OF - BUSINESS PARTNER - The Clorox Company
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BUSINESS
PARTNER
OF
A Message from Linda Rendle | 2
Do the right thing.
This core value has been part of Clorox Our Code also supports our environmental,
since our founding in 1913, and it’s one of the social and governance (ESG) commitments
reasons I love this company. related to human rights and labor, respectful
treatment and equal opportunity, anti-
At Clorox, we know that our long-term corruption, and environmental sustainability.
success relies upon honest and ethical Our Code is grounded in international
business practices and treating people with standards and best practices, including the
dignity, respect and equal opportunity. This International Labour Organization (ILO)
is how we build trust with the millions of Declaration on Fundamental Principles and
consumers who bring our products into their Rights at Work and the Ten Principles of the
homes and lives every day. United Nations Global Compact.
We require all team members and employees Please take the time to read the Code so
of wholly owned subsidiaries to be trained that you understand Clorox’s ongoing
annually on our Code of Conduct so everyone expectations of you as our business partner.
understands our commitment to responsible
business practices and responsible sourcing Our business relationships are rooted in
for our products. integrity and based on the Clorox core
value to “do the right thing.” Thank you
We expect our business partners to live up for your partnership.
to our values and standards, too. That’s why
we’ve developed a Business Partner Code of Linda Rendle
Conduct (Code). It details business practice Chief Executive Officer
standards for our direct suppliers of goods
and services, consultants, distributors,
licensees, joint ventures, contractors and
temporary workers.
CLO ROX BUSINESS
BUSINESS PART
PARTNER
NER CODE
CODE OOFF CO
CONNDU
DUCT
CT
IS
Who must comply with it?
?
What are the consequences
for violations?
CLO ROX BUSINESS PART NER CODE O F CO N DU CT
VALUES. CLO ROX BUSINESS PART NER CODE O F CO N DU CT
What is the business partner code of conduct? | 5
Clorox maintains relationships with business partners who share our values
Our Code details business practice standards • Safeguarding the environment and reducing the
for our direct suppliers of goods, service environmental impact of our operations
providers, consultants, distributors, licensees,
joint ventures, contractors and temporary • Establishing high standards of ethical conduct
workers. It is based on the International Labour and complying with fair business practices
Organization (ILO) Declaration on Fundamental
We also expect our business partners to ensure
Principles and Rights at Work and reflects our
that their own business partners assisting with
commitment to advancing Clorox’s ESG goals
Clorox-related business meet or exceed the
as well as the Ten Principles of the United
principles set forth in the Code.
Nations Global Compact (UNGC), to which
we are a signatory. The UNGC’s Ten Principles The Clorox Responsible and Sustainable Sourcing
are derived from the Universal Declaration Policy and associated social and environmental
of Human Rights, United Nations Guiding standards translate the Code’s principles into
Principles on Business and Human Rights, the minimum requirements that the Clorox suppliers
International Labour Organization’s Declaration must adhere to and form part of the Clorox
on Fundamental Principles and Rights at contracts. In situations where laws applicable to
Work, the Rio Declaration on Environment our business partners are more restrictive than
and Development, and the United Nations the principles of the Code, our business partners
Convention Against Corruption. must follow the applicable laws.
Clorox business partners must meet or exceed Nothing in the Code shall create any employment
the principles, expectations and commitments relationship with a business partner’s workers
contained in the Code, including: or any new or additional third-party rights for a
business partner or its workers.
• Complying with all applicable laws
and regulations
• Protecting human rights of workers, including
the principle of freely chosen employment,
and treating all workers with dignity
• Creating safe working conditions and a healthy
work environment for all workers
CLO ROX BUSINESS PART NER CODE O F CO N DU CT
What is the business partner code of conduct? | 6
Business partner training, policies and codes
Business partners must communicate the Clorox may periodically request business
principles and expectations set out in the partners and their workers to attend
Code to their workers and business partners trainings on legal or compliance topics
in a manner understandable to all. In order to conducted by Clorox or on Clorox’s behalf.
satisfy this obligation, we encourage business Failure to make reasonable efforts to
partners to develop and maintain internal participate in such trainings upon request
training, policies and/or codes to ensure that is a violation of the Code.
their workers and business partners assisting
with Clorox business understand the principles
and expectations set out in the Code.
Consequences for violations of the Code or applicable laws
Business partners must be able to We may pursue legal or other remedies
demonstrate compliance with the principles against any business partner who violates
of the Code. Compliance with the principles the Code or applicable laws when conducting
of the Code and all applicable laws is a Clorox business. Additionally, in the event
material condition of continued business of non-compliant conduct, we may, in our
with Clorox, and business partners may not sole discretion, require the business partner
do indirectly what the Code forbids business to implement remedial measures specified
partners from doing directly. by Clorox within a defined time period or
impose consequences up to and including
termination of the business relationship
and any related contracts.
CLO ROX BUSINESS PART NER CODE O F CO N DU CT
CAN I DO
NEED
?
or want to report a concern?
CLO ROX BUSINESS PART NER CODE O F CO N DU CT
ASK & REPORT. CLO ROX BUSINESS PART NER CODE O F CO N DU CT
What can I do if I need help or want to report a concern? | 9
Asking questions and reporting concerns
Our Code details business practice for confidential reporting where permitted
standards. No code of conduct can cover by law. Business partners are required to
every business situation that may require provide the reporting information in this
legal or ethical guidance. We encourage Code to their employees and their own
our business partners to contact us with business partners. Ensuring access to
any questions about the Code or ethical or reporting mechanisms is a core component
legal concerns arising from their relationship of this Code, and Business Partners are
with us. In addition, anyone who becomes expected to disseminate this information
aware of any actual or potential violation in a manner that is easily understood and
of the Code or any applicable law by any accessible for all employees.
Clorox business partner, or other misconduct
including infringements on human rights, The Clorox Compliance Hotline can be
should immediately report such conduct to reached using the contact information below.
Clorox. Business partners, including their Business partners are expected to comply
employees, may contact Clorox directly via with all applicable data privacy laws when
either (1) the Clorox employee with whom using the hotline. We will in turn comply
they have a working relationship or (2) the with applicable requirements upon receipt.
Clorox Compliance Hotline, which allows
CLO ROX BUSINESS PART NER CODE O F CO N DU CT
What can I do if I need help or want to report a concern? | 10
Ask questions or report concerns by telephone
UNITED STATES, CANADA AND PUERTO RICO
1-888-9 CLOROX (1-888-925-6769)
Ask questions or report concerns by internet
The following countries have local direct dial numbers for the Hotline:
ARGENTINA DOMINICAN REPUBLIC NEW ZEALAND http://www.cloroxhotline.com
0800-555-1352 (collect call) 050-853-6017
1-704-526-1175
AUSTRALIA SAUDI ARABIA
1-800-08-7065 HONG KONG 800-850-0372
CHINA
800-96-1701
SOUTH AFRICA Ask questions or report concerns by e-mail
400-882-2048 MALAYSIA 800-44-4460
1-800-81-8498 cloroxcompliance@alertline.com
COLOMBIA UNITED KINGDOM &
01-800-912-0580 MEXICO NORTHERN IRELAND
001-877-978-0052 0808-234-3903
Two-step toll-free dialing is used for these countries:
Ask questions or report concerns by mail
CHILE GERMANY PHILIPPINES Clorox Company Compliance, PMB 3767
Step #1: 800-800-288 Step #1: 0-800-225-5288 Step #1: 1010-5511-00 13950 Ballantyne Corporate Place
Step #2: 888-925-6769 Step #2: 888-925-6769 Step #2: 888-925-6769
Charlotte, NC 28277 USA
COSTA RICA KOREA SPAIN
Step #1: 800-228-8288 Step #1: 00-309-11 Step #1: 900-99-0011
Step #2: 888-925-6769 Step #2: 888-925-6769 Step #2: 888-925-6769
ECUADOR PANAMA UNITED ARAB EMIRATES
Step #1: 1-800-225-528 Step #1: 800-0109 Step #1: 8000-021
Step #2: 001-888-925-6769 Step #2: 888-925-6769 or 8000-555-66
Step #2: 888-925-6769
EGYPT PERU
Step #1: 2510-0200 Step #1: 0-800-50-288 URUGUAY
or 02-2510-0200 Step #2: 888-925-6769 Step #1: 000-410
Step #2: 888-925-6769 Step #2: 888-925-6769
Callers from other countries should consult the international toll-free number with the dialing
instructions listed on www.cloroxhotline.com.
CLO ROX BUSINESS PART NER CODE O F CO N DU CTWhat can I do if I need help or want to report a concern? | 11
Investigating reports of misconduct
All reports of possible violations of the Code misconduct will be handled with appropriate
or applicable laws by our business partners sensitivity. This means that information
will be evaluated promptly and investigated regarding an investigation will only be shared
where appropriate. The investigation may be with those who have a need to know for an
conducted by Clorox personnel and/or our effective investigation and follow-up.
third-party advisors. Reports of potential
Zero tolerance for retaliation
We are committed to ensuring that persons who business misconduct or Code or legal
report violations or participate in investigations violation. Retaliation can include conduct such
are treated fairly. Business partners may as (a) harassment or threats of physical harm,
not retaliate against their workers who report (b) loss of job or contract, (c) less desirable
in good faith possible violations of the law work assignments, or (d) negative impact on
or the Code to Clorox, law enforcement or salary, benefits or contractual remuneration.
government agencies. Nor may business Retaliation against workers is a violation of
partners retaliate against their workers for the Code and may lead to termination of the
cooperating with or participating in good business relationship with Clorox.
faith in any investigation of actual or potential
Monitoring, certifications and auditing
Business partners are expected to designate From time to time, Clorox or its third-party
one or more members of management staff advisors may evaluate business partners’
to be responsible for the implementation and compliance in areas relevant to the Code, such as
maintenance of systems to assess and monitor financial books and records, responsible sourcing,
its compliance with the Code. quality, safety and environmental compliance.
All Clorox business partners are expected to
From time to time, and consistent with our cooperate with reasonable requests from Clorox
business partners’ obligation to comply with the or its advisors in connection with performing
Code, we may ask business partners to execute these reviews, audits and remediation, and
certifications of their compliance with the to respond accurately and transparently to
principles in the Code. requests for information. In the event these
reviews or audits uncover that a business partner
To manage risk in the supply chain, we use
is not adhering to the Code or Clorox’s social,
various third-party audit criteria to help evaluate
sustainability and ethical practices expectations,
suppliers’ overall compliance in areas such
appropriate remediation steps may be taken,
as responsible sourcing, quality, safety and
up to and including termination of the business
environmental compliance.
CLO ROX BUSINESS PART NER CODE O F CO N DU CT relationship or contracts.DOES THE
REQUIRE
ME TO
CLO ROX BUSINESS PART NER CODE O F CO N DU CTETHICAL & RESPONSIBLE. CLO ROX BUSINESS PART NER CODE O F CO N DU CT
What does the Code require me to do? | 14
Human rights and labor
Prohibit harassment, discrimination, harsh or workers with a timely and understandable written Responsible employment and recruitment: To
inhumane treatment: Business partners must statement with each wage payment, via pay check every extent possible, business partners must
provide a workplace free from discrimination, or similar documentation, so that workers can ensure that work is performed on the basis of
harassment, bullying, and abuse. Physical abuse verify that they have been accurately compensated recognized employment relationships established
or discipline, the threat of physical abuse, sexual for the work they have performed. At a minimum, through national law and practice. Business
or other harassment and verbal abuse or other business partners must provide all workers living partners must not avoid their obligations to
forms of intimidation shall be prohibited. Business wages as defined under applicable local law. employees under labor or social security laws
partners must comply with all applicable laws, Business partners must not make deductions and regulations arising from regular employment
treat their workers with dignity and respect, and from wages as a disciplinary measure nor make relationships through the use of labor-only
Clorox’s business partners must endeavor to provide equal opportunities and any deductions from wages not provided for by contracting, sub-contracting, or home-working
must respect the human fair treatment to all workers with respect to hiring, national law without the expressed permission of arrangements, or through apprenticeship
rights of workers and must employment, promotions, training, compensation, the worker concerned. All disciplinary measures schemes where there is no real intent to impart
treat all workers with benefits, termination or retirement and acceptable should be recorded. skills or provide regular employment, nor shall any
dignity. Clorox business living conditions when accommodation is provided. such obligations be avoided through the excessive
Business partners must not discriminate against Working hours: Regular working hours, excluding use of fixed-term contracts of employment.
partners must: overtime, shall be defined by contract and shall
any person on the basis of race, caste, national Business partners must have full understanding of
origin, religion, age, disability, gender, marital not exceed 48 hours per week, in accordance the entire recruitment process including all labor
status, sexual orientation, union membership with applicable law. Business partners must use recruiters and intermediaries in terms of required
or political affiliation or any self-identified or overtime responsibly, taking into account all of legal and/or ethical requirements. Effective
perceived association with a category protected by the following: the extent, frequency and hours management systems must be in place to identify
applicable law and are encouraged to demonstrate worked by individual workers and the workforce and monitor the hiring and management of all
a commitment to building and maintaining a as a whole. It shall not be used to replace regular migrant workers, contract, agency, temporary
diverse workforce. employment. Business partners must always or casual labor and identifying potential abuse
compensate overtime at a premium rate, in of such workers. Business partners must ensure
Comply with internationally recognized wage and accordance with local law or prevailing industry that employment agencies must only supply
hour and benefits standards as well as local laws: standard. The total hours worked in any 7-day workers registered with them and that workers
Business partners must comply with internationally period shall not exceed 60 hours, except in the pay no recruitment fee at any stage of the
recognized applicable wage and hour and benefits following exceptional circumstances where all recruitment process. Business partners’ workers’
standards and laws, including standards and laws of the following criteria are met: (i) it is allowed contracts must accurately reflect the agreed
governing minimum wages, maximum hours, by national law; (ii) it is allowed by collective payment and terms in the recruitment process
days of service, rest periods, overtime pay and agreement freely negotiated with a workers’ and are understood and signed by workers. There
restrictions, worker benefits, organization representing a significant portion should be no sub-contracting unless previously
and leaves of absence. of the workforce; (iii) appropriate safeguards are agreed with Clorox. Business partners must
taken to protect the worker’s health and safety; have systems and processes in place to manage
Wages: Business partners must provide all workers and (iv) business partners can demonstrate sub-contracting, home-working and external
with written and understandable information that exceptional circumstances apply such as processing. Business partners must ensure that
about their employment conditions and wages unexpected production peaks, accidents or they only employ workers with a legal right to
before they enter employment, including specific emergencies. Business partners must provide work. All workers, including employment agency
information about the payment of wages, such as workers with at least one day off in every 7-day staff, must be validated by the business partners
pay periods and frequency, overtime standards and period or, where allowed by national law, 2 days for their legal right to work by reviewing
calculation, and any conditional or discretionary off in every 14-day period. original documentation.
CLO ROX BUSINESS PART NER CODE O F CO N DU CT
payments. Business partners must also provideWhat does the Code require me to do? | 15
Human rights and labor
Comply with laws protecting the rights of slavery-like conditions; (vi) the surrender Land rights of communities: Business
workers to freely associate: Business partners of identity or immigration documents; (vii) partners must respect the rights and
must respect the rights of workers to freely the imposition of unreasonable restrictions title to property and land of individuals,
associate, organize and bargain collectively on workers’ freedom of movement; (viii) the indigenous people and local communities.
in accordance with applicable laws and the demand that any worker directly or indirectly All negotiations with regard to purchasing,
customs of the countries in which they are pay for their job or lodge “deposits”; and (ix) leasing, extracting from or otherwise
employed. Business partners must respect any requirement or threat that a person is using property, natural resources or land,
the rights of workers to communicate indebted or coerced to work. We may require including the use of and transfers of such, must
openly with management or with each other that business partners certify that materials adhere to the principles of free, prior and
Clorox’s business partners regarding working conditions without fear of incorporated into Clorox’s products comply informed consent, contract transparency and
must respect the human retaliation, harassment, intimidation, penalty with the laws regarding slavery and human disclosure. Clorox has zero tolerance
rights of workers and must or interference. Where the right to freedom trafficking of the country or countries in which for land grabbing.
treat all workers with of association and collective bargaining is they are doing business.
dignity. Clorox business restricted under law, business partners must
facilitate and not hinder the development No child labor: Business partners must comply
partners must: with all applicable child labor laws, including
of parallel means for independent and free
association and bargaining. laws governing minimum age requirements
and hazardous or night work, and business
Prohibit human trafficking and modern partners must not employ individuals under
slavery: Business partners must evaluate the age of 14 (unless such work does not
and mitigate risks of human trafficking and interfere with schooling and is permitted by
modern slavery in their operations, and must local laws or applicable portions of the ILO
not produce goods or services for Clorox using Declaration on Fundamental Principles and
forced, bonded, involuntary including prison Rights at Work). Business partners may not
labor or compulsory labor. Such prohibited produce goods or services for Clorox with:
conduct includes: (i) force, threats of force, (i) the sale and trafficking of children; (ii) debt
physical restraint or threats of physical bondage and serfdom of children; (iii) forced
restraint to that person or another person; or compulsory labor of children; or (iv) work
(ii) serious harm or threats of serious harm to which is likely to harm the health, safety or
that person or another person; (iii) the abuse morals of children. Business partners must
or threatened abuse of law or legal process; develop or participate in and contribute to
(iv) any scheme, plan or pattern intended to policies and programs which provide for the
cause the person to believe that, if that person transition of any child found to be performing
did not perform such labor or services, that child labor to enable her or him to attend and
person or another person would suffer serious remain in quality education until no longer
harm or physical restraint; (v) any act involved a child. The Clorox’s definition of “a child”
in the recruitment, abduction, transport, is in accordance to the ILO Conventions for
harboring, transfer, sale or receipt of persons minimum ages (C138) and child labor (C182).
within national or across international borders,
through force, coercion, fraud or deception,
to place persons in situations of slavery or
CLO ROX BUSINESS PART NER CODE O F CO N DU CTWhat does the Code require me to do? | 16
Business partners must maintain safe working
conditions and a healthy work environment for all
of their workers. Business partners must:
Health and safety
Establish regulatory requirement Business partners must provide access to
processes and programs: Business partners clean toilet facilities and to potable water and,
must have in place the proper processes and if appropriate, provide sanitary facilities for
programs that will ensure safety, health and food storage. When Business Partners provide
environmental compliance with applicable accommodation, they must be clean, safe and
regulatory requirements. meet the basic needs of the workers.
Communicate hazards: Business partners Prevent chemical and other exposure:
must ensure that workers receive appropriate Business partners must identify, evaluate,
workplace health and safety information, mitigate and, where possible, eliminate worker
regular and recorded training and warnings, exposure to harmful chemical, biological and
and such training shall be repeated for new or other physical agents. Where hazards cannot
reassigned workers. Business partners must be eliminated, business partners must provide
post Safety Data Sheets for any hazardous or appropriate controls such as closed systems
toxic substances used in the workplace. and ventilation. In all cases, business partners
must provide safe work procedures and
Prevent occupational injury and establish appropriate personal protective equipment.
occupational safety procedures: Business
partners must identify, mitigate and Prepare for emergencies and their response:
eliminate hazards where possible, including Business partners must anticipate, identify
worker exposure to physically demanding, and assess emergency situations and events,
highly repetitive or forced assembly tasks. and minimize their impact by implementing
Business partners must establish safe work emergency plans and response procedures,
procedures and provide appropriate personal including worker notification and evacuation
protective equipment. Physical guards, procedures, worker training and drills,
interlocks and barriers should be provided appropriate fire detection and suppression
and properly maintained for equipment used equipment, adequate exit facilities and
by workers. As part of this commitment, first-aid supplies.
business partners must establish procedures
and systems to manage, track, investigate
and report occupational injury and illness.
CLO ROX BUSINESS PART NER CODE O F CO N DU CTWhat does the Code require me to do? | 17
Environment
We also expect business partners to support waste and air emissions of volatile chemicals or and oceans, and other habitats, ecosystems
Clorox in achieving our sustainability goals, other substances that would violate applicable and living systems.
to strive toward goals that are equally as laws or cause adverse environmental impacts
ambitious to their organizations and to on the local community. Respond to sustainability and related
work toward continuous improvement of reporting requests: Clorox strives toward
their sustainability performance. Business Prevent pollution and waste: Business partners greater traceability of our supply chain to
partners must have an environmental policy should aim to reduce pollution and waste assess and monitor associated risks and
covering their environmental impact, which related to their business, including emissions improving sustainability and human rights
As part of our values and is communicated to all appropriate parties, to air and water and emissions of greenhouse conditions in our supply chains. We expect
Clorox’s commitment to including its own suppliers. Business partners gasses, and encourage their own suppliers and existing and potential suppliers and other
business partners to do the same. In order to business partners to support our reporting
the UNGC’s Ten Principles, must have a nominated individual responsible
for coordinating their sites’ efforts to improve facilitate these reductions, business partners and traceability initiatives to comply with the
we are dedicated to should adopt policies addressing topics such Code, and encourage their own suppliers and
environmental performance. Business
driving sustainable and partners must: as energy use, management of hazardous business partners to do the same. This includes
ethical practices across materials, deforestation, and other waste and responding to our information requests
our operations and our Prevent banned or restricted product content: environmental risks relevant to their business. regarding sustainability commitments and
supply chain. To help us Business partners must implement programs to Business partners should use commercially progress — such as environmental footprint
ensure their products do not contain restricted, reasonable efforts to reduce or eliminate reporting, supply chain traceability and third-
meet this commitment,
banned or unlawfully taken or traded materials, waste of all types, including source reduction, party verification. This information may be
our business partners must including protected wildlife, protected plants recycling, composting, reusing materials and considered in our selection decisions and our
demonstrate stewardship or illegal wood products. Business partners conserving water and energy. Where it is a willingness to continue doing business with any
of the environment must also disclose to Clorox what due diligence legal requirement, business partners must be business partner. Clorox may also periodically
and work to reduce the they performed to determine whether their able to demonstrate that they have the relevant assess and audit suppliers and other business
environmental impacts supply chain is free of minerals or materials valid permits, including for use and disposal partners in fields such as environmental
that finance conflict in the Democratic Republic of resources (e.g., water, waste, etc.) and performance, health and safety, human rights,
of their operations.
of the Congo and surrounding countries, or have available for review any environmental ethics and fair competition (see section II.H). If
from other countries designated as part of a certifications or any environmental a business partner is not acting in accordance
conflict region, including providing relevant management systems documentation. with our sustainability goals, we may
documentation upon request. implement corrective steps to address these
Conserve natural resources and reduce concerns, including education, formal warnings
Manage hazardous materials appropriately: environmental footprints: Business partners and, when warranted, termination
Business partners must identify and manage should operate in a sustainable manner of the relationship.
chemical and other materials posing a hazard consistent with reducing the environmental
if released to the environment and must ensure impact of their operations and encouraging Minimize packaging and shipping impact:
safe handling, management, movement, their own suppliers and business partners to Business partners should identify methods to
storage, recycling or reuse, and legally act in the same manner. Business partners eliminate or minimize the amount of packaging
authorized disposal of such materials, if not are expected to harvest, mine or otherwise used to ship products. Business partners
by themselves, through licensed third parties. acquire and use materials for production should utilize recycled, recyclable, reusable or
Business partners must work to prevent in a responsible manner that minimizes returnable shipping material and should make
accidental or deliberate releases of hazardous the negative impact on the well-being of every effort to optimize shipping methods to
materials, including wastewater and solid humans, animals and biodiversity, forests minimize energy consumption.
CLO ROX BUSINESS PART NER CODE O F CO N DU CTINTEGRITY. CLO ROX BUSINESS PART NER CODE O F CO N DU CT
What does the Code require me to do? | 19
Business conduct and ethics
Comply with all applicable laws: Business Comply with international trade controls, information includes any information that
partners must ensure that they, their affiliates sanctions and anti-boycott laws: Business is non-public or not easily determined or
and their workers comply with all applicable partners must comply with U.S. and other obtained by others. Business partners must
laws and regulations when conducting applicable import/export controls, sanctions, also respect the intellectual property rights,
business for Clorox. and anti-boycott laws when conducting trade secrets and confidential or proprietary
Business partners must business for Clorox, and must avoid taking information of third parties and are prohibited
commit to and abide by Not give or accept illegal payments or any actions that would cause Clorox to from compromising these rights in the course
the highest standards engage in corruption: Business partners violate these laws. Business partners must of working with Clorox. Business partners may
of ethical conduct and must not give, offer, or promise anything of not transfer Clorox goods or technologies not use Clorox’s name or trademarks in any
value (including cash and cash equivalents, to sanctioned/embargoed countries or advertising or marketing materials without
fair business practices. as well as gifts, goods, services or any territories, to sanctioned or restricted parties, prior written authorization from Clorox.
Business partners are other benefit) directly or indirectly to any or for restricted end uses unless such transfer
encouraged to have their government official or any other person is authorized or otherwise not prohibited by Comply with securities and insider trading
own policy prohibiting for the purpose of improperly influencing applicable law or regulation and approved in laws: Business partners that possess non-
bribery, corruption or the recipient or obtaining or retaining an advance by Clorox. public information relating to Clorox must
any type of fraudulent improper business advantage. Government not use or share that information to trade or
officials include any (i) officer, employee or Comply with antitrust and competitive enable others to trade in Clorox securities or
business practice. Business consultant of a government or governmental laws: Business partners must not enter into the securities of another company to which
partners must ensure that department or agency; (ii) officer or agreements or take actions that unreasonably such information pertains. Business partners
the staff whose job roles employee of a state-owned enterprise or restrain trade, are deceptive or misleading, or must comply with all applicable securities
carry a higher level of partially state-owned enterprise; (iii) political restrict competition. Business partners must and insider trading laws when conducting
risk in the area of ethical party official or candidate for political comply with all applicable antitrust Clorox business.
business practice (e.g., office; (iv) officer or employee of a public and competition laws.
international organization, such as the World Operate with high financial integrity:
regulatory approvals, sales, Health Organization or World Bank; (v) any Behave ethically in general contracting: Business partners must not make false,
purchasing, logistics) are private person acting temporarily in an official Business partners must compete fairly and inaccurate or intentionally misleading
trained on what action capacity; or (vi) the spouse or any immediate ethically for all business opportunities. entries in accounting books, records or
to take in the event of an family member of the persons mentioned Business partners must ensure that communications with external or internal
all statements, communications and auditors related to Clorox, and must maintain
issue arising in their area. above. Business partners must fully comply
with the U.S. Foreign Corrupt Practices representations to or on behalf of Clorox accurate books and records in compliance
Business partners must: are accurate and truthful. with generally accepted accounting principles.
Act, the UK Bribery Act 2010 and all other
applicable anti-corruption laws. Business
Protect intellectual property and
partners also may not accept or request any
confidentiality: Business partners must
improper payments or anything else of value.
respect and protect Clorox’s intellectual
All Clorox payments to business partners
property rights and maintain the
must be made directly to the business
confidentiality of Clorox trade secrets and
partners by local bank wire transfer, check
other Clorox proprietary or confidential
or credit card.
information. Confidential and proprietary
CLO ROX BUSINESS PART NER CODE O F CO N DU CTWhat does the Code require me to do? | 20
Avoid conflicts of interest: A conflict of Comply with anti-money laundering and
interest occurs when someone’s personal counter-terrorism financing laws: Business
interests influence or appear to influence partners must comply with applicable anti-
their ability to act objectively and in Clorox’s money laundering and counter-terrorist
best interest. For that reason, business financing laws. Business partners must
partners must disclose to Clorox any actual scrutinize the source of funds transmitted to
or potential conflict of interest. Business Clorox to ensure that the funds are not the
partners must inform Clorox if one of their proceeds of criminal activity. Partners also
workers, investors, family members or other must conduct due diligence of customers
affiliated person has a relationship with a and counterparties to avoid inadvertently
Clorox employee who can make decisions facilitating money laundering or funding
that may affect the business partner’s terrorist organizations in the course of doing
business, or if a Clorox employee has an business with Clorox.
interest of any kind in the business partner’s
organization. Ownership of less than 1% of Data privacy and security: Business partners
a public company’s outstanding shares need must ensure that they, their affiliates and
not be disclosed unless it might influence their workers comply with all applicable laws
judgment or decisions. and regulations concerning the collection, use
and protection of personal information when
Minimize gifts and avoid offers of hospitality: conducting business for Clorox. Personal
Business partners must ensure that the information includes information that
acceptance or giving of any gift or offer of relates to an identifiable individual. Personal
hospitality when performing Clorox business information is only used for purposes that
is not and cannot be construed as an attempt are stated in the privacy notice. Business
to secure favorable treatment from or to any partners must take appropriate steps to
party. Business partners and their family safeguard confidentiality and privacy of
members must not accept or give any gift or personal information of individuals. Business
offer of hospitality exceeding a nominal value partners must not access, use or disclose
when conducting Clorox business. personal information in a manner that is not
compatible with the context in which the
Prohibit animal testing: Business partners personal information was obtained by or on
must ensure that they do not conduct, or behalf of Clorox, or otherwise not aligned with
cause third parties to conduct, any animal Clorox’s expectations based on the business
testing with products, raw materials or relationship with Clorox.
components of finished products supplied
to Clorox, unless such testing is disclosed in
writing to Clorox in advance and mandatory
under applicable laws.
CLO ROX BUSINESS PART NER CODE O F CO N DU CTDO THE RIGHT THING. CLO ROX BUSINESS PART NER CODE O F CO N DU CT
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