relationship ends.

• To the extent that Suppliers transports goods for Hershey into the United States, Suppliers

shall comply with the C-TPAT (Customs-Trade Partnership Against Terrorism) security

procedures on the U.S. Customs website at https://www.cbp.gov/ (or other active website

established for such purpose by the U.S. government).

• Suppliers must comply with all applicable data privacy and protection laws and regulations

concerning the collection, use and protection of personal information when conducting

business with Hershey. Suppliers must take appropriate steps to safeguard condentiality

and privacy of personal information pursuant to applicable data privacy laws.

Grievance Mechanisms

Hershey requires Suppliers to provide grievance mechanisms, in line with the UN Guiding Principles on

Business and Human Rights (UNGP) eectiveness criteria, that are transparent, responsive, anonymous,

unbiased and condential to Workers and other parties across the value chain. Suppliers are encouraged to

review their grievance mechanisms against the UNGP eectiveness criteria periodically and adjust, as needed,

for eectiveness.

REPORTING A BREACH OR CONCERN

Hershey values the help of Workers across our supply chain who identify and speak up in good faith about

potential violations and concerns that need to be addressed or explained.

• Workers know of and have access to grievance mechanisms which allow for anonymous

reporting. Reported concerns and violations are addressed in a timely manner and follow a

clearly outlined process.

• Workers who speak up in good faith are protected from retribution, retaliation and reprisal.

• Suppliers shall not prevent complainants from using other channels or procedures,

such as local law enforcement or workplace related agencies, to resolve their issue where

relevant.

• Suppliers should aim to have an appropriate gender balance in the composition of their

internal grievance committee that processes complaints.

• Suppliers must notify Hershey if any concerns or violations are reported through the

grievance mechanism that are in direct violation of this Supplier Code.

Concerns can be shared condentially and anonymously via phone or web at www.HersheysConcern.com. Local toll-free phone

numbers are available selecting the location in the “Call us” section in the portal. To change the language of the portal, select the

language in the top right corner dropdown.

• Violations and concerns should be reported directly to Hershey’s Concern Line

, an

independent third-party monitored service available 24/7, in more than 60 countries with

toll-free numbers available in each location. The Concern Line is available via phone and

internet to employees, suppliers and other parties; reports can be made anonymously.

• Hershey does not retaliate nor permit retaliation against anyone who makes a good faith

report about any potential violation.

Examples of issues that can be raised to Hershey’s Concern Line include but are not limited to violations

against applicable law or this Supplier Code of Conduct, human rights violations, discrimination or harassment,

environmental violations or deforestation, conflicts of interest, insider trading, food safety issues, and retaliation

against anyone speaking up in good faith.

MANAGEMENT SYSTEMS AND DEMONSTRATION OF COMPLIANCE

Hershey intends to work with Suppliers that share our values, and who are actively implementing action plans

that adhere to this Supplier Code. We are also committed to collaborating and working with our Suppliers on

continuous improvement.

Management Systems

Suppliers must establish adequate and eective management systems, policies, procedures, nancial

documentation, non-compliance and grievance procedure, and training programs to uphold and ensure

ongoing compliance with all applicable laws and standards, including this Supplier Code within their own

business operations and supply chain. We reserve the right to request from our Suppliers information about the

management of relevant issues outlined in the Supplier Code. For more guidance and information on strong

management systems, please refer to our Supplier Program Guidebook and Supplier Quality Expectations

Manual.

Assessments and Audits

Hershey monitors compliance with this Supplier Code through our Responsible Sourcing and Human Rights

Due Diligence Programs, namely our Responsible Sourcing Supplier Program. We reserve the right to verify

compliance with this Supplier Code, at the Supplier’s own expense, 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 condential worker interviews. If non-compliances are observed, the

supplier will be required to take corrective actions within the allotted timeframes acceptable to Hershey.

If Suppliers fail to implement the corrective action plans within acceptable timeframes and do not remedy

any act of non-compliance, Hershey may, in its sole discretion and without any further obligation to Suppliers,

suspend purchases, refuse to take delivery under any purchase order and return any goods or services from

the supplier until the corrective actions have been successfully implemented, or may terminate its business

relationship with the supplier in addition to any other rights or remedies available to Hershey.

Traceability and Transparency

We also reserve the right to request that Suppliers disclose information that may pertain to geographical

GOVERNANCE

Management of our Supplier Code of Conduct is the responsibility of the Global Responsible Sourcing,

Procurement Team and is led by our Director of Global Responsible Sourcing who reports into the Vice

President Procurement, who reports to the Senior Vice President Chief Supply Chain Ocer. The day-to-day

management of our Responsible Sourcing Supplier Program and related due diligence programs is led by the

Global Responsible Sourcing team, in partnership with our buyers, category and relationship managers across

Procurement and Supply Chain, Licensing and The Hershey Experience. The Global Responsible Sourcing

team monitors supplier compliance to this Supplier Code, supports suppliers’ continual improvement through

corrective action plans and capacity building, and proactively identies opportunities for future due diligence.

The Global Responsible Sourcing Team works closely with our Global Sustainability & ESG Team, particularly

around sustainability eorts that include human rights and environment in our entire value chain, including our

agricultural and manufacturing supply chains. Ultimate oversight for Global Responsible Sourcing resides with

our Board of Directors and our Executive Committee (inclusive of the CEO and the CEO’s direct reports) who

are briefed at least on an annual and bi-annual basis, respectively.

location of facilities that produce any item supplied to Hershey, origin of raw materials produced within their

facilities and environmental performance indicators such as Greenhouse Gas emissions.