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Responding department: Legal & Compliance

Stock exchange symbol: (K:US)

Kellogg provided the following introduction to its survey answers:

Every journey has a start.  Our human rights journey started over 100 years ago, when our company founder, W. K. Kellogg, established our company with a belief in the power of people, the power of relationships and the promise of tomorrow.  Mr. Kellogg was not only a great entrepreneur; he was one of the great philanthropists of the 20th century.  He gave away almost all his wealth and created the W.K. Kellogg Foundation, one of the world’s largest philanthropic organizations and also the single largest shareholder of Kellogg Company.  This foundation provides over $300 million dollars of support to children’s healthcare and education programs worldwide.  It is easy to see why people view Kellogg as a company with a soul.

The information in this survey highlights our commitment to making the world a better place.  This was W.K. Kellogg’s goal as he conducted business and supported philanthropy, and we intend to carry on his legacy for generations to come.

Does your company have a publicly available commitment to respect human rights?

We have expressed our commitment to human rights in our Global Code of Ethics, our Global Supplier Code of Conduct, the Global Supplier Code of Conduct Resource Guide and our Corporate Responsibility Report; all of which are publicly available at www.kelloggsupplier.com and www.kelloggcompany.com.

How are human rights governed in your company?

Human rights are governed collaboratively at Kellogg.  At the working level, it is managed by our Sustainability, Procurement, Legal, and Ethics & Compliance functions.  At senior leadership level, it is managed by our heads of Legal and Compliance, Human Resources and Global Supply Chain.  At a board level, it is managed by our Social Responsibility and Public Policy board sub-committee.

How are human rights managed within your company?

The day to day management of human rights is conducted at the working level, as described above. We have signaled the importance of human rights in a number of ways, including them into the documents listed under Question #1:

  • Requiring suppliers with significant Kellogg spend to certify compliance with our newly published Global Supplier Code of Conduct;
  • Including the Global Supplier Code of Conduct in supplier contractual obligations;
  • Including responsible and sustainable sourcing training in supplier events;
  • Training our procurement employees on the global issue of forced labor, slavery and human trafficking;
  • Providing ethics and compliance training to our  employees on human rights issues such as workplace diversity, discrimination, harassment, etc.;
  • Joining and leveraging AIM PROGRESS, a consumer goods forum of manufacturers and suppliers that promotes responsible sourcing practices; and
  • Using SEDEX, the Supplier Ethical Data Exchange, to verify our suppliers’ responsible sourcing compliance and using MapleCroft to identify areas of higher risk in the supply chain.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Some recent examples of our stakeholder engagement include our collaborative approach to developing our new Global Supplier Code of Conduct, our new Open for Breakfast initiative and our supplier diversity activities.  

  • As we were developing our Global Supplier Code of Conduct, we incorporated the viewpoints of AIM PROGRESS and Oxfam, an international organization that focuses on alleviating poverty and injustice, to ensure it addressed human rights in a manner that was compatible with international standards and current thought leadership.  The Ruggie principles were cited in our Global Supplier Code of Conduct Resource Guide for supplier engagement and understanding.
  • We recently started a new initiative, Open for Breakfast, which provides additional transparency to our stakeholders into how we produce and what we include in our foods as well as how we impact the human rights of our business partners and communities world-wide.  It also provides a forum for a robust dialogue around our aspirations, our commitments and our stakeholders’ questions and concerns.
  • Each year, we highlight our expectations that our suppliers will encourage diversity within their organizations and utilize diverse suppliers.  We segment our supply base, rate them by our internal supplier diversity metrics and recognize suppliers that demonstrate a commitment to diversity.  

Priority human rights issues: What are some of the priority human rights issues for your company?

Among the list provided, Kellogg has placed priority on women, workplace diversity / non-discrimination, sexual harassment, and forced labor and human trafficking.  For example, advocating the economic viability and opportunity of women has been incorporated into our Global Code of Ethics, Global Supplier Code of Conduct and into our supplier diversity and sustainability initiatives.  We are a signatory to the UN Women’s Empowerment Principles.  

In addition, we have placed significant emphasis and focus on the right for people to eat high quality, great-tasting, nutrient-dense food.  We believe everyone has a right to eat food that nourishes and enables them to thrive.  To address this critical human right, we launched Breakfasts for Better Days. This initiative focuses corporate investment on hunger relief programs that support breakfast for children and families.  We have committed to provide 1 billion cereal and snack servings to children and families in need around the world by the end of 2016.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

We annually communicate our human rights commitments, efforts and progress in our Corporate Responsibility Report and on our corporate website at www.kelloggcompany.com.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

We provide a variety of reporting mechanisms for our employees, customers, consumers and suppliers to contact our company.  For example, we have an Ethics Alertline, with web and telephonic capability, which is published in our Global Code of Ethics and our Global Supplier Code of Conduct.  Our manufacturing facilities have an additional employee grievance mechanism where complaints are reviewed and actioned as appropriate.   

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

At Kellogg, we believe in leveraging the power of collective action and joining the global community to effect social change on a broader scale.  In 2014, our Chairman and CEO, John Bryant addressed the UN Global Climate Summit.  We are a signatory to the UN Women Empowerment Principles.  We are long standing members of AIM PROGRESS, where Kellogg Company is involved in a workstream that is dedicated to improving human rights within global supply chains.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

The majority of the activities and initiatives stated in our response, such as referencing these principles in our Global Supplier Code of Conduct Reference Guide and engaging our supply chain on these issues, took place since June 2011.  These actions were taken, to some degree, in response to the UN Guiding Principles.  However, the actions highlighted in our response is part of the journey started by W.K. Kellogg - to make the world a better place by investing in people and leveraging relationships.  Caring about people and communities is part of the legacy we received from W.K. Kellogg.  So we are on a journey.  There is more to do and more to discover.  But we believe that our founder placed us on the right path; believing in and working for the promise of a better tomorrow.