Responsible Sourcing Policy
PURPOSE
At TreeHouse Foods, Inc. we strive to engage & delight – one customer at a time. Our vision is to be the
undisputed solutions leader for custom brands and our mission is to create value as our customers’ preferred
manufacturing and distribution partner, providing thought leadership, superior innovation, and a relentless focus on
execution. We also believe that it is imperative to operate our business in an environmentally and socially
responsible manner, which is why we have developed an Environmental, Social, and Governance (“ESG”)
strategy and published specific ESG goals outlining how we plan to bring that strategy to life.
We know that to provide high quality food and beverages, we need a diverse and effective supply chain and to
accomplish that, we need to work closely with our vendors and suppliers. As we look to address broader issues like
public health, climate change, global natural resource scarcity, deforestation, human rights, and fair labor
practices, it is essential that we engage our suppliers and work collaboratively with them to address these
concerns. It is in this spirit that we outline our expectations for suppliers and invite all partners to join us in
our mission.
Our Responsible Sourcing Policy describes our position on, approach to, and expectations for all suppliers that seek
to join us to be “Better Together.”
APPLICABILITY
Better Together is part of our cultural values at TreeHouse Foods, Inc. which focuses on being diverse, equitable,
inclusive and collaborative, and this spirit is extended to our valued suppliers. TreeHouse Foods, Inc. is dedicated
to cultivating authentic business partnerships built on shared values, trust, and a commitment to running an
environmentally and socially responsible business. As we continue to service our customers and integrate our ESG
strategy and goals into our business, explicitly stating our expectations for supplier environmental, social, and
governance performance will ensure we attract the right partners to join us in our mission.
- This code applies to all TreeHouse Foods, Inc.’s suppliers, third-party contractors, and other external
vendors.
- We are committed to treating all parties fairly and ethically, as articulated in our Code of Ethics and Food
Safety and Quality (FSQA) Supplier Expectations Manual.
- Acceptance and adherence to this Policy is mandatory for all suppliers to undertake business with TreeHouse
Foods, Inc.
POLICY
ESG Alignment
We are dedicated to leveraging our capabilities, geographic presence, and resources to positively impact and create
value for all of our stakeholders. We believe it is in our best interest, and those of our suppliers, to anticipate
and adapt to changing environmental, social, and economic conditions, including climate change and its impacts. We
prioritize working with suppliers that share this commitment to conduct business responsibly, sustainably, and in
alignment with our ESG objectives.
We strive to uphold the principles of the Organisation for Economic Co-operation and Development (“OECD”)
Due Diligence Guidance for Responsible Business to inform efforts on environmental protection and the treatment of
employees, and we expect our suppliers to use the same guidance to identify and address risks to their business.
Environmental Sustainability
We take an integral approach to environmental stewardship by working with suppliers that strive to mitigate the
environmental impact of their operations, goods, and services. At minimum, suppliers must comply with all applicable
environmental laws and regulations. We seek to build and maintain sustainable partnerships with suppliers that align
with our efforts pertaining to energy and water conservation, greenhouse gas emissions reduction, preservation of
biodiversity, and implementation of sustainable packaging solutions.
- Suppliers will demonstrate that products provided did not contribute to deforestation or biodiversity loss in
any way.
- Suppliers will provide, whenever possible, information on efforts to reduce energy, water, and waste in the
production of product provided to TreeHouse Foods, Inc.
- Suppliers will provide TreeHouse Foods, Inc., whenever possible, with sustainable packaging solutions that are
recyclable, recycled, compostable or biodegradable.
- Suppliers will provide TreeHouse Foods, Inc. with information on efforts to reduce greenhouse gas emissions
associated with production and/or distribution of goods and services to the company.
Priority Ingredients (Palm Oil, Coffee, and Cocoa)
Poor management of the cultivation and expansion of crops like palm oil, coffee, and cocoa have led to deforestation
and loss of biodiversity, as well as to labor and human rights abuse issues. This is why TreeHouse Foods, Inc. works
with suppliers, non-governmental organizations (“NGOs”) and third-party certification entities that seek
to transform the global supply chains of these priority ingredients through the application environmental and
socially responsible standards for preserving biodiversity, protecting human rights, and promoting transparency and
traceability.
- No Deforestation and No Development on Peat Lands
- Suppliers will be able to demonstrate, upon request, that they meet the following principles:
- No conversion of High Carbon Stock (“HCS”) forest and/or of High Conservation Value
(“HCV”) areas.
- No burning for clearing land or for the production or cultivation of the product.
- No development on peat lands regardless of depth, and the utilization of best management practices for
existing plantations on peat.
- Suppliers will comply with the standards of the Roundtable on Sustainable Palm Oil (“RSPO”), the
HCS Approach and the HCV Resource Network.
- No Exploitation
- Suppliers should adhere to all regulations and laws addressing the rights of workers, indigenous peoples,
and local communities.
- Suppliers should respect land tenure rights, including rights of indigenous and local communities to give or
withhold their free, prior, and informed consent for development on land to which they hold legal,
customary, communal, or user rights.
- Small Holders
- Suppliers will align with RSPO principles and criteria for Shared Responsibility and support of small
holders.
- Suppliers should collaborate with smallholder farmers by providing support for agricultural capacity
development and promoting on-farm environmental and socially responsible practices.
- Supply Chain Transparency
- TreeHouse Foods, Inc. reserves the right to audit supplier performance on ingredients deemed high risk by
the company such as palm oil, coffee, or cocoa.
- Upon request, suppliers will be expected to provide traceability and accounting documentation substantiating
the source and certification status of high-risk ingredients, ensuring traceability to mill, plantation,
and/or farm-level.
Human Rights & Fair Working Conditions
We are committed to working with suppliers that treat their employees with dignity and respect. To ensure protection
and promotion of the human rights of all supplier employees, we expect our suppliers to comply with applicable laws
and regulations and have internal controls and systems in place to adhere to the following:
- Suppliers must abide by all legislation prohibiting child labor, slavery, human trafficking, and forced or
compulsory labor.
- Every worker should have freedom of movement and no worker should pay for a job or be indebted or coerced to
work.
- Verify the employment eligibility of employees.
- Respect the right of employees to freely associate, organize, and legally bargain collectively in accordance
with applicable laws and regulations.
- Ensure an inclusive workplace free from discrimination and harassment, based on all of the following
characteristics: Race, religion, color, gender identity, age, sexual orientation, sex, national origin,
ethnicity, disability, veteran status, marital status, pregnancy, genetic information, political beliefs, or any
other characteristics protected by applicable law.
- As applicable, and if they are not exempt, suppliers will comply with the federal and local laws and regulations
pertaining to nondiscrimination and affirmative action.
- Suppliers must comply with all applicable laws concerning wages, overtime pay, and benefits. Workers are
entitled to fair and equitable compensation.
- Suppliers must ensure that working hours and rest periods are in accordance with applicable laws. Work schedules
should not be excessive and workers should be provided with reasonable rest and leave periods and paid holidays.
- Suppliers must have processes in place to identify, prevent, and mitigate human rights violations and impacts,
including mechanisms for the remediation of any adverse human rights impacts they contribute to.
Workplace Health & Safety
We require our suppliers to provide a safe and healthy work environment for its employees and local stakeholders,
including appropriate safety controls and procedures, training, and protective equipment, in accordance with all
applicable laws and regulations.
- Suppliers are required to abide by all local, national, and applicable international laws relating to health,
safety, and the environment while conducting work for and with TreeHouse Foods, Inc.
- We expect adequate measures and controls are in place to protect the health and safety of their employees, their
local stakeholders, and the overall community as it pertains to the company’s operations and behaviors.
- Product plants and manufacturing sites must be made safe for all workers, vendors, and the surrounding
community.
- Suppliers must provide health and safety training prior to employment and on an ongoing basis in the primary
languages of its workers and of the regions in which they operate.
- Workers must be provided with appropriate protective equipment and shall be instructed on its proper use.
- Workers have the right to refuse to work in unsafe or unhealthy working conditions, as well as to report health
and safety hazards without fear of retaliation.
- Suppliers should conduct risk assessments for production facilities to identify potential concerns that could
lead to serious incidents or hazards. Appropriate corrective actions should be taken.
Food Safety, Quality and Regulatory Compliance
Ensuring that every product we produce is safe and fit for human consumption is our greatest responsibility. We work
closely with our suppliers to ensure production quality, supply chain traceability, and accurate and transparent
labeling.
- All food products must meet or exceed applicable government and contractual standards for safety and quality.
Refer to the TreeHouse Foods, Inc. FSQA Supplier Expectations Manual. All concerns or issues regarding product
safety or quality must be reported immediately to TreeHouse Foods, Inc. to ensure appropriate action can be
taken to protect our customers, their consumers, the brand of our suppliers, and the greater public.
- We are dedicated to supporting capacity building and operational guidance to enhance supplier food safety and
quality measures. However, we always reserve the right to terminate the relationship if expectations are not
met.
Animal Welfare
We recognize the role we play in influencing ethical and humane behavior throughout our supply chain, including when
it comes to the treatment of animals. We strive to meet the high standards of our customers and consumers in all
aspects, and therefore expect that all supplier animal welfare programs meet or exceed industry best practices,
aiming to prevent all forms of abuse that negatively impact the health and welfare of animals. We support the Five
Freedoms framework, and we work with our suppliers to ensure their practices are consistent with the Five Freedoms
of animal welfare.
Business Integrity
We are committed to conducting business the right way all the time, with integrity as our key ingredient. We work
with suppliers that share this commitment and do business ethically and in compliance with all applicable laws and
regulations.
- Suppliers will promote honesty and integrity in its business conduct by raising ethical awareness among its
employees and providing direction and education on ethical issues.
- Suppliers shall not engage in any form of bribery or corruption in order to obtain an unfair or improper
advantage.
- Supplier certifies that, in performing work under any agreement on behalf of itself and its affiliates,
partners, owners, officers, directors, employees, and agents, they understand 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.
- Suppliers shall abide by all applicable anti-corruption, money laundering and competition laws.
- Suppliers shall not participate in activities which could be seen as impending competition.
Supplier Selection Process and Conflicts of Interest
- We reserve the right to conduct integrity screening of our suppliers as part of its selection process.
- Prior to the start of the selection process, all potential conflicts of interest must be declared.
- We reserve the right to offer preferred purchasing opportunities to business partners that have established ESG
goals and are aligned with our own ESG objectives and long-term aspirations.
ESG Collaboration & Reporting
We reserve the right to conduct supplier surveys to assess performance on ESG and Code of Ethics related issues.
Suppliers are expected to participate in these surveys and respond with accurate and timely information.
Compliance and Verification
We will monitor and enforce this Policy through a variety of audit protocols if any potential risks are detected.
These measures include but are not limited to third-party verification, on-site visits and relevant records, and any
additional monitoring and enforcement measures we deem necessary on a case-by-case basis.
We highly encourage all of our suppliers to uphold the same standards and compliance when working with their
suppliers and subcontractors. This reduces risk exposure to both our suppliers and TreeHouse Foods, Inc.
We specifically reserve the right to the following:
- Prioritize working with suppliers that share our ESG commitment and align with our goals.
- Require verification of environmental and social impact claims through documentation and/or on-site visits.
- Terminate the relationship due to unsatisfactory performance on stated requirements and/or a lack of engagement
and collaboration. TreeHouse Foods, Inc. prides itself on being a collaborative partner to all stakeholders and
will utilize its capabilities, knowledge, and resources to assist our suppliers in course correcting or
development of required measures and controls.
Code of Ethic Violations and Corrective Action
We will investigate any alleged or actual instances of non-compliance with this Policy. Suppliers shall cooperate
with any such investigation and provide any requested documentation or information. In situations where TreeHouse
Foods, Inc. determines remediation is required, the supplier will be expected to implement corrective actions to
remedy the non-compliance in a timely manner.
We reserve the right to terminate the relationship with any supplier that violates this Responsible Sourcing
Policy.
Raising a Concern or Grievance
Should you have any concerns, questions, or needed clarification on our Responsible Sourcing Policy or its relevance
to your specific business, please speak directly to your Procurement point of contact at TreeHouse Foods, Inc. or
contact us at: ESG@treehousefoods.com. If preferring to report a concern confidentially, please contact TreeHouse
Foods, Inc.’s anonymous Hotline at 1-800-763-0781, 24 hours per day, seven days per week.
NOTIFICATIONS
The Company reserves the right to modify or change the policy from time to time at its sole and absolute discretion.
Due to variations in local and state law, some applications of this policy may vary. In addition, to the extent any
provisions or procedures of this policy conflict with local, state/provincial, or federal law, the Company shall
comply with the applicable law.