To our stakeholders:

I am pleased to confirm that Upfield reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

David Haines
Group CEO, Upfield

Principle 1 - Businesses should support and respect the protection of internationally proclaimed human rights:
• The principles within Upfield’s publicly-available Human Rights Statement are guided by the Universal Declaration of Human Rights: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf

Principle 2 - Make sure that they are not complicit in human rights abuses:
• Upfield’s Code of Conduct covers our responsibilities to our employees, consumers and communities and includes our commitment to uphold human rights within our business and throughout our supply chain: https://upfield.com/wp-content/uploads/2021/04/UPF_Code-of-Conduct_Final-040921_EN.pdf
• We require that all new suppliers and other business partners sign our Business Partner Code of Conduct (BPCC), which includes a set of human rights commitments, covering child labour, forced labour, wages and benefits, working hours, working conditions, freedom of association and collective bargaining, land rights, health and safety, harassment and abuse, diversity and inclusion, and our grievance process. As per our BPCC, “we use a risk analysis process to identify and prevent human rights breaches to people in our business and supply chain.” Our BPCC requires that business partners adopt equivalent commitments to Upfield’s Human Rights Statement, which is guided by the Universal Declaration of Human Rights: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Our Responsible Sourcing Policy also requires all partner businesses to respect internationally accepted human rights standards: https://upfield.com/wp-content/uploads/2021/02/Our-Responsible-Sourcing-Policy.pdf

Women and Gender Equality:
• Our Diversity, Equity and Inclusion Policy outlines our commitments to remove discriminatory barriers to recruitment, promotion and advancement. It also outlines our ambition to achieve a 50/50 gender balance by 2030, as well as a parental leave policy that applies equally to all parents, regardless of gender: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf
• Our Business Partner Code of Conduct states that we expect business partners to encourage a diverse and inclusive workforce and not to discriminate based on gender: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf

Children’s Rights:
• As per our Business Partner Code of Conduct, “Business partners must not use or permit any unlawful form of employment or exploitation of children. No individuals are hired under the age of 16 and not lower than the end of compulsory education, or under the legal age of work in accordance with local laws and regulations”: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf

Indigenous Peoples:
• As per our Human Rights Statement, “We engage with communities on human rights matters that are important to them such as land rights, access to water and health. We also engage with people in those communities, including indigenous peoples as well as other vulnerable and disadvantaged groups”: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf
• As per our Business Partner Code of Conduct, “We expect our business partners to respect the land rights of local farmers, communities and indigenous peoples. Business partners will have all the relevant documents to prove their right (legal title or legal lease) to operate on the land their operations are located on and should not have any on-going legal processes or events indicating that the ownership or lease right to the land is contested”: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• As per our Responsible Sourcing Policy, “Land rights of communities, including indigenous people, should be protected and promoted at all times”: https://upfield.com/wp-content/uploads/2021/02/Our-Responsible-Sourcing-Policy.pdf
• As per our Sustainable Palm Oil Sourcing Policy, we require the application of the principles of Free, Prior and Informed Consent (FPIC) to ensure the protection and promotion of the rights of indigenous peoples and vulnerable communities: https://upfield.com/wp-content/uploads/2021/01/Our-sustainable-palm-oil-sourcing-policy.pdf

Persons with Disabilities:
• Upfield’s Human Rights Statement commits the company to maintain workplaces that are free from discrimination or harassment based on disability: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf
• Our Business Partner Code of Conduct requires the same of suppliers: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Finally, our Diversity, Equity and Inclusion Policy outlines our commitment to remove discriminatory barriers to recruitment, promotion and advancement on the basis of disability: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf

Human Trafficking:
• As per our Human Rights Statement, Upfield prohibits the use of any form of human trafficking: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf

Upfield undertakes the following actions to implement our human rights policies and commitments, to address human rights risks and to respond to human rights violations:

Grievance mechanisms:
• Upfield requires all new business partners and direct suppliers to sign our Business Partner Code of Conduct (BPCC). Our BPCC includes a requirement for suppliers to include a robust, anonymous grievance and complaints process for their employees: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Upfield operates an easy and confidential “Speak Up” service for all company Associates and our external business partners. This facility can be used to report any ethical or legal concerns related to the way we do business, including human rights risks/concerns: https://upfield.com/speak-up/
• Within our palm oil supply chain, we improve human rights conditions by ensuring that 100% of our palm oil is physically certified sustainable palm (RSPO certification) which ensures mandatory minimum standards on human rights for our suppliers: https://upfield.com/purpose/better-planet/responsible-sourcing/; https://rspo.org/resources/certification/rspo-principles-criteria-certification
• Within our Palm Oil Policy, we also ensure a grievance process whereby we commit to both internal and external investigation of supplier organisations. Our grievance process includes supporting non-compliant companies to develop an action plan to avoid future non-compliances: https://upfield.com/wp-content/uploads/2021/01/Our-sustainable-palm-oil-sourcing-policy.pdf
• Finally, we ensure accountability in our palm oil supply chain by publishing and updating our Palm Oil Grievance Tracker on our Responsible Sourcing page, including any official grievances pertaining to human rights risks: https://upfield.com/purpose/better-planet/responsible-sourcing/

Training of employees on human rights:
• Upfield implements mandatory training on our Code of Conduct, which covers our commitments to maintain human rights and references our Human Rights Statement: https://upfield.com/wp-content/uploads/2021/04/UPF_Code-of-Conduct_Final-040921_EN.pdf

Consultation with stakeholders and affected parties:
• Within our palm oil supply chain, we improve human rights conditions by ensuring that 100% of our palm oil is physically certified sustainable palm (RSPO certification) which requires communication and consultation with affected parties: https://upfield.com/purpose/better-planet/responsible-sourcing/; https://rspo.org/resources/certification/rspo-principles-criteria-certification

Allocation of responsibilities for the protection of Human Rights within the company:
• As per our Human Rights Statement, “The Human Rights statement is overseen by Upfield’s Executive Committee, including the Chief Executive Officer”: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf

Human resource policies and procedures supporting Human Rights:
• Upfield’s Diversity, Equity and Inclusion Policy commits the company to protect human rights by putting procedures in place to reduce discrimination when hiring. For example, all job adverts globally are screened by a bias-checker for gender, and a “balanced slate” is used for all job applications, whereby half of the shortlisted applicants for each advertised role are women: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf

Specific progress made in the area of Human Rights in the past reporting period:
• In the past reporting period, Upfield joined the Consumer Goods Forum’s Human Rights Coalition, working with the Coalition and its membership to share best practice and to further advance the protection of human rights within our own operations and our wider supply chain: https://www.theconsumergoodsforum.com/news_updates/human-rights-coalition-working-to-end-forced-labour-welcomes-two-new-members-jeronimo-martins-and-upfield/
• We also launched our ESG Strategy - “A Better Plant-Based Future” – which further commits us to our existing goal of 100% responsibly sourced ingredients. This ESG Strategy is subject to annual reporting and tracking of progress: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Information about how the company deals with incidents of Human Rights violations:
• As per our Palm Oil Policy, Upfield commits responds to grievances (including human rights grievances) with both internal and external investigation of supplier organisations, and supports non-compliant companies to develop and action plan to avoid future non-compliances: https://upfield.com/wp-content/uploads/2021/01/Our-sustainable-palm-oil-sourcing-policy.pdf

Investigations, legal cases, rulings, fines and other relevant events related to Human Rights:
• Upfield’s Palm Oil Grievance Tracker details all official grievances related to our palm oil supply chain, and can be found on the Responsible Sourcing page of our website: https://upfield.com/purpose/better-planet/responsible-sourcing/

Periodic review of results by senior management:
• As per our Human Rights Statement, “we […] audit the implementation of our Human Rights Statement to ensure compliance”: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf
• We also report annually to the Global Reporting Initiative (GRI), which includes reporting on our labour rights progress. Our GRI submission is signed off at Board level.

External audits of Human Rights performance:
• Upfield is rolling out Sedex Members Ethical Trading Audit (SMETA) to its factories. This includes assessment of human rights related questions. Last year there were no reported human rights findings during the audits.

Upfield’s stance on Human Rights and Labour Rights aligns with the ILO’s Declaration on Fundamental Principles
and Rights at Work, as mentioned in our Human Rights Statement: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf

Principle 3 - Businesses should uphold freedom of association & effective recognition of the right to collective bargaining:
• We require that all new suppliers and other business partners sign our Business Partner Code of Conduct (BPCC). As per our BPCC, “Freedom of association and collective bargaining: We expect business partners to respect the right of employees to join, or not join, or form a labour union in accordance with the law and without fear of reprisal or intimidation”: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• As per our Responsible Sourcing Policy, “all workers are free to exercise their right to form and/or join trade unions, and to bargain collectively. Workers who choose to form or join trade unions must not be discriminated against or be intimidated with fear of job loss for joining such organizations”: https://upfield.com/wp-content/uploads/2021/02/Our-Responsible-Sourcing-Policy.pdf
• As per our Human Rights Statement, “Upfield respects our Associates right to join or form a labour union without fear of reprisal, intimidation or harassment. Where Associates are represented by a legally recognised union, we are committed to establishing a constructive dialogue with their freely chosen representatives”: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf

Principle 4 - The elimination of all forms of forced and compulsory labour:
• Our Human Rights Statement specifically mentions that “Upfield prohibits the use of all forms of forced labour, including prison labour, indentured labour, bonded labour, military labour, modern forms of slavery and any form of human trafficking”: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf
• Our BPCC requires that “Business partners must not use any form of bonded, forced, or involuntary labour. All work must be voluntary, and all workers must have the right to terminate their employment at any time”: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Our Responsible Sourcing Policy states that “. Employment is voluntary, and workers are free to leave work or terminate their employment upon reasonable notice. Partners shall not use any prison, slave, bonded, forced or indentured labor”: https://upfield.com/wp-content/uploads/2021/02/Our-Responsible-Sourcing-Policy.pdf

Principle 5 - The effective abolition of child labour:
• As per our Business Partner Code of Conduct, “Business partners must not use or permit any unlawful form of employment or exploitation of children. No individuals are hired under the age of 16 and not lower than the end of compulsory education, or under the legal age of work in accordance with local laws and regulations”: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf

Principle 6 - Eliminate discrimination in respect of employment and occupation:
• As per our Business Partner Code of Conduct, “We expect our business partners to treat employees fairly, encourage a diverse and inclusive workforce and not discriminate on factors such as race, gender, colour, caste, religion, ethnicity, sexual orientation, disability, age marital status, health, pregnancy, union membership, political affiliation, or national origin”: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Upfield’s Diversity, Equity and Inclusion Policy outlines our commitment to remove bias from the recruitment process, our use of a “balanced slate” process for all job applications and our ambition to reach a 50/50 gender balance by 2030: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf

Migrant Workers:
• Upfield’s Responsible Sourcing Policy applies to all workers, including migrant workers. It mentions that “All workers should have the appropriate paperwork to prove they meet the minimum legal age and eligibility criteria to be employed in their respective countries”: https://upfield.com/wp-content/uploads/2021/02/Our-Responsible-Sourcing-Policy.pdf
• In particular, our Sustainable Palm Oil Sourcing Policy stipulates that particular attention should be paid to protecting migrant workers and other vulnerable workers: https://upfield.com/wp-content/uploads/2021/01/Our-sustainable-palm-oil-sourcing-policy.pdf

Grievance mechanisms:
• Upfield requires all new business partners and direct suppliers to sign our Business Partner Code of Conduct (BPCC). Our BPCC includes a requirement for suppliers to include a robust, anonymous grievance and complaints process for their employees: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Upfield operates an easy and confidential “Speak Up” service for all company Associates and our external business partners. This facility can be used to report any ethical or legal concerns related to the way we do business, including labour rights risks/concerns: https://upfield.com/speak-up/
• Within our palm oil supply chain, we bolster labour rights conditions by ensuring that 100% of our palm oil is physically certified sustainable palm (RSPO certification) which ensures mandatory minimum standards on human rights for our suppliers: https://upfield.com/purpose/better-planet/responsible-sourcing/; https://rspo.org/resources/certification/rspo-principles-criteria-certification
• Within our Sustainable Palm Oil Sourcing Policy, we also ensure a grievance process whereby we commit to both internal and external investigation of supplier organisations. Our grievance process includes supporting non-compliant companies to develop an action plan to avoid future non-compliances: https://upfield.com/wp-content/uploads/2021/01/Our-sustainable-palm-oil-sourcing-policy.pdf
• Finally, we ensure accountability in our palm oil supply chain by publishing and updating our Palm Oil Grievance Tracker on our Responsible Sourcing page, including any official grievances pertaining to labour rights risks: https://upfield.com/purpose/better-planet/responsible-sourcing/

Training for employees on labour rights and policies:
• Upfield implements mandatory training on our Code of Conduct, which covers our commitments to maintain labour rights and references our Human Rights Statement (which includes our commitments to protecting labour rights): https://upfield.com/wp-content/uploads/2021/04/UPF_Code-of-Conduct_Final-040921_EN.pdf

How the health and safety of all employees is ensured:
• We have comprehensive incident prevention measures in place, including job hazard analysis, process hazard analysis, HAZOP studies, risk assessment for locations, tasks and auxiliary equipment, machine safety assessments, ATEX assessments and audits at all factories. Risk assessments are required for all working areas and tasks, and are reviewed regularly, when there are incidents and when there are changes to processes. The areas and tasks that pose higher risks undergo additional, more detailed, assessments.

Describe how the company prevents discrimination of all kinds and ensures comparable pay for comparable work:
• As per our Diversity, Equity and Inclusion Policy, “we will maintain gender pay balance through equal promotion and salary review practices, and through establishing and maintaining competitive salary bands across the company.” Our ambition to reach a 50/50 gender balance across the whole company includes our production facilities. On top of this, our interim target is a 50/50 gender balance for manager level roles and above by 2025 also supports our stance on equal pay for equal work. As per the Policy, we track any gender disparities in pay in order to close the gap: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf

Consultation with employees and other stakeholders:
• As per our Diversity, Equity and Inclusion policy, we measure inclusion throughout our global workforce with our Inclusion Index. This is a company-wide survey collecting insights about inclusion, diversity and non-discrimination: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf
• In terms of external stakeholder consultation, Upfield is a member of the UNGC’s Target Gender Equality programme, to learn, measure and improve our non-discrimination and equality of opportunity practices: https://www.unglobalcompact.org/what-is-gc/participants/143984-Upfield-Group

Allocation of responsibilities for the protection of labour rights within your organization:
• Our Human Rights Statement covers our stance and commitments on all pertinent labour rights issues. As per the Statement, “The Human Rights statement is overseen by Upfield’s Executive Committee, including the Chief Executive Officer”: https://upfield.com/wp-content/uploads/2019/05/Human-Rights-statement.pdf

Human resource policies and procedures supporting the Labour principles:
• As per our Diversity, Equity and Inclusion Policy, all job adverts globally are screened by a bias-checker for gender, and a “balanced slate” is used for all job applications, whereby half of the shortlisted applicants for each advertised role are women: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf
• Additionally, our target to achieve a 50/50 gender balance by 2030, and our interim target to achieve a 50/50 gender balance for management roles and above by 2025 are bolstered by fair hiring, promotion and development practices: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf

Participation in international framework agreements and other agreements with labour unions:
• We have a strong commitment to continual, and transparent dialogue with our Associates. All of our employed factory workers are covered by collective labour agreements.

Demographics of management and employees by diversity factors (e.g. gender, ethnicity, age, etc.):
• Within our Diversity, Equity and Inclusion Policy, we disclose that 40% of manager level and above roles were held by women as of the end of 2020: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf
• We measure inclusion globally within our company using our Inclusion Index – a company-wide survey collecting insights about inclusion, diversity and non-discrimination. As per our DE&I Policy, “Disclosure of personal demographics is voluntary, anonymous and in accordance with local cultures and sensitivities. The index measures how different groups experience life at Upfield, and how inclusive we really are. Using this data, we commit to work to improve our corporate practices regarding diversity, equity and inclusion”: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf

Describe how the company deals with incidents of violations of the Global Compact Labour principles:
• Upfield requires all new business partners and direct suppliers to sign our Business Partner Code of Conduct (BPCC). Our BPCC includes a requirement for suppliers to include a robust, anonymous grievance and complaints process for their employees: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Upfield operates an easy and confidential “Speak Up” service for all company Associates and our external business partners. This facility can be used to report any ethical or legal concerns related to the way we do business, including labour rights risks/concerns and any allegations of discrimination: https://upfield.com/speak-up/
• We ensure accountability in our palm oil supply chain by publishing and updating our Palm Oil Grievance Tracker on our Responsible Sourcing page, including any official grievances pertaining to labour rights risks: https://upfield.com/purpose/better-planet/responsible-sourcing/

Investigations, legal cases, rulings, fines and other relevant events related to the Global Compact Labour principles:
• Our Palm Oil Grievance Tracker is available via the Responsible Sourcing page on our website, which is updated regularly with any official grievances around non-compliance to our policies, including our commitments towards labour rights: https://upfield.com/purpose/better-planet/responsible-sourcing/
• We report to the Global Reporting Index (GRI), which involves all necessary disclosures of incidents related to labour rights.

Periodic review of results by senior management:
• We report annually to the Global Reporting Initiative (GRI), which includes reporting on our labour rights progress. Our GRI submission is signed off at Board level.

Specific progress made in the area of Labour during the last reporting period:
• Upfield launched its Diversity, Equity and Inclusion Policy, which includes new corporate commitments on achieving gender balance, measuring inclusion, bolstering equitable parental leave policies and implementing recruitment processes with a “balanced slate” whereby half of the shortlisted candidates for each role are women: https://upfield.com/wp-content/uploads/2022/01/Diversity-Equity-and-Inclusion-Policy-Final.pdf

External audits of Labour Rights performance:
• Upfield is rolling out Sedex Members Ethical Trading Audit (SMETA) to its factories. This includes assessment of labour rights related questions. Last year there were no reported human rights findings during the audits. We also assess external suppliers for social and environmental impact, with many also being subject to SMETA.

Principle 7 - Businesses should support a precautionary approach to environmental challenges:
• Upfield undertook a formal materiality assessment, covering our key environmental, social and governance risks. This led to a prioritisation of risks which formed the basis of our ESG Strategy. Both the materiality assessment and our ESG Strategy are publicly available on our Purpose page: https://upfield.com/purpose/

Principle 8 - Undertake initiatives to promote greater environmental responsibility:
• Upfield’s ESG Strategy commits the company to a range of different goals on environmental responsibility, including (1) “better than net zero” by 2050 (all 3 scopes), with a 2030 interim target of a 25% reduction in total GHG footprint including net zero in scopes 1 and 2, (2) introduce on-pack carbon labels using ISO-compliant LCA data to 500 million packs by 2025, (3) reduce waste by 50% by 2030, with zero waste to landfill, and (4) eliminate 95% of plastic packaging by 2030: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Principle 9 - Encourage the development and diffusion of environmentally friendly technologies:
• Upfield’s target to eliminate 95% of plastic packaging by 2030 means a transition to plastic-free, environmentally friendly packaging production technologies. Our Plastic Free & Better Packaging Policy also ensures that any alternative packaging solutions we choose will have a lower climate impact : https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf
• Upfield’s target to eliminate dairy within our supply chains by 2025 requires R&D into 100% plant-based options, with the environmental impacts that follow: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Climate Change:
• As above, Upfield has a target of better than net zero” by 2050 (all 3 scopes), with a 2030 interim target of a 25% reduction in total GHG footprint including net zero in scopes 1 and 2: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf
• Our target to introduce carbon labels based on ISO-compliant LCA data onto 500 million packs by 2025 gives consumers the information they need to make informed environmental consumption and purchasing decisions: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Water Sustainability:
• As part of our environmental analyses, we study the water use associated with our products. Our LCA data finds that, when studied across 21 European and North American markets, on average, our margarines and spreads require half the amount of water use than their dairy counterparts. As such, we provide less water-intensive products for consumers: https://upfield.com/purpose/better-planet/climate-action/

Energy:
• Upfield’s climate targets (above) mean the requirement to reduce the carbon footprint associated with the energy we use. For instance, our interim 2030 climate target includes a goal of net zero for scopes 1 and 2, which requires energy transition in our own sites: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Biodiversity:
• Upfield implemented a “cover crops” programme via our Country Crock brand in the USA, supporting farmers to introduce cover crops into their agricultural practices. This was done in partnership with No-Till on the Plains, in order to improve soil health, make better use of water, and reduce emissions: https://www.countrycrock.com/our-story/cover-crops

Environmental Stewardship:
• Upfield’s has policies governing the sustainable sourcing of palm, soy, shea and coconut, ensuring responsible use of resources and environmental protection across the specific issues that impact those commodities.
• Palm: https://upfield.com/wp-content/uploads/2021/01/Our-sustainable-palm-oil-sourcing-policy.pdf;
• Soy: https://upfield.com/wp-content/uploads/2021/01/Our-position-on-soy-sourcing.pdf;
• Shea: https://upfield.com/wp-content/uploads/2021/01/Our-statement-on-responsible-sourcing-of-Shea.pdf
• Coconut: https://upfield.com/wp-content/uploads/2022/02/Upfield-Coconut-Policy-FINAL-V1.0-SEPT.pdf

Green Industry:
• Upfield’s margarines and spreads are associated with 70% lower GHG emissions, 2/3 less land occupation and half of the water use of their dairy counterparts. We provide a solution for consumers to reduce their food-based climate impact by switching from dairy to our products: https://upfield.com/purpose/better-planet/climate-action/

Awareness raising or training of employees on environmental protection:
• Upfield organises company-wide panel discussions and town hall events which cover our ESG Strategy as a topic – this includes our commitment towards environmental protection. We also encourage all employees to align their professional goals with our ESG Strategy, meaning that employees are incentivised to improve our ESG performance.

Initiatives and programmes to reduce waste materials and consumption of resources:
• Upfield’s Cover Crops programme, implemented via our Country Crock brand, aims to reduce the carbon impact of the crops we use in our products by providing farmers with the tools to introduce cover crops to soy production: https://www.countrycrock.com/our-story/cover-crops
• Upfield is investing into our new Upfield Food Science Centre in Wageningen, Netherlands. This new building allows re-use of rainwater for irrigation and sanitary installation, reduced energy use, with solar panels and ground storage of energy allowing for 70% heat recovery, and other energy-reduction initiatives like LED lighting throughout: https://upfield.com/wp-content/uploads/2021/06/The-Upfield-Food-Science-Centre_Breeam-Case-Study.pdf

Activities aimed at improving the energy efficiency of products, services and processes:
• Upfield’s GHG targets of “better than net zero” by 2050 (all 3 scopes) and our interim target of a 25% reduction in overall GHGs, including net zero in scopes 1 and 2 by 2030 require an energy transition in our Upfield-owned sites, including both our offices and our production facilities: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Development and diffusion of environmentally friendly technologies:
• As per our Plastic Free & Better Packaging Policy, Upfield commits to o innovate, test, trial and launch new packaging solutions, that are plastic free and better for the planet: https://upfield.com/wp-content/uploads/2021/09/Plastic-Free-Better-Packaging-Policy-Position-1.pdf
• During the reporting window, Upfield also entered into a strategic partnership with OGGS, a leading producer of plant-based egg alternatives, whose plant-based egg alternatives produce 70% lower GHG emissions than chicken eggs. The partnership champions environmentally friendly innovation, by expediting the growth of the already leading egg-alternative products, by leveraging Upfield’s global distribution network and food service channel: https://upfield.com/press/upfield-enters-into-strategic-partnership-with-oggs-a-leading-producer-of-plant-based-egg-alternatives-2/

Raise awareness among suppliers by asking for the environmental footprint of products or services:
• Upfield conducts ISO-compliant LCAs on our products, capturing all environmental impacts from “cradle to grave,” including a focus on the ingredients we source to make our products: https://upfield.com/purpose/better-planet/climate-action/

Allocation of responsibilities for environmental protection within the company:
• Upfield’s ESG Strategy includes our aforementioned environmental commitments around carbon emissions, waste and responsible sourcing. This Strategy is signed off at Board level: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Information about how the company deals with incidents:
• Upfield requires all new business partners and direct suppliers to sign our Business Partner Code of Conduct (BPCC). Our BPCC includes a requirement for suppliers to include a robust, anonymous grievance and complaints process for their employees: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• Upfield operates an easy and confidential “Speak Up” service for all company Associates and our external business partners. This facility can be used to report any ethical or legal concerns related to the way we do business, including environmental risks/concerns: https://upfield.com/speak-up/
• Within our palm oil supply chain, we improve human rights conditions by ensuring that 100% of our palm oil is physically certified sustainable palm (RSPO certification) which ensures mandatory minimum standards on environmental protection for our suppliers (e.g. including “No Deforestation, No Development on Peat, No Exploitation” policies): https://upfield.com/purpose/better-planet/responsible-sourcing/; https://rspo.org/resources/certification/rspo-principles-criteria-certification
• Within our Palm Oil Policy, we also ensure a grievance process whereby we commit to both internal and external investigation of supplier organisations. Our grievance process includes supporting non-compliant companies to develop an action plan to avoid future non-compliances: https://upfield.com/wp-content/uploads/2021/01/Our-sustainable-palm-oil-sourcing-policy.pdf

Investigations, legal cases, rulings, fines and other relevant events related to the Global Compact environmental principles:
• Our Palm Oil Grievance Tracker lists official grievances, including grievances centred around our environmental commitments. This is updated regularly and hosted on our Responsible Sourcing webpage: https://upfield.com/purpose/better-planet/responsible-sourcing/
• We also report annually to the Global Reporting Initiative (GRI). Other relevant grievances are listed in our GRI submission.

Specific progress made in the area of the environmental protection during the last reporting period:
• Upfield’s ESG Strategy was signed off and launched during the reporting period, formalising our various climate, waste and responsible sourcing targets: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf

Periodic review of results by senior management:
• We report annually to the Global Reporting Initiative (GRI), which includes reporting on our environmental progress. Our GRI submission is signed off at Board level.

External audits of environmental performance:
• As per our ESG Strategy, “We use a variety of Sedex tools; sustainability certification standards like RSPO; and our own Supplier Code of Conduct, to manage and remove risk within our supply chains”: https://upfield.com/wp-content/uploads/2021/09/Upfield_ESG_report.pdf
• We also use BREEAM certification, for example in the development of our Upfield Food Science Centre in Wageningen, Netherlands: https://upfield.com/wp-content/uploads/2021/06/The-Upfield-Food-Science-Centre_Breeam-Case-Study.pdf

Principle 10 - Businesses should work against all forms of corruption, including extortion and bribery:
• In 2021, Upfield concluded a risk assessment conducted by an independent organisation. There were no significant findings that required attention.
• Upfield’s Code of Conduct specifically states Upfield’s “zero-tolerance approach to bribery, corruption, money laundering and insider trading”: https://upfield.com/wp-content/uploads/2021/04/UPF_Code-of-Conduct_Final-040921_EN.pdf
• The Code of Conduct references Upfield’s Anti-Bribery and Corruption Policy, which includes guidance on suspicious behaviour, and requires employees to report suspicious behaviour through Upfield’s anonymised “Speak Up” tool for grievances: https://upfield.com/speak-up/
• Our policy requires all new contracts with suppliers to include signing Upfield’s Business Partner Code of Conduct, which states “We expect our business partners to have a zero-tolerance policy to bribery corruption or any type of fraudulent behavior, in any form, everywhere they operate. Business shall be conducted without asking for, engaging in, making, offering, promising or authorizing any bribes”: https://upfield.com/wp-content/uploads/2021/09/Business-Partner-Code-of-Conduct-Upfield.pdf
• In our standard contract template, Upfield has clear wording on compliance with anti-bribery laws and regulations.

Suggestion box, call center or grievance mechanisms:
• Upfield operates an easy and confidential “Speak Up” service for all company Associates and our external business partners. This facility can be used to report any ethical or legal concerns related to the way we do business, including bribery and corruption risks/concerns: https://upfield.com/speak-up/

Awareness raising or training of employees about the company's policies regarding anti-corruption and extortion (e.g. mailings, internet, internal communication, etc.) :
• Upfield issues a company-wide mandatory training on our bribery and corruption, and also requires all employees to complete a mandatory training session on our Code of Conduct, which includes a section against bribery and corruption.

Allocation of responsibilities for anti-corruption within the company:
• Responsibility for anti-corruption lies with Upfield’s Chief Compliance Officer.

Participation in industry initiative or other collective action on anti-corruption:
• Within our palm oil supply chain, we tackle corruption by ensuring that 100% of our palm oil is physically certified sustainable palm (using RSPO certification) which ensures mandatory minimum standards on corruption, requiring RSPO members to include anti-corruption statements in their policies: https://upfield.com/purpose/better-planet/responsible-sourcing/; https://rspo.org/resources/certification/rspo-principles-criteria-certification

Information about how the company deals with incidents of corruption:
• Upfield’s Anti-Bribery and Corruption Policy states that non-compliance is considered as “a serious violation, and may result in disciplinary action, up to and including termination, as well as civil or criminal charges.”

Internal audits to ensure consistency with anti-corruption commitment, including periodic review by senior management:
• Upfield conducts regular reviews of alleged grievances, including any grievances that may be related to bribery and corruption. These reviews are attended by members of Upfield’s Executive Committee.

Investigations, legal cases, rulings, fines and other relevant events related to corruption and bribery:
• In 2021, we concluded a risk assessment conducted by an independent organisation. There were no significant findings that required attention.

Specific progress made in the area of anti-corruption during the last reporting period:
• Within the reporting period, all relevant employees were required to complete our Code of Conduct training and our anti bribery and competition law training.