Updated February 2015

TreeHouse Foods, Inc. Social Responsibility Policy

POLICY

The Company is committed to ensuring that our manufacturing and workplace activities have a reduced negative impact on the environment. It is our intent to have our suppliers partner with us to focus on environmental responsibility as a basic part of their daily activities, and that these values are communicated and shared with their employees, agents, and subcontractors. Some focal areas to help achieve these goals are to reduce waste and the usage of resources by regularly reviewing operations to ensure that they are as efficient as possible. We encourage the use of computerized forms and systems to promote a paperless environment, to recycle throughout manufacturing facility and office buildings, and promote the use of recycling services. We want our partners to have continually effective processes in place that endorse the resourceful use of electric and water supplies. To better meet environmental regulations that relate to our partners and their supply base, we ask that they use ethically sourced products, meet or exceed environmental regulations, and show an environmentally responsible work principle.

OUR SOCIAL RESPONSIBILITY POLICY

Supplier shall be in compliance with, and shall require its subcontractors and any person under its control to comply with, all applicable local, state, national, and international laws, rules and regulations relating to ethical and responsible standards of behavior, including, without limitation, those dealing with human rights (including, without limitation, human trafficking and slavery and conflict mineral sourcing), environmental protection, sustainable development and bribery and corruption. Supplier certifies that it has adopted and implemented appropriate and effective policies to ensure compliance with these obligations, including:

 

1. EMPLOYMENT PRACTICES

  1. Minimum Age for Employment - Supplier will not employ anyone under the legal working age as defined by local law.
  2. Forced Labor - Supplier will not use forced or involuntary prison labor.
  3. Abuse and Harassment - Supplier will not use corporal punishment or other forms of physical or sexual harassment or abuse of their employees.
  4. Discrimination - Supplier will not discriminate on the basis of any condition or characteristic which is protected by applicable law or regulation. Bay Valley is an equal opportunity employer and may be a federal contractor or subcontractor. Supplier agrees that, as applicable, it will abide by the requirements of 41 CFR 60-1.4(a), 41 CFR 60-300.5(a) and 41 CFR 60-741.5(a) and that these laws are incorporated herein by reference. These regulations prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities, and prohibit discrimination against all individuals based on their race, color, religion, sex, or national origin. These regulations require that covered prime contractors and subcontractors take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, national origin, protected veteran status or disability. Supplier also agrees that, as applicable, it will abide by the requirements of Executive Order 13496 (29 CFR Part 471, Appendix A to Subpart A), relating to the notice of employee rights under federal labor laws. To the extent applicable and if Supplier is not exempt, Supplier also agrees to comply with federal regulations, as amended, pertaining to nondiscrimination and affirmative action (generally parts 60-1 of Title 41 of the CFR), including, but not limited to, the following, all of which are incorporated herein by reference: (i) Affirmative Action Compliance Program (41 CFR 60-1.40); (ii) Affirmative Action – Disabled Veterans and Veterans of the Vietnam Era (41 CFR 60-250.4); (iii) Affirmative Action – Handicapped Workers (41 CFR 60-741.4); (iv) Equal Opportunity (41 CFR 60-1.4); (v) Employer Information Report SF-100, annual filing (41 CFR 60-1.7); (vi) Fair Labor Standards Act of 1938; (vii) Prohibition of Segregated Facilities (41 CFR 60-1.8); and (viii) Small Business Concerns, Small Disadvantaged Business Concerns, and Women Owned Business Concerns (48 CFR Chapter 1, Subpart 19.7), (viii) 41 C.F.R. Parts 60-1 through 60-60 (women and minorities); 29 U.S.C. Section 793 and the applicable regulations contained in 41 C.F.R. Part 60-741 (individuals with disabilities); 38 U.S.C. Section 4212 and the applicable regulations contained in 41 C.F.R. Part 60-300 (covered veterans); the employee notice requirements set forth in 29 C.F.R. Part 471, Appendix A; FAR 52.203-13 & 15 (code of business ethics and conduct); 52.219-8 (utilization of small business concerns); 52.222-50 (combatting trafficking in persons); 52.226-6 (promoting excess food donations to nonprofit organizations); and 52.247-64 (preference for privately owned US flag commercial vessels).
  5. Supplier shall also comply, unless exempt, with any applicable state laws pertaining to nondiscrimination and affirmative action.
  6. Freedom of Association - Supplier will recognize and respect each employee’s right to associate with any legally sanctioned organization. The rights of labor unions must be respected.
  7. Work Hours, Work Week and Payment of Wages - Supplier will comply with all applicable local laws.
  8. Health and Safety - Supplier will provide employees with working conditions that are in compliance with all applicable laws and regulations regarding worker health and safety.

2. BUSINESS INTEGRITY

  1. Supplier will promote honesty and integrity in its business conduct by raising ethical awareness among its employees and providing direction and education on ethical issues.
  2. Supplier certifies that, in performing work under any agreement with Bay Valley, Supplier, on behalf of itself and its affiliates, partners, owners, officers, directors, employees, and agents, understands the terms of the Foreign Corrupt Practice Act of 1977, as amended, and has not and will not pay, offer, or promise to pay, or authorize the payment, directly or indirectly, of any monies or anything of value to any government official, government employee, political party, or candidate for political office for the purpose of influencing any act or decision of such person or of the government to obtain or retain business, or direct business to any person, and Supplier has not and will not pay or accept bribes, arrange or accept kickbacks, or participate in illegal inducements in business or government relationships.

3. ENVIRONMENT AND SUSTAINABILITY

  1. Supplier will work to continuously improve its environmental performance by setting and then working toward quantifiable goals that reduce the environmental impact of its activities.
  2. Supplier will be expected to comply with applicable environmental laws and regulations in their operations and to develop and implement plans and programs to correct any non-compliant practices.

 

Supplier will be expected to certify its compliance with this Policy at Bay Valley’s request and to authorize Bay Valley and its designated agents (including any third parties) to engage in monitoring activities, including on-site inspections based upon reasonable notice. Supplier agrees that Bay Valley may audit Supplier in order to verify compliance with the terms herein or any agreement with Bay Valley. At Bay Valley’s option, Bay Valley may select an independent third party to conduct the audit on Bay Valley’s behalf in order to certify to Bay Valley that no breach has occurred or will occur. Supplier shall fully cooperate at no additional charge to Bay Valley, in any audit conducted by or on behalf of Bay Valley.