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We employ more than 20,000 people, operate more than 40 manufacturing facilities and market our products in more than 80 countries. As a result, we have a big impact on — and responsibility to — the world.

We are committed to being a responsible corporate citizen in many ways. Some examples are:

  • Ethical business conduct;
  • Environmental impact reductions;
  • Animal welfare;
  • Product safety, quality and nutrition;
  • Employee safety, diversity and professional development; and
  • Community support and philanthropy.

Every year we publish a global impact report to share our accomplishments and goals in these areas and others.

OUR APPROACH To Issues That Matter

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Animal Stewardship Policy
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Hormel Foods is dedicated to doing things the right way in every aspect of our business. That includes our animal stewardship practices. To maintain our high standards, we have developed the following principles to guide our animal care and handling procedures.

  • All farms will provide a balanced and nutritious diet, plus water.
  • A safe and humane environment will be provided for every animal throughout its life, including minimization of stress, management of social needs and control of environmental conditions.
  • Every facility will be properly maintained with the animals’ well-being in mind, including appropriate facilities and space, and the utilization of compassionate, stress-reducing techniques during handling.
  • Animals will be provided with appropriate preventive and, if necessary, medical care, including veterinary oversight and the identification of prompt treatment of sick animals. When medically necessary, we use antibiotics responsibly.
  • We will follow clearly documented humane procedures in the event an animal needs to be euthanized.

We have developed industry-leading standards in conjunction with animal care experts, including renowned authorities on humane animal husbandry. These veterinarians and animal experts help us to create a blueprint that ensures every animal is raised in a healthy environment and treated with care, respect and compassion throughout its entire life. Our network of family farm suppliers understands and shares these values.

Hormel Foods has a zero-tolerance policy toward the mistreatment of animals through abuse or neglect. We have strict requirements related to animal care, which are overseen by veterinarians, third-party experts and a team of animal welfare professionals at Hormel Foods.

In addition to these principles, we have more requirements for hogs and turkeys. Our Applegate (Bridgewater, N.J.) subsidiary has additional animal care requirements as well. Applegate works with third-party certifiers like Global Animal Partnership® and Certified Humane® to ensure animals are raised and handled in ways that honor the Five Freedoms of Animal Welfare. Applegate requires its suppliers to meet third-party certified animal welfare standards.

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Animal Welfare Quality Assurance Requirements
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Our animal welfare quality assurance requirements include:

  • All individuals who transport hogs to Hormel Foods must have the National Pork Board’s Transport Quality Assurance (TQA) certification. The training materials for this program cover the responsible way to treat and handle animals during loading, transportation and delivery. Handlers are taught to recognize the amount of space needed around each hog and points of balance to aid in hog movement. Achieving TQA certification requires attendance at an educational and training session, and a score of 90% or above on a written exam.
  • All sites where a producer raises hogs supplied to Hormel Foods must achieve Site Status as defined by the National Pork Board’s PQA Plus program. This is attained through an on-farm assessment that evaluates welfare and well-being principles.
  • All team members at our company-owned hog farm are required to comply with qualifications outlined in our quality management system, which includes standard operating procedures, a personal pledge of proper conduct and certifications in the National Pork Board’s PQA Plus and TQA programs. Team members cannot be promoted until they have undergone appropriate training for the new positions and until their managers have attested to their ability to work with animals in a new capacity.
  • All producers who supply hogs to Hormel Foods, and the employees of those producers, must be certified in the National Pork Board’s PQA Plus program. To achieve certification, producers must attend an educational and training session taught by a PQA Plus adviser – a veterinarian, extension professional or adult agricultural educator. The class content focuses on food safety, animal well-being, herd health, and medication decision making, administration and records management.
  • All producers who supply hogs to Hormel Foods must also adhere to the Hormel Foods Farm Animal Care and Treatment Specifications (FACTS) program. In addition to documentation and animal/facility observations, key components of the program include third-party audits and corrective actions for noncompliance.
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Beef Policy
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South American Beef Sourcing

We source beef from suppliers who share these commitments and follow the principles and criteria of the Global Roundtable for Sustainable Beef (GRSB). The GRSB is a multi-stakeholder group whose mission is to advance continuous improvement in global beef value chain sustainability. The GRSB envisions a world in which all aspects of the beef value chain are environmentally sound, socially responsible and economically viable.

To ensure compliance with our requirements, our beef suppliers have monitoring systems in place for farms supplying cattle, which use satellite images and geo-referenced maps of farms, deforestation data and information from public agencies regarding embargoed areas and human rights. We also require and review independent audits of the environmental monitoring systems of our suppliers.

If a supplier is found to be in violation of our sourcing principles, Hormel Foods will require the supplier to implement corrective actions. If reasonable/appropriate corrective actions cannot be agreed to, Hormel Foods will suspend or discontinue purchases from the supplier.

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Broiler Chicken Commitment
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Hormel Foods has made a commitment to support additional standards for broiler chickens in our Applegate business, working with the industry to achieve these standards by 2024. With Applegate leading the way, Hormel Foods will also work with suppliers, peers and other stakeholders to encourage efforts to achieve the following standards for all broiler chickens in our supply chain by 2024:

  • Offer improved environments in line with the Global Animal Partnership (GAP) standards for better lighting, litter quality and other enrichments.
  • Provide birds with enough space to perform natural behaviors, including stocking densities that provide the best outcomes, in line with GAP.
  • Develop systems to process broiler chickens in a manner that avoids pre-process handling, and instead uses a multi-step controlled atmospheric processing system.
  • Require supplier participation in third-party auditing to track progress.

And by 2028:

  • Transition to breeds of chicken recognized as having improved welfare outcomes, including better overall health, in line with GAP.

Achieving these additional standards for broiler chickens is a complex undertaking that will require industrywide collaboration in order to succeed. We are committed to collaborating across our supply chain to further animal welfare while preserving consumer access to quality, accessible food.

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Cage-Free Eggs
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We understand that consumers are increasingly requesting cage-free eggs and are proud of the fact that 100 percent of the shell and liquid eggs we purchase for use in the manufacturing of Hormel Foods branded products globally are cage free.

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California Proposition 12
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Updated: 05/11/23

Hormel Foods has been ready for Prop 12 since January 2022 and is prepared to serve customers and consumers in the state of California.

Hormel Foods has confirmed that it faces no risk of material losses from compliance with Proposition 12 While this measure adds complexity to our supply chain, including costs associated with compliance, California is an important market for Hormel Foods, and we will continue to meet the needs of our consumers and customers throughout these states.

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Environmental & Energy Policy Statement
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Updated: 06/18/24

Hormel Foods and its subsidiaries are committed to operating all facilities in accordance with company environmental and energy policies and all applicable legal requirements. The organization commits to the continuous improvement of our environmental and energy programs, including the wise stewardship of natural resources and the documentation, implementation and maintenance of formal Environmental and Energy Management Systems.

We are specifically committed to:

  • The conservation of natural resources through careful planning and efficient use of water, energy and raw materials;
  • The minimization of waste through source reduction, reuse and recycling;
  • The handling and disposal of waste through safe and environmentally sustainable methods;
  • The prevention of pollution, including greenhouse gases, and the unintended release of substances that could cause harm to air, water or land;
  • Conducting regular environmental assessments at our facilities and making recommendations for improvement;
  • The annual review of our Environmental & Energy Management Systems to ensure that it is appropriate for the nature, scale and environmental impacts of our activities and products;
  • Training and encouraging our employees to conduct their activities in an environmentally responsible and sustainable manner;
  • Establishing objectives and targets, conducting an annual review of our performance, and publicly reporting our progress;
  • Making this policy publicly available to all employees and interested parties; and
  • Encouraging our suppliers and business partners to maintain the same high levels of environmental performance.

The Hormel Foods Board of Directors is responsible for monitoring the corporation’s overall approach to environmental and energy matters.

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Group Sow Housing
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Group Sow Housing Commitment and Next Steps

As a purchaser of animal products, we understand and value the principles of responsibility of our suppliers, including animal welfare, and we require that all animals in our supply chain are raised in a healthy environment and treated appropriately.

As it relates to sow housing alternatives, Hormel Foods understands that many of its customers have made commitments surrounding continued support of group sow housing alternatives within their supply chains. To aid these efforts, Hormel Foods will continue to support alternatives to gestation stalls, including group sow housing, and is committed to leading the way in our owned operations and playing a role in evolving the supply chain. We will continue to support customers’ and consumers’ wishes related to animal welfare standards, as we work with suppliers on how best to achieve these requirements.

Hormel Foods made a commitment to transition its company-owned sow farms to group sow housing by 2018. It met this commitment early, and today the company uses the latest sow housing technology for its company-owned sows. Our company-owned sow housing operation is also California Proposition 12 and Massachusetts Question 3 compliant. In fact, Hormel Foods was among the first companies to commit to compliance with California Proposition 12 and a wide range of compliant Hormel Foods products were available beginning in January 2022, and continue to be today. In addition, one of our subsidiaries, Applegate Farms, already houses sows in groups and has been doing so since 1987.

The next steps Hormel Foods will take are:

  • Baseline Study: Starting early in our fiscal year 2024, Hormel Foods will conduct a baseline study to understand the use and prevalence of group sow housing throughout our supply chain. Targeting spring of 2024, we will publicly share the results of this study, including the current total percentage of animals harvested coming from group housing systems within our supply chain and action steps we will take toward increasing this percentage within our supply chain in order to exceed customer/consumer demand.
  • Reporting Progress: Moving forward, our Global Impact Reports will provide quantitative data, including the total percentage of group-housed production in our supply chain, and relevant actions taken in that year.
  • Engaging Customers: We will work closely with our customers, especially those who have made similar commitments, to ensure that there is an understanding of the investments required by farmers to achieve progress in this area.
  • Working Group: We will create a working group comprised of multiple farm partners to convene at least twice a year, including with customers that have group housing commitments, to understand the issue and its importance to customers and consumers.

We understand that this is a significant commitment, and one that will be dependent on a large and complex independent supply chain and market demand. We will do our part to collaborate across our supply chain to help drive progress.

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Human Rights Statement
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Hormel Foods follows local and national laws in the United States and other regions in which we operate. We are committed to treating people with the utmost dignity and respect throughout our entire supply chain, and promoting and protecting the rights of all workers, including at-risk populations such as minors, women and minorities. Our human rights practices and expectations for our operations, partners and suppliers are part of our Code of Ethical Business Conduct, other policies, Supplier Code of Conduct and supplier contracts. Please see additional information below regarding our efforts to ensure our supply chain is free from slavery and human trafficking.

To ensure adherence to our Code of Ethical Business Conduct and Supplier Code of Conduct, we established a compliance program that upholds accountability through reporting, tracking and investigating possible violations. The Audit Committee of the company’s Board of Directors oversees the compliance program. In order to facilitate anonymous feedback and address concerns, we provide a hotline number and website that are operated by an independent, third-party organization. In 2020, there were no human rights incidents determined to be violations of our Code of Ethical Business Conduct or Supplier Code of Conduct.

Hormel Foods supports the Consumer Goods Forum resolution on human rights and its priority principles. We also value and respect the international principles, guidelines and goals aimed at promoting and protecting human rights, including the:

  • International Bill of Human Rights;
  • International Labour Organization Conventions;
  • International Labour Organization’s Declaration on Fundamental Principles and Rights at Work;
  • Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises;
  • U.N. Declaration of Human Rights;
  • U.N. Global Compact’s 10 Principles;
  • U.N. Guiding Principles on Business and Human Rights; and the
  • U.N. Sustainable Development Goals.

When Hormel Foods considers international investments, acquisitions and joint ventures, as part of the due diligence process we conduct research on human rights parameters to ensure compliance with all governing country or province laws regarding investment agreements, including:

  • Verifying that the workforce is of appropriate and legal age.
  • Determining whether the company is in compliance with the governing country or province laws regarding paying for overtime, as well as setting aside and disbursing legally required employee welfare funds for areas such as housing and education.
  • Addressing overarching questions to determine whether the company adheres to all governing country or province laws and whether there are outstanding litigation or enforcement actions underway or expected.
  • Documenting the company’s adherence to employee safety and right to work policies, ensuring they meet governing country or province laws.

We are committed to engaging in meaningful consultation with stakeholders regarding this important topic as we make updates to this statement, which is reviewed annually by the senior vice president of human resources. The company’s Code of Ethical Business Conduct is reviewed yearly by the Audit Committee of the company’s Board of Directors.

Information about employee safety, training, human rights training and diversity is reported annually in our global impact report.

Modern Slavery
Hormel Foods does not tolerate forced labor or human trafficking. Our efforts to ensure our supply chain is free from slavery and human trafficking include the following:

  • Identifying and analyzing risks.
  • Requiring compliance with all applicable laws and regulations, our purchase order terms and conditions and our Supplier of Code of Conduct.
  • Performing supplier due diligence, including assessing the environmental, social and governance (ESG) performance and programs of our suppliers through a survey assessment process. Third-party audits may be conducted based on the results of assessments.
  • Providing the ability for anyone to report a concern through our third-party compliance website or hotline (1-833-672-1232), which are available 24 hours a day, seven days a week. Reporters may choose to be anonymous.
  • Implementing corrective actions for any supplier not in compliance with our standards or applicable laws. Should a supplier continue to fail to meet our standards, we will initiate our supplier discontinuation process.
  • Providing training on our Supplier Code of Conduct, which includes the topics of slavery and human trafficking, for our team members and managers who have responsibility for supply chain management and procurement.

For additional information about these efforts, please see our California Transparency in Supply Chains Act disclosure.

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Massachusetts Question 3 Space Requirements for Animal Housing
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Updated: 05/11/23

Hormel Foods has assessed Question 3, and while we are still awaiting final clarity on specific details and rules, the company is preparing to fully comply when this law goes into effect. The company’s brand products already comply with Massachusetts Question 3.

Hormel Foods has confirmed that it faces no risk of material losses from compliance with Question 3. While it adds complexity to our supply chain, including costs associated with compliance, Massachusetts is an important market for Hormel Foods, and we will continue to meet the needs of our consumers and customers throughout these states.

As a global branded food company, we have a broad range of products that we currently sell in Massachusetts – from Skippy® peanut butter to Wholly® Guacamole. Question 3 impacts the company’s fresh pork business. Hormel Foods is currently working with its supply chain to implement internal processes for segregation and SKU expansion. We are currently working through supply and logistics planning for affected products, and we expect a full range of compliant products to be available in our Retail and Foodservice segments. We will continue to work closely with our customers to ensure that our consumers in these states will be able to purchase the Hormel Foods products they depend upon.

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Palm Oil Policy
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Palm Oil Principles
Hormel Foods recognizes the unique environmental and social risks associated with palm oil.

These risks require additional due diligence in sourcing, education and training to ensure we meet our commitment that the palm oil in our supply chain is not associated with human rights issues, deforestation or plantation expansion on carbon-rich peatlands.

While Hormel Foods is a relatively minor user of palm oil, we realize that responsible sourcing of even the smallest amount of this ingredient can make a difference. Therefore, we will only purchase palm oil from suppliers who comply with the following sourcing principles:

  • Legally acquire land rights and operations.
  • Follow local laws and regulations.
  • Respect the rights of all workers.
  • Respect the free, prior and informed consent of local and indigenous communities.
  • Identify legal, customary, and user rights, and people entitled to compensation.
  • Resolve social conflicts and provide remedy and redress for past violations.
  • Include smallholders in supply chains and ensure equitable benefit sharing.
  • Protect high conservation value areas and high-carbon-stock forests.
  • Protect rainforests and peatlands, regardless of depth.
  • Reduce greenhouse gas emissions and institute a ban on burning.
  • Follow the principles and criteria of the Roundtable on Sustainable Palm Oil (RSPO).
  • Comply with our Supplier Code of Conduct, which outlines our expectations for all suppliers to uphold top standards related to food quality, product integrity, human and labor standards, environmental practices, business ethics and animal care. In the event an audit or other credible source reveals a supplier is in violation of these principles, Hormel Foods will require the supplier to implement corrective actions. If reasonable/appropriate corrective actions cannot be agreed to, Hormel Foods will suspend or discontinue purchases from the supplier.

Palm Oil Action Plan

  • We purchase RSPO-certified palm oil. We made an initial commitment that by the end of 2014, we would purchase only fully traceable palm oil. We met this commitment by working with our suppliers and achieved traceability to the mill level. In the spirit of continuous improvement, we will continue to work with our suppliers to reach 100% traceability to the plantation level, which we estimate will be completed by the end of 2025.
  • All of our suppliers are required to report the locations of mills from which they source through their RSPO certification. They must also report annually to RSPO on their progress in verifying the palm oil they source meets responsible production practices.

We will communicate our progress toward this action plan in future Global Impact Reports.

This policy applies to all products that contain palm oil that our company sells, in all countries where we operate.

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SBTI (FLAG) Zero Deforestation Commitment
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Hormel Foods has committed to setting a Science Based Target by 2023. This was a publicly-stated goal as part of our 20 by 30 challenge, which includes several environmental and climate-related goals. The company submitted its SBTi information in July of 2022 and is awaiting final validation from the Science Based Target Initiative governing body. The SBTi is a partnership between CDP, the United Nations Global Compact, World Resources Institute (WRI) and the World Wide Fund for Nature (WWF). The SBTi call to action is one of the We Mean Business Coalition commitments. Once validated, the SBTi goals will be made public and the company will track progress against the goals, including reporting publicly its progress.

As part of this commitment, we will agree to follow SBTi’s Forest Land and Agriculture (FLAG) Guidance. The Forest, Land and Agriculture Science Based Target Setting Guidance is the world’s first standard for companies in land-intensive sectors to set science-based targets that include land-based emissions reductions and removals. The guidance requires that Hormel Foods commit to no-deforestation across its primary deforestation linked commodities. Under the timeline established by SBTi, Hormel Foods must finalize the commitment by December 31, 2024. Understanding the importance of deforestation concerns, we are committing to accelerating the development of the no-deforestation policy from the date established by SBTi.

Key requirements of the SBTi FLAG Guidance

  • Set near-term FLAG science-based targets: 5-10 year emission reduction targets in line with limiting warming to 1.5°C.
  • Account for removals in near-term FLAG science-based targets: GHG removals include approaches such as improving forest management practices and enhancing soil carbon sequestration on working lands.
  • Set long-term FLAG science-based targets: Companies in the forest, land and agriculture sectors will reduce at least 74% of emissions by no later than 2050. They should use the SBTi Net-Zero Standard to set long-term FLAG science-based targets.
  • Zero deforestation targets must be set for no later than 2025: In line with the Accountability Framework initiative (AFi).
  • Set science-based targets for fossil emissions: Businesses with land-based emissions are required to set FLAG science-based targets AND science-based targets, since all companies produce fossil emissions.

Additionally, Hormel Foods is committing to a detailed review of the company’s forest footprint in 2023. Once completed, we will review appropriate independently verified deforestation-free approaches and communicate targets for a verified deforestation-free supply chain by 2025.

The forest footprint review will also allow us to better evaluate and assess improved disclosure of Scope 3 emissions related to deforestation and land-use change in subsequent CDP Climate Change responses. While not required by SBTi, Hormel Foods understands that inclusion of native vegetation conversion and primary forest degradation language is strongly supported by SBTi and other stakeholders. We will work to include the appropriate language in our deforestation-free policy.

Finally, Hormel Foods commits to increasing the level of detail disclosed related to primary deforestation linked commodity programs through the annual CDP Forests response. The organization will evaluate including additional sourcing information at the completion of the detailed review of the company’s forest footprint. This additional detail will include disclosures of nonconfidential information related to the company’s beef supply in Brazil and supporting procurement policies which will be reviewed and updated as appropriate. We will continue to work closely with third-party experts to fulfill these commitments.

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Supplier Code of Conduct
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The Hormel Foods Supplier Code of Conduct is designed to ensure that the quality of products and services we receive from our suppliers follows our commitment to responsible economic, environmental, and social performance as directly linked to our activities and products. In partnership with our suppliers, we deliver quality, nutritious and convenient food products.

Our Supplier Code of Conduct (“Code”) outlines our expectations and requirements for all suppliers. “Supplier” means any company, corporation, or other entity that sells or seeks to sell goods or services to Hormel Foods, and also includes such Supplier’s own suppliers and sub-contractors. Suppliers are also expected to communicate and apply our Code and relevant policies throughout their own supply chain.

Compliance with Applicable Laws, Regulations and Practices

At a minimum, we require our Suppliers to act in accordance with all applicable federal, state, and local laws and regulations. In addition, international laws and industry standards must be followed where applicable. If there is a conflict between what the law requires and the standards of our Supplier Code of Conduct, we expect our Suppliers to meet the higher standard.

Verification of Compliance

Hormel Foods expects all Suppliers to be able to demonstrate compliance with this Code. Suppliers must promptly respond to our requests for compliance verification, and Suppliers must take any necessary action to correct noncompliance. Hormel Foods reserves the right to terminate a Supplier business relationship in the event of a Supplier’s egregious violation or failure to satisfactorily correct a noncompliance. Hormel Foods maintains the right to take certain actions, such as inspection of production facilities or review of the applicable documentation, to ensure compliance with this Code.

Human Rights

Suppliers are expected to act in accordance with the international principles and guidelines aimed at promoting and protecting human rights, including the International Bill of Human Rights, International Labour Organization Conventions and Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, UN Declaration of Human Rights, UN Global Compact’s 10 Principles and the UN Guiding Principles on Business and Human Rights. Hormel Foods expects compliance by our Suppliers throughout our supply chain, including:

Non-Discrimination

We expect Suppliers to foster an inclusive and diverse work environment that is free from harassment and discrimination of any kind. Suppliers must not discriminate in hiring and employment practices based on race, color, gender, gender identity or expression, religion, age, nationality, sexual orientation, social or ethnic origin, disability, pregnancy, political affiliation, veteran status, union membership or marital status.

Working Hours, Wages and Benefits

Suppliers must meet or exceed all legal requirements for compensation, working hours, time off, rest periods, benefits and working conditions.

Health and Safety at Workplace

Suppliers must provide safe and healthy working conditions and have appropriate controls, procedures, and training in place.

Freedom of Association

Suppliers must respect the rights of employees to freedom of association and collective bargaining.

No Forced or Compulsory Labor

Suppliers must ensure that no forced labor, including bonded, indentured, or involuntary prison labor, is used. Suppliers must ensure that no fees or costs are charged to job-seekers and employees for the services directly related to recruitment for temporary or permanent job placement, including when using the services of private recruitment, a labor broker or employment agent or performing recruitment activities directly. Workers must be allowed to terminate employment at any time upon reasonable notice.

No Child Labor

Suppliers must not use or tolerate the use of human trafficking, forced labor or child labor as defined by the International Labour Organization. The term “child” refers to any person employed under the age of 15 (or 14 where the applicable laws permit), or under the age of completing compulsory education, or a minimum age for employment in the country.

Immigration Law Compliance

Suppliers will only employ workers with a legal right to work, which Supplier must validate before the employment by reviewing the relevant documents. Suppliers must ensure they only use employment agencies that follow these same standards.

Small and Diverse Business Inclusion

Suppliers must make all possible efforts to include small and diverse suppliers (minority-owned, women-owned, veteran-owned, disabled-owned, disadvantaged or HUB-certified businesses) in their active supplier base and partnerships.

Environment

Hormel Foods expects Suppliers to have programs in place to reduce their environmental impacts, set targets for improvement, measure efforts, and make a commitment to continuous improvement, including, but not limited to, reducing greenhouse gas emissions, reducing food waste, minimizing food packaging, increasing recyclability, reducing or optimizing the use of water, energy, and agriculture inputs, and minimizing water pollution and waste.

Deforestation

For Suppliers who are subject to deforestation laws (i.e., beef, cocoa, coffee, fiber-based packaging, palm oil, soy, sugar), Hormel Foods expects such Suppliers to follow all applicable laws requiring such Suppliers to legally acquire land rights, and to take measures to ensure the protection of high conservation value areas, high carbon stock forests, rainforests and peatlands (regardless of depth). Hormel Foods does not procure products directly sourced from areas at high risk for deforestation and expects the same from its Suppliers.

Animal Care

Hormel Foods has a zero-tolerance policy toward the mistreatment of animals through abuse or neglect. To maintain our high standards, Hormel Foods requires that all Suppliers of live animals, products containing animal protein, or products containing animal byproducts, will always observe appropriate animal welfare and handling practices pursuant to applicable laws industry standards. In addition, all Suppliers of live animals are contractually required to abide by additional animal care and treatment specifications.

Product Quality and Safety

Suppliers must ensure high-quality and safe products through appropriate measures of quality control. All ingredients and products must be produced following the highest standards of sanitation.

Business Integrity

Confidential Information and Intellectual Property

Confidential information must be protected and must not be used inappropriately or to support insider trading activity. Suppliers must respect intellectual property rights and safeguard customer and other protected information.

Gifts and Hospitality

No gift, loan or favor should be made by any Supplier to employees, officers, directors, or their immediate families if it is intended to influence a business decision. This does not prohibit casual, business entertainment consistent with the Supplier’s usual practices or gifts of nominal value ($100 or less).

Anti-Bribery and Corruption

Suppliers must not, directly or through others, offer, give, or accept any form of payment or incentive to gain an improper business advantage. Suppliers must not engage in bribery (including facilitations payments), kickbacks, money laundering, or any other form of corruption. Suppliers must, as applicable, comply with the U.S. Foreign Corrupt Practices Act, and the UK Bribery Act and shall not take any actions to violate, or cause business partners to violate, any applicable anti-bribery and corruption laws.

Reporting

To report a concern, please visit our third-party compliance website or call our hotline (1-833-672-1232). Both are available 24 hours a day, seven days a week.

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