Nestle S A : Nestlé Responsible Sourcing Core Requirements

Nestlé Responsible Sourcing Core Requirements

Issuing department

ESG Strategy and Deployment

Target audience

Public

Date of approval

January 2024

Copyright

All rights belong to Société des Produits Nestlé S.A., Vevey, Swizerland. © 2024, Société des Produits Nestlé S.A.

Contents

I. Introduction	2
Preamble	2
Purpose	2
II. Applicability	2
III. Verification mechanisms and reporting	3
Verification mechanisms	3
Addressing non-compliances	3
Reporting non-compliances	3
IV. Requirements	4
Requirements structure	4
Requirements for Direct Suppliers	4
1. Human rights and environmental due diligence (HREDD) Management System Requirements	4
2. Business ethics, compliance, and transparency	5
3. Human rights	5
4. Environment	8
5. Animal-based production	9
6. Aquaculture and fisheries	10
Requirements for Origins	10
1. Business ethics, compliance, and transparency	10
2. Human rights	10
3. Environment	13
4. Animal-based production	14
5. Aquaculture and fisheries	15
Appendices	16
Appendix 1 - Related Nestlé frameworks and strategies	16
Appendix 2 - Definitions applicable to the Requirements	16
Appendix 3 - References	18
Appendix 4 - List of pesticides referred to under "Use of Agrochemicals"	19

Nestlé Responsible Sourcing Core Requirements

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I. Introduction

Preamble

Sourcing with care is a fundamental pillar of Nestlé's pur- pose, which is to unlock the power of food to enhance quality of life for everyone, today and for generations to come. Our aim is to ensure that our responsible sourcing core requirements are systematically put into effect throughout our supply chain, thereby helping to transform production practices in a way that will impact positively on people, nature and climate. This approach is helping us build the foundations necessary to advance regenerative food systems at scale.

Our Nestlé Responsible Sourcing Core Requirements (the "Requirements") contribute to the implementation in our supply chain of our commitment towards the UN Guiding Principles on Business and Human Rights (UNGPs), the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises on Respon-

sible Business Conduct, the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

These Requirements complement other Nestlé commit- ments, strategies and frameworks, such as our Human Rights Framework and Roadmap and associated salient issue action plans, our Net Zero Roadmap, our Agriculture Framework, and our Forest Positive Strategy (see Appendix 1).

This 2024 version replaces and supersedes the Nestlé Responsible Sourcing Standard adopted in 2018.

Underlined terms are defined in Appendix 2.

Purpose

These Requirements need to be complied with by all actors forming, directly or indirectly, part of our supply chain as further described in Chapter 2. They constitute an integral part of our contracts with our Direct Suppliers.

Nestlé recognizes that some social and environmental issues require long-term, tailored interventions to tackle their root causes. To help address the complex factors that contribute to those issues, we implement complementary frameworks and strategies, as referred to in Appendix 1 (e.g. Human

Rights Salient Issue Action Plans, Agriculture Framework), and work on two different levels:

1. Taking action in our supply chain to assess the risks, address them, and monitor and report on activities and their outcomes.
2. Using leverage and collaboration to actively support col- lective engagement to help address widespread, systemic environmental and social issues.

II. Applicability

The Requirements, set out under Chapter IV, apply to Direct Suppliers and Origins, as relevant.

Direct Supplier(s) are entities or individuals having a direct business relationship with Nestlé (e.g. through a contract or because they invoice Nestlé), including their employees, agents, and subcontractors. Co-manufacturers are considered Direct Suppliers.

Origins are entities or individuals responsible for the harvest or primary production of the materials and ingredients we source for the manufacturing of our products (e.g. farms, plantations, fishing vessels), including packaging materials.

Where Direct Suppliers are also entities or individuals in Origins, the requirements for Origins apply.

Where Direct Suppliers are not entities or individuals in Origins, it is the responsibility of Direct Suppliers to cascade down the Requirements to the next tiers of the supply chain, all the way to the Origin(s).

The Requirements applicable to Origins take account of the farm context, such as its size (e.g. hectares and number of workers) and its structure (i.e., formal or informal).

Academic institutions and research centers that we collaborate with fall outside the scope of these Requirements.

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III. Verification mechanisms and reporting

Verification mechanisms

We verify alignment to and compliance with these Requirements using different methods at different tiers of the supply chain. These include self-declaration,desk-based assessments and second or third-party site audits or assessments. The tools used to assess compliance depend, at Nestlé's dis- cretion, on the supply chain tier and the level of risk. Risk is assessed taking into consideration different criteria, such as the country(ies) of operation and of origin (for materials and ingredients), the level of spending, and the type of goods or service supplied to Nestlé.

We have also identified priority materials and ingredients that present a higher risk of environmental and/or social issues. In those cases, we work closely with our Direct Suppliers and other partners to conduct a supply chain mapping and carry out assessments in the upstream supply chain.

Direct Suppliers

• Human Rights and Environmental Due Diligence (HREDD) assessments
• Site audits carried out by independent audit firms using Sedex best-practice principles and the SMETA methodol- ogy
• Responsible Business Alliance (RBA) audits
• EcoVadis self-assessment questionnaire
• Any other means, as may be required by Nestlé

Origins (for our priority materials and ingredients) 1

• Validated certification schemes
• Validated industry schemes or programs
• Validated landscape or jurisdictional initiatives

Addressing non-compliances

Non-compliances identified through the verification mechanisms outlined above, or in any other manner, must be addressed by the relevant entity through a time-bound action plan agreed with Nestlé, which will include prevention, mitigation and remediation actions, as appropriate. Nestlé may decide, as its own discretion and without any responsibility, to suspend the relationship with the Direct Supplier or require suspension of the Direct Supplier's non-compliant site(s), sub-contractor(s) or sub-tier supplier(s) until an action plan is agreed, or during the execution of the action plan, should the timelines or actions be delayed or not executed as agreed. In case of suspension, the Direct Supplier, site(s), subcon- tractor(s) or sub-tier supplier(s) may be allowed to re-enter Nestlé's supply chain if there is clear evidence, as required by Nestlé, that practices have improved to the required level.

Nestlé reserves the right to terminate the commercial relationship with the Direct Supplier in accordance to the

relevant contract, or to exercise any other remedy as set out in the relevant contract or under the applicable law, in case (i) the action plan appears unsuitable for the purposes of improving practices to the required level, (ii) the Direct Supplier does not agree to develop and implement an action plan, (iii) the agreed action plan was not executed or executed in a satisfactory manner or (iv) the Direct Supplier does not provide evidence of improved practices within a reasonable period of time.

The process of setting up action plans to address non-compliances shall not represent or be understood as a waiver of Nestlé's other rights and remedies, as set out in the relevant contract with the Direct Supplier or under the applicable law. For the sake of clarity, if there is any conflict between the referred process and the contract between Nestlé and the supplier, the contract shall prevail.

Reporting non-compliances

Direct Suppliers must notify Nestlé of any actual or potential severe adverse impact on human rights or the environment, keeping Nestlé informed of the progress of any investigation and shall, if requested, consult Nestlé regarding all material steps in the process until remediation. Severe adverse impacts must be notified to the following e-mail address: [e-mail].

Direct Suppliers must retain all supporting documents and evidence in order to maintain an adequate record of all due diligence processes, grievances submitted by affected stake- holders, including records related to investigations under-

taken, and grant access to Nestlé to review such records upon demand. Upon Nestlé's first demand, the supplier must send a report to Nestlé with detailed information on what has been achieved, a detailed progress plan and, if requested, undergo a verification process of compliance.

We also encourage the reporting of any suspicion of non-compliance with our Requirements by Direct Suppliers or any other part of our supply chain through our Speak Upsystem, an independently operated reporting system. Reports can be submitted confidentially via a webform or call a toll-free number.

1 Countries of origin categorized as low-risk for environmental, social and governance issues using data from Verisk Maplecroft are not subject to verification.

Nestlé Responsible Sourcing Core Requirements

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IV. Requirements

Requirements structure

The Requirements fall into the following categories:

Substantive Requirements, which are requirements on specific practices or topics.

Management Systems Requirements, which are:

• The processes related to ensuring the effective imple- mentation of the Substantive Requirements, and
• Human Rights and Environmental Due Diligence (HREDD) systems.

The Requirements may be amended from time to time, as international standards, national or supranational regulations or industry standards evolve.

Current Requirements are based on, among others, the guiding principles, standards and conventions referred to in Appendix 3.

Requirements for Direct Suppliers

1.Human rights and environmental due diligence (HREDD) Management System Requirements

These apply to our Direct Suppliers, and may be evidenced by HREDD systems established by the parent company, where applicable.

1.1 Embedding HREDD into policy and management systems

1. Direct Suppliers have policies or commitments cover- ing all requirements laid out in these Requirements.
2. Direct Suppliers have management systems and processes, in line with the UNGPs, to implement those policies and commitments.

1.2 Traceability systems

1.2.1 Direct Suppliers have in place traceability systems for materials and ingredients that enable assessment of human rights and environmental risks, and make it possible to ascertain that the production and process- ing units of Origins comply with the supplier's commit- ments and policies, or enable the extent and nature of the issues that must be resolved to be determined.

1.3 Identify and assess adverse impacts in own opera-

tions, supply chains and business relationships

1.3.1 Direct Suppliers assess actual and potential adverse impacts on people and the environment and use this information to prioritize issues, high-risk operations, geographies, and supply chains.

1.4 Address adverse impacts

1.4.1 Based on the results of their risk assessment (as per point 1.3 above), Direct Suppliers have action plans in place to prevent, mitigate and remedy potential and actual adverse human rights and environmental impacts that they may cause or contribute to through their own activities, or which may be directly linked to their operations, products or services by their business

relationships. Those actions should take into consideration the Direct Supplier's heightened risks when operating in or sourcing from a conflict-affected area, in line with the UNGPs.

1.4.2 Direct Suppliers cascade down human rights and envi- ronmental requirements to their respective suppliers and subcontractors.

1.5 Grievance management and remediation

1. Direct Suppliers implement or ensure the existence of an effective grievance mechanism accessible to all affected stakeholders.
2. Direct Suppliers have processes in place to address grievances in an effective and timely manner.

1.6 Monitoring and verification

1. Direct Suppliers effectively track the progress and effectiveness of their action plans (as per point 1.4 above) through monitoring and impact measurement.
2. Direct Suppliers conduct an annual review of their HREDD management systems and use learnings to drive continuous improvement.
3. Direct Suppliers engage a second partyto validate the effectiveness of their HREDD management systems.
4. Direct Suppliers have an on-going engagement pro- cess with their own suppliers, which includes cascad- ing HREDD requirements, assessing their own sup- pliers' performance, agreeing on their supplier action plans, monitoring progress, and taking action.

1.7 Reporting

1.7.1 Direct Suppliers publicly report on the actual and potential risks in their own operations, suppliers, and sourcing regions, as well as on the actions being taken to address those risks.

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2. Business ethics, compliance, and transparency

Substantive Requirements

1. All international, national, federal, state or local laws and regulations in the countries of operation and any other applicable laws, including those relating to international trade (such as those relating to sanctions, export controls and reporting obligations), anti-bribery, human rights, environment, no deforestation, data pro- tection, confidentiality and privacy, intellectual property as well as anti-trust and competition laws, must be complied with.
2. Improper payments for or from governments officials are not offered, made, solicited, or accepted, directly or indirectly, and contractual relations with Nestlé or with sub-tiers are not knowingly used as a vehicle for improper payments to government officials.
3. Gifts exchanged with Nestlé must be reasonable, mod- est and appropriate under the circumstances and must not create the appearance of improper influence or ille- gitimate advantages. Gifts should normally be offered only on customary business and cultural occasions and must never include cash or cash equivalents.
4. Meals, hospitality, and entertainment must be rea- sonable and appropriate, and must be conducive and proportionate to the legitimate underlying purpose. Reasonable and appropriate entertainment may be offered solely in connection with legitimate business meetings and conferences. They may never be pro- vided on a stand-alone basis.
5. Any conflict of interest, involving a Nestlé employee or not, must be duly reported.
6. All information must be provided to Nestlé regarding the origin of the materials and ingredients used to

produce the products (if any) and on the movement of the products, as well as complete and accurate records relating to the manufacture, packaging, testing, stor- age, shipment and destruction of the products and their ingredients, including production code accountability records. Suppliers give their consent, and must obtain any other necessary consent from relevant third parties, for the public disclosure by Nestlé of supply chain information (including, without limitation, to the authorities, the media, and other organizations) through its annual supply chain disclosure exercise

in order to increase transparency towards all relevant stakeholders. Nestlé and its affiliates will have no responsibility towards the supplier, provider or any third parties in relation to the use of such information.

2.7 All information related to the products and services supplied to Nestlé, including but not limited to, green- house gas emissions, packaging recyclability, regener- ative agriculture practices and sustainability commit- ments is disclosed to Nestlé.

Management Systems Requirements

1. An effective conflict of interest policy and organiza- tional processes to prevent and mitigate conflicts of interest are maintained.
2. Adequate internal systems are in place to maintain awareness of and ensure compliance with all applica- ble laws.
3. Adequate internal systems to record gifts exceeding established thresholds are in place.

3. Human rights

3.1 Workers are treated equally, with respect and dignity Substantive Requirements

3.1.1 No worker is subject to any form of psychological, physi- cal, sexual or verbal abuse, intimidation, or harassment.

3.1.2 All workers have equal opportunities for employment and promotion and are not discriminated against in the course of their employment, including in the context of hiring, compensation, advancement, disciplinary action, termination or retirement, or on the basis of gender, pregnancy, race, religion, age, disability, sexual orientation, nationality, HIV/AIDS status, political opin- ion, social group or ethnic origin.

3.1.3 The use of pregnancy testing, or other forms of health screening that might result in discrimination, are pro- hibited, except where required by law. In such cases, the results of such tests must be used solely for official purposes in accordance with the law.

3.1.4 Workers' personal data is processed lawfully and fairly, is kept secure against unauthorized processing, unlaw- ful or accidental destruction, loss or misuse.

Management System Requirements

1. Policies and processes are in place to prevent any form of psychological, physical, sexual or verbal abuse, intimidation, harassment, as well as any form of dis- crimination.
2. Workers are notified appropriately and regularly of the policies against discrimination, violence and harass- ment, as well as regarding the available reporting channels and procedures.
3. Workers, in particular line managers, supervisors and security personnel, are provided with information and training in accessible formats on the risks of discrim- ination, violence and harassment at work and the associated prevention and protection measures.

3.2 Work is conducted on a voluntary basis Substantive Requirements

3.2.1 Under no circumstance is forced laborused. This includes trafficked labor, prison labor, bonded labor or other forms of forced labor.

Nestlé Responsible Sourcing Core Requirements

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1. The use of violence, threats of violence, punishment, confinement, or any methods of intimidation, to coerce workers is strictly prohibited.
2. Workers have freedom of movement and are not confined to the workplace premises, including pro- vided housing.
3. No worker pays recruitment fees or related costs. If workers have paid any fees, these must be reimbursed by the employer.
4. Retention of workers' personal documents (e.g. pass-

port, identity card, birth certificate, work or residence permit or other travel documents) is prohibited. Where presentation of these documents is required by law, they are returned as soon as possible to the worker.

Management Systems Requirements

1. Policies and processes are in place to ensure that work- ers are entering into employment freely, that they are not prevented from leaving their job if they so wish and that they have freedom of movement.
2. Policies and processes are in place to identify, prevent and remediate any potential cases of recruitment feespaid by workers, such as through the screening and monitoring of recruitment agencies and labor brokers, pre-departure and post-arrival trainings of migrant workers, etc.
3. Relevant functions and employees (e.g. human resources) are trained on forced laborrisks and responsible recruitment practices to increase their participation in risk prevention and mitigation decisions and activities.

3.3 Terms of employment are fair and transparent Substantive Requirements

3.3.1 All workers are provided with employment contracts in a language they understand. If required, the terms of employment are explained verbally or pictorially to the worker.

3.3.2 Employment contracts include details of the working conditions, including nature of work, hours, overtime, pay, benefits, leave, and duration of the contract in a format and language that the workers understand.

Management Systems Requirements

1. Policies and processes are in place to ensure that all workers are provided with an employment contract that they understand and have freely agreed to.
2. Relevant functions and employees (e.g. human resources) are trained to ensure they understand and can implement the relevant policies and processes.
3. Up-to-daterecords are kept for permanent workers, containing the following information in respect of each worker: full name, sex, date of birth, and wages paid.

3.4 The minimum age of employment is respected, and young workers are protected

Substantive Requirements

3.4.1 No child aged 15 or below is employed. 2

1. Children aged 13 or over (or aged 12 or over in countries that have set the minimum age of employment at 14) can perform only light workwhere this is permitted by local law.
2. No child (defined as all persons under the age of 18) carries out hazardous workor other worst forms of child labor.

Management Systems Requirements

1. A policy is in place, which, at the minimum, stipulates the minimum age for all workers, the conditions under which young workers can be employed and the reme- diation process to follow in the event that a child laborcase is identified.
2. A process to verify the actual age of workers is in place and implemented (e.g. inclusion of minimum working age in the job advertisement, verifying the applicant's proof-of-age documents in their original form).
3. A process to remedy identified child labor cases is in place and implemented.
4. Relevant functions and employees are trained on child laborto increase their participation in risk prevention and mitigation decisions and activities.

3.5 Workers are free to form and/or join a trade union

and to bargain collectively Substantive Requirements

1. Workers can freely exercise their right to form or join a union of their choice, to seek representation and col- lectively bargain and can do so without fear of intimida- tion, discrimination, harassment or the need to obtain prior approvals, unless legally required.
2. Worker representatives are not discriminated against because of their role as worker representatives. They have reasonable access to workplaces to carry out their representative functions.
3. Where the right to freedom of association and collec- tive bargaining is restricted under local law, alternative forms of worker representation, association and bar- gaining are allowed.
4. Collective bargaining negotiations are entered into in good faith when this is requested by any legally recog- nized representative group of workers.

Management Systems Requirements

1. Policies and processes are in place to uphold workers' freedom of association and the effective recognition of the right to collectively bargain. These should ensure that workers' representatives can carry out their repre- sentative functions in the workplace.
2. Relevant functions and employees (e.g. human resources) are trained on freedom of association and collective bargaining.

3.6 Workers are provided with a healthy and safe work-

place environment Substantive Requirements

3.6.1 Workers are provided with a safe and healthy work- placeenvironment to prevent work-related accidents,

2 Some countries have chosen to set the minimum age of employment at 16. Other countries have set it at 14 as a transitional measure while they strengthen their education systems and economies. In these cases, the legal minimum age prevails.

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injuries and illnesses. The same applies to housing, when provided.

1. Workers are provided with personal protective equip- ment(PPE) as required, at no cost.
2. All workers and visitors who enter the site are informed about its inherent dangers and about the appropriate actions to take should a health and safety incident occur. There is clear and appropriate signage or infor- mation provided on how to evacuate in the case of
   an emergency.
3. Workers are provided with adequate access to free and safe water, sanitation and hygiene (WASH) at the workplace and any provided housing.

Management Systems Requirements

1. Occupational health and safety (OHS) policies and processes are in place to adequately identify, assess and effectively prevent work-related accidents, injuries and illnesses, and to minimize or eliminate, insofar as is reasonably practicable, the causes of all hazards in the workplace environment.
2. Where hazards remain, emergency and contingency plans for addressing residual risks are established and regularly tested through drills or other means.
3. A health and safety committee, comprised of a well-balanced group of management representatives and workers, is established and meets regularly to continuously improve OHS.
4. Workers are appropriately trained on OHS, including awareness of the risks and procedures related to their work, and the appropriate use of work-related tools and machinery, as well as PPE.
5. Employees, contractors and other third parties entering the work site are made aware of and trained on OHS to ensure they are empowered to avoid unsafe situations and respond rapidly to unexpected events.
6. Work-relatedaccidents, injuries and illnesses are analyzed, and corrective and preventive actions are implemented to prevent recurrence.
7. Processes are in place to assess, address and ensure access to free WASH in the workplace environment and any provided housing.

3.7 Working hours are legal and decent Substantive Requirements

3.7.1 Total weekly working hours, including overtime, may exceed local legal requirements or 60 hours, whichever is stricter, only in the following circumstances:

• it is allowed by local legislation;
• it is allowed by a collective bargaining agreement where applicable;
• appropriate safeguards are taken to protect workers' health and safety;
• the employer can demonstrate that exceptional cir- cumstances apply, such as unexpected production peaks, accidents or emergencies.

3.7.2 All overtime is voluntary and is compensated, at the minimum, in accordance with local laws.

3.7.3 Workers are entitled to at least 24 consecutive hours of rest in every seven-day period, and to take legally required annual leave. If workers are required to work on a rest day due to a genuine need for continuity of pro- duction or service, workers must receive an equivalent period of compensatory rest immediately following so as to ensure a minimum of two days' rest in every 14 days.

Management Systems Requirements

1. A written policy on working hours is in place and communicated to workers. It stipulates that overtime is voluntary.
2. Processes are in place to ensure that working hours comply with applicable laws, collective bargaining agreements (where applicable) and industry standards.
3. Relevant functions and employees (e.g. human resources) are trained to ensure they understand and can implement the relevant policies and processes.
4. A process to record and monitor working hours and overtime for all workers is in place and implemented. This includes recording and documenting workers' consent to perform overtime.

3.8 Workers' compensation is fair Substantive Requirements

3.8.1 Wages and benefits (including in-kind) paid for a stan- dard working week meet at least the legal or industry minimum standards, or the requirements set out in collective bargaining agreements (where applicable), whichever is higher. In any event, wages should always be sufficient to meet basic needs and to provide some discretionary income.

3.8.2 Payments in kind (e.g. payment of wages in goods or services instead of cash) as part of wages cannot exceed legal limits.

3.8.3 Other than legally mandated deductions, deductions from wages are made only with the written consent of the workers in a language they understand.

3.8.4 Wages are paid, on time, regularly and in full.

3.8.5 Where a worker is paid based on volume output, piece- rate, quotas or similar, the pay rate allows the worker to earn at least the legal or industry minimum standards, or the amount specified in collective bargaining agree- ments (where applicable), whichever is higher.

Management Systems Requirements

1. A written policy on compensation is in place and communicated to workers in a language and format they understand.
2. Processes are in place to ensure that compensation packages comply with applicable laws, collective bargaining agreements (where applicable) and industry standards, whichever is stricter.
3. A process to document workers compensation is in place and records are kept in order to demonstrate that workers are paid accurately; these include details of regular and overtime hours worked, benefits, incen- tives/bonuses and any agreed deduction.

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1. When wages are paid, workers are provided with wage slips documenting their regular and overtime hours worked, wages paid, and deductions; or documenting how their pay was calculated if not based on time.
2. Relevant functions and employees (e.g. human resources) are trained to ensure they understand and can implement the relevant policies and processes.

3.9 The land and resources of Indigenous peoples and local communities are respected

Substantive Requirements

1. The right to use the land is substantiated by applicable documents demonstrating ownership, lease, or use, or accepted customary rights.
2. The acquisition, leasing or disposal of land, as well as land use changes, are managed in compliance with applicable laws and respects human rights, particularly the rights (statutory and/or customary) to land and nat- ural resources of Indigenous peoplesand local commu- nities(IPLCs) that are impacted or potentially impacted.
3. Any activity that may affect IPLCs' rights, lands, resources, territories, livelihoods, food security, such as agricultural and forestry developments are subject to their Free, Prior and Informed Consent(FPIC). When FPIC has not been applied or respected, any harm caused must be resolved and remediated.
4. Where production or conservation uses impinge on their rights, lands, resources, territories, livelihoods, or food security, IPLCs are compensated or accom- modated through appropriate measures reflecting the negotiated outcomes of an FPICprocess.

Management Systems Requirements

1. A written policy is in place on respecting the land and resource rights of IPLCs, including zero tolerance for land grabbing and measures for the protection of envi- ronmental and human rights defenders(HRDs).
2. Processes are in place to effectively identify, assess and remedy violations of land rights. These should include processes for:

• conducting assessments prior to acquiring an interest in land or resources (e.g. new purchases, licenses, or concessions, or renewals or modifications of exist- ing interests);
• conducting a process to obtain FPICprior to any activ- ity, including acquisitions, that may affect IPLCs' rights,

land, resources, territories, livelihoods, and food security in a culturally appropriate manner, in accordance with the traditions, norms, and values of such peoples and communities, and through the representatives and institutions they choose;

• having an effective grievance mechanismthat covers land rights;
• protecting the security of IPLCs and their members acting as HRDs.

3.9.7 Relevant functions and employees (e.g. sustainability, community relations) are trained to ensure they under- stand and can implement the relevant policies and processes.

3.10 Workers and affected rightsholders have access to effective grievance mechanisms and processes

for remedy Substantive Requirements

1. A transparent and fair grievance mechanismis in place. It is open to all stakeholders that could be affected by the company's operations or business relationships, including workers and IPLCs.
2. The confidentiality of any complainant is guaranteed unless the complainant gives express permission to disclose his/her identity.
3. The grievance mechanismis communicated to direct suppliers, e.g. through inclusion in suppliers' contracts.
4. There is no abuse, threats, intimidation or reprisals against anyone who, in good faith, raises a concern, lodges a complaint or participates in an investigation, or whistle blows on activities in the company's oper- ations or supply chain. This may include workers and their representatives, IPLCs or HRDs.
5. Grievances are addressed in an effective, timely, trans- parent and equitable manner.

Management Systems Requirements

1. A written policy that states that workers or whis- tle-blowers who report grievances will be protected from retaliation is in place.
2. Processes are in place to record, monitor and track the progress and effectiveness of remediation actions.
3. Relevant functions and employees (e.g. human resources, grievance management) are provided with training so as to ensure that they understand and can implement the relevant policies and processes.

4. Environment

4.1 Forest, ecosystems and biodiversity Substantive Requirements

4.1.1 All materials and ingredients supplied to Nestlé comply with the deforestation-and conversion-free require- ments in the Origins section, and with all relevant applicable laws.

Management Systems Requirements

4.1.2 Documented procedures or processes are in place to ensure effective implementation of no-deforestation

and no-conversion requirements, as well as compliance with relevant laws.

4.2 Water and natural resources conservation Substantive Requirements

4.2.1 License(s) or permit(s) locally required to withdraw and use water are obtained, maintained and/or renewed.

4.2.2 Water withdrawals are monitored, and volumes allowed by license(s) or permit(s) are not exceeded.

4.2.3 Local water resources are used efficiently and negative

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