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Responding department: Sustainability

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

Stand-alone “human rights” policy: Read our human rights policy: [link]

A reference to the company’s human rights commitment within another corporate policy (e.g. Code of Conduct or Sustainability Policy): Mars Supplier Code of Conduct (Code) sets forth the Mars guidelines and expectations with respect to key areas of responsible sourcing. Content in this Code is informed by the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work ([link]).

The Mars Principles in Action Summary includes this statement: “Mars respects human rights throughout our value chain and recognizes the principles of the United Nations Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.” ([link]).

How are human rights governed in your company?

Where is the lead responsibility for human rights located, and why?

In January 2015, we launched our new human rights policy and program. In 2015, we will appoint a new Human Rights Director to oversee the policy’s implementation in our operations and our supply chain. The Director will liaise with other functions to ensure human rights activities are aligned across the business. The Director will have overall accountability for implementation and communication of Mars’ human rights strategy.

Does any board member or board committee have oversight of human rights issues?

Executive oversight and responsibility for the implementation of our Human Rights Policy rests with our Global Leadership Team. At an operational level, this policy is implemented by Mars’ Human Rights Director, who reports to our Chief Sustainability Officer and advises the Global Leadership Team on human rights issues.

What is the relevance of human rights considerations to the company’s business model and strategy?

Mars, Incorporated aims to become the most mutual company in the world. This is guided by our Five Principles of Quality, Responsibility, Mutuality, Efficiency and Freedom, which are deeply rooted in our operating philosophy and guide the way we do business. Promoting respect for the human rights of everyone we touch is an essential part of Mutuality.

How are human rights managed within your company?

To ensure that we target salient impacts, where we can make the most valuable contribution, our due diligence will initially focus on two areas:

1. Our operations, where we have the most control and; 2. Sourcing, where our highest risks lie.

How are actual and potential human rights impacts identified and assessed?

For our operations, we will conduct a risk assessment for sites and factories to identify and prioritize the high-risk countries and the impacts within those countries.

For our supply chain, as a first step, we will focus on those areas where impacts are most severe and where we can make the biggest improvements. We will conduct pilot human rights impact assessments in two countrycommodities, based on independent country and commodity risk data.

We will prioritize human rights impacts based on severity of impact, external stakeholder feedback, Mars’ Sustainable Sourcing Strategy, supply security, and areas necessary to protect and build our freedom to operate.

What steps are taken to prevent or manage negative human rights impacts?

For our operations, following the risk assessment, our People and Organization Department will address areas for remediation in sites and factories and conduct training for relevant associates (including senior management) in the high-risk countries.

  • For our supply chain, following impact assessments, areas for remediation will be implemented by specific Commercial teams as part of their sustainable sourcing strategies.

How is the importance of human rights signaled to business partners?

  • Our Responsible Sourcing program provides the opportunity to align interests with our suppliers—ranging from small farming cooperatives to multinational corporations. This includes improving respect for human rights.
  • Our company-wide Supplier Code of Conduct captures the spirit of the way we do business and sets globally aligned standards for all our suppliers. These include 10 workplace standards that meet or exceed International Labour Organization guidelines. At a minimum, all new suppliers must sign the Mars Supplier Code of Conduct or share their policies and practices to demonstrate alignment with Mars’ expectations.
  • Our Responsible Sourcing team oversees Mars Responsible Sourcing program. Once we launch our human rights program, the team will address identified areas of human rights remediation for our suppliers, Tier 1 and above.

What training is conducted for staff and business partners?

  • In 2015, we will develop and implement training on human rights for new Associates and managers in high-risk countries

How does the company track the effectiveness of its actions on human rights?

  • We will audit and track the effectiveness of remediation actions taken within our operations and agricultural supply chain. We will also embed metrics to track and internally report on our performance to the Management Leadership Team and the Board

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?

The Human Rights Director will oversee all external stakeholder engagement, including origin visits, external collaborative initiatives, industry groups etc. This engagement will partly focus on ensuring that all Mars’ policies and position statements on human rights remain up to date and as effective as possible. We will also continue to report on our human rights progress and performance in our annual Principles in Action Summary. We will also validate our salient impacts with external stakeholders. Internally, all Associates will be engaged on human rights through regular communications and updates. The Essence of Mars training program, delivered to all new associates, will include training on human rights.

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

The company selected the following from a check list:

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Sexual harassment
  • Freedom of association and trade union rights
  • Women
  • Children (including child labour)
  • Indigenous peoples
  • Migrant workers

Actions on health

Suppliers: Mars Supplier Code of Conduct includes specific requirements and guidelines on health and safety and the environment. See [link]

Our operations: We have high safety standards in our factories and promote healthy living among office-based Associates. Read more: [link]

Actions on workplace diversity / non-discrimination

Suppliers: Mars Supplier Code of Conduct includes specific requirements and guidelines on maintaining workplaces that have fair and equal treatment and no discrimination.

Our Operations: We recruit and reward Associates based on capability and performance, regardless of age, gender, sexuality, ethnicity, religion, or physical ability. Read more: [link]

Actions on forced labour and human trafficking

Suppliers: Mars Supplier Code of Conduct stipulates that suppliers employs all employees on a voluntary basis and do not use any prison, slave, bonded, forced or indentured labor, or engage in any other forms of compulsory labor, or any other forms of slavery or human trafficking.

Actions on sexual harassment

Suppliers: Mars Supplier Code of Conduct requires that suppliers do not engage in physical, mental, verbal, sexual or any other abuse, inhumane or degrading treatment, corporal punishment or any form of harassment. Suppliers have to treat all employees with respect and dignity and comply with local legislation on disciplinary practices.

Actions on freedom of association and trade union rights

Suppliers: Mars Supplier Code of Conduct requires that suppliers respect the right of employees to form and join trade unions and bargain collectively in a lawful and peaceful manner, subject to and in accordance with applicable law.

Actions on women

Our operations: We strive to increase the proportion of women in Mars by 1% each year on average. In addition to our Women in Leadership program, we offer a specific global program for Women in Sales Leadership. We also provide mentoring circles for women in the U.S. Read more: [link]

Actions on children (including child labour)

Our Supplier Code of Conduct has specific requirements and guidelines prohibiting the use of child labor.  Suppliers have to maintain documentation of each individual’s date of birth or have legitimate means of confirming each individual’s age.

Our policy on child labor is available here: [link]

In 2013, Mars Chocolate entered into a public/private agreement with the International Labour Organization to introduce a Child Labor Monitoring System (CLMS) in select communities in the Soubré region of Côte d’Ivoire. Read more: [link]

Actions on indigenous peoples

Our Deforestation Policy, which applies to our beef, palm oil, pulp and paper, and soy supply chains. It requires our producers and suppliers to produce or purchase all raw materials from legal sources and to comply with our Supplier Code of Conduct. Producers and suppliers must respect the rights of all affected communities to give or withhold their free, prior and informed consent for plantation developments on land they own legally, communally or by custom. They must resolve land rights disputes through a balanced and transparent dispute resolution process and support farmers and plantation owners to comply with our Deforestation Policy.

Actions on migrant workers

Our Supplier Code of Conduct has specific requirements and guidelines on migrant laborers.

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

Tracking and transparency In order to measure progress internally, we will develop relevant metrics, including quarterly reporting on number of new Associates trained on human rights. We will also annually report on our performance to the Management Leadership Team and the Board Reporting and external communication We will report on our human rights progress and performance in our annual Principles in Action Summary (link) and on Mars’ website. We will respond to specific human rights concerns raised by civil society on a case-by-case basis.

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?

Associate grievances and concerns will be measured by the existing Ombudsman program and Associate Engagement Survey. The Mars Ombudsman program provides a confidential, independent and neutral channel of communication for Associates to express their concerns. The program, which is externally audited, makes recommendations to management based on key themes identified through the feedback. We are working to strengthen the programs’ effectiveness as human rights grievance mechanism. Read more: [link]

For suppliers, non-compliance with the Mars Supplier Code of Conduct can be reported through an online form: [link]

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

We are a signatory of the Harkin-Engel Protocol, which works towards the elimination of the worst forms of child labor
in the growing of cocoa beans and their derivative products from West Africa.

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.

In response to the UN Guiding Principles, we launched our human rights policy and program in January 2015. In accordance with the UN Guiding Principles on Business and Human Rights, this Policy is informed by the International Bill of Human Rights and the International Labour Organization's 1998 Declaration on Fundamental Principles and Rights at Work. In accordance with the UN Guiding Principles, we will implement a due diligence process to identify, mitigate and prevent adverse impacts on human rights and appropriate mechanisms for remediation.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

Mars’ human rights strategy was launched in January 2015; we will work with stakeholders to continue to evolve our human rights approach, and will update this Policy as lessons are learned.