Responsible Sourcing Policy
Purpose
At TreeHouse Foods, Inc. we make high quality food and beverages affordable to all. 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.”
Scope and Objective
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.
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
2 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 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.
- No conversion of High Carbon Stock (“HCS”) forest and/or of High
Conservation Value (“HCV”) areas.
- 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 traceablity to mill, plantation, and/or farm-level.
Human Rights and 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 and 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.
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 cerifies 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 Ethics 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 Grievances
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.