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Stock exchange symbol: (MDLZ:US)

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

Yes. [link]

Additional policies:

  • Corporate Responsibility Expectations for Direct Suppliers and Supplier Contract Provisions: [link] [link]
  • Supply Chain Transparency and Labor Practices: [link]
  • Palm oil position statement: [link]
  • Cocoa Life approach – child labor update: [link]
  • Cocoa Life gender action plans: [link]

How are human rights governed in your company?

Human rights fall within the scope of our Board of Directors Committee responsible for public affairs: [link]

How are human rights managed within your company?

Compliance and Integrity Group: responsible for overseeing our code of conduct and employee training and communication about it, as well as providing guidance and support to the commercial groups and global functions (e.g., Procurement) who are responsible for implementing our statement on human rights, corporate responsibility guidelines and corporate responsibility expectations of direct suppliers.

Procurement: implementing our corporate responsibility expectations through contract requirements with direct suppliers; ethical trade audits of tier-one suppliers (AIM-PROGRESS); embedding additional requirements in procurement process for relevant commodities, for example our palm oil action plan.

Chocolate category: implementing the Cocoa Life gender action plan and child labor approach

External affairs: stakeholder engagement (see below)

Human resources: provides direct and indirect support to the company so that we respect human and labor rights in our operations.

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?

Our approach to stakeholder engagement is summarized on our corporate website: [link]

Update 2016:

Following extracts from ‘The Call for Well-Being Progress' Report 2015 ([link]):

“Partnership is the key to lasting change. Cocoa Life integrates the work of stakeholders to achieve common goals (including gender equity and the elimination of child labor in the cocoa supply chain) in ways that are relevant and tailored to Cocoa Life farming communities around the world. We work with communities, suppliers, non- governmental organisations and national cocoa authorities – including the Ghana Cocoa Board (COCOBOD), Conseil du Café-Cacoa in Côte d’Ivoire and the Indonesian Coffee and Cocoa Research Institute (ICCR) – to build lasting change.

Together, we implement national strategies for sustainable environmental management, including the United Nations Collaborative Programme on Reducing Emissions from Deforestation and Forest Degradation (REDD+), ensuring that field – level realities feed into national dialogues and policies.

The Cocoa Life program has also brought together a range of other partners including CARE International, Save the Children, Solidaridad, Voluntary Services Overseas (VSO), and World Vision, to ensure holistic development for farm families and empowerment of farming communities.

Cocoa Life Advisory Members

We work with a group of advisors and strategic partners from outside of the business to help develop our approach and provide oversight of the implementation of Cocoa Life (including) Andrew Bovarnick, Lead Natural Resource Economist and Global Head of the United Nations Development Programme’s Green Commodities Program, Aidan McQuade – Director of Anti- Slavery International, the World’s leading anti- slavery charity, David McLaughlin- Managing Director and Vice President of Agriculture at World Wildlife Fund and specialist in sustainable supply chain transformation, (and) Mil Niepold –mediation expert of The Mara Partners, focused on finding solutions to social and human rights issues through dialogue.”

Palm Oil (p.23)

“We believe progress in the palm oil sector requires us to go well beyond our own supply chain to achieve sector-wide change involving all participants in palm oil. That’s why we use our position as a global company to help catalyze change across the industry through broad scale partnership and engagement. One example is our support and collaboration with the United Nations Development Programme (UNDP), the Government of Indonesia, and other partners to develop the Indonesia Sustainable Palm Oil (SPO) Initiative. The initiative aims to develop national capacity to promote and scale up sustainable palm oil by strengthening smallholder farmers, supporting national policy reform and reducing deforestation through public-private partnerships. In addition, we co-chair the Consumer Goods Forum’s Palm Oil Working Group – which published palm oil sourcing guidelines for members during 2015 – and we serve on the Roundtable for Sustainable Palm Oil (RSPO) Board of Governors.

Within our supply chain, we are tackling through our Palm Oil Action Plan, which engages our suppliers to implement traceability and more sustainable production practices.

Working with World Wildlife Fund and the UNDP, we developed an action plan in 2014 outlining steps needed to ensure the palm oil we buy is produced on legally held land, does not lead to deforestation or loss of peat land, respects human rights – including land rights – and does not use forced or child labor. The plan will be updated during 2016 to recent progress made to date.

Our approach was driven by growing concerns regarding the long-term environment and societal impacts of palm oil production, including deforestation and human rights. In 2013, we achieved our goal of having RSPO coverage of 100 percent of the palm oil we buy . We achieved this through a combination of RSPO-certified oil and Greenpalm certificates that support sustainable production”.

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

The company selected the following from a checklist:

  • Health (including workplace health & safety, prevention of pollution)
  • Workplace diversity / non-discrimination
  • Women
  • Children (including child labour)

Update 2016:

The company selected the following from a checklist:

  • Health (including workplace health & safety, prevention of pollution)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Freedom of association and trade union rights
  • Women
  • Children (including child labour)

Actions on women

Our Cocoa Life program has embedded gender and child labor as cross-cutting themes. Our ultimate aim is to source all our cocoa sustainably, mainly via Cocoa Life, our $400-million, ten-year program to empower cocoa farmers, in thriving communities, at scale. For more information, see:

  • Cocoa Life approach – child labor update: [link]
  • Cocoa Life gender action plans: [link]

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

Our corporate strategy to Protect the Well-being of People and the Planet includes four focus areas: sustainability, mindful snacking, community and safety of our people and products. Our 2013 progress report summarizes our approach and reports progress made against our goals: [link]

Progress with our Cocoa Life program will be reported on: [link] according to the verification and reporting framework we published in June 2014: [link]

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?

As part of our compliance and integrity program, we enable people to speak up within the company and from outside. Details of the various ways to file reports are listed on our corporate website. Resulting investigations are reported to members of our executive team and the Audit Committee of the Board of Directors.

In 2013, our compliance and integrity group received more than 1,400 contacts from around the world through our "Speaking Up" channels. These contacts included questions about our compliance policies and program or matters that we referred to other departments for handling. We received reports of misconduct that required investigation. Some of these matters resulted in disciplinary action, including the separation of people from the company when appropriate.

See: [link]

Update 2016:

Key extracts:

Mondelēz International Compliance and Integrity ([link])

“We expect employees to ask questions and raise concerns about business practices when they see something they think might be wrong. There may be times when employees are not comfortable speaking with their supervisors, business integrity officers or human resources contacts, or simply wish to remain anonymous. Consistent with applicable local law, we have a toll-free and in some countries a collect call/reverse charge telephone HelpLine and an online version WebLine so that our employees can confidentially and, if they wish, anonymously report instances of suspected wrongdoing or ask questions about compliance matters. Our HelpLine operates in more than 90 countries”

“In 2015, our business integrity group received more than 1,700 contacts from around the world through our "Speaking Up" channels. These contacts included questions about our compliance policies and program or matters that we referred to other departments for handling. We received reports of misconduct that required investigation. Some of these matters resulted in disciplinary action, including the separation of people from the company when appropriate.”

“ To make sure that senior management and the Board of Directors are aware of any potentially significant matters, our business integrity group reports investigations to members of our executive team and the Audit Committee of the Board of Directors.”

Statement in Opposition to AFL CIO Proposal ([link])

“If an employee reports a violation, we will investigate it fully. Conducting independent, efficient and effective investigations is vital to our commitment to effective corporate governance and an environment that respects human rights. Furthermore, anyone who retaliates against another employee for raising a concern in good faith will face discipline, which may include termination. People outside of the Company may also bring concerns to our attention using our Integrity HelpLine or Integrity WebLine, mail or email”.

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

  • International Cocoa Initiative – Board member
  • AIM PROGRESS – active member of AIM-PROGRESS and member of SEDEX

Update 2016:

Examples of these include multi-stakeholder initiatives such as the Fair Labor Association, Global Network Initiative, Voluntary Principles on Security & Human Rights; industry initiatives such as the Electronic Industry Citizenship Coalition; UN Global Compact; other international, regional or local initiatives.

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.

We are aware of the UN Guiding Principles and have discussed their implications with key managers within the business. The initiatives listed below have been implemented since 2011, though they are responses to issues relevant to our business rather than the Guiding Principles specifically:

Cocoa Life approach – child labor update: [link]

Cocoa Life gender action plans: [link]

Palm oil position statement: [link]

Update 2016:

Cocoa Life: Empowering Cocoa Farmers and Communities 2015 Progress Report: [link]

Children at the Heart: Assessment of child labour and child slavery in Côte d’Ivoire’s cocoa sector and recommendations to Mondelēz International [link]

Children at the Heart: Assessment of child labour and child slavery in Ghana’s cocoa sector and recommendations to Mondelēz International [link]

Signatory to the UN Women’s Empowerment Principles [link]

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

We do business in many countries. Consequently, we experience many potential human rights issues and opportunities. Within our four walls, we start with our commitment to comply with the law and our corporate policies which stress the importance of safety, non-discrimination and no harassment. We also have meaningful standards for co-manufacturers and suppliers (noted above).

Beyond this, many issues are complex, requiring multiple stakeholders - including governments and NGOs as well as private companies - to work together to resolve.

We focus where we think that we can have meaningful impact, such as Cocoa Life, our $400 million program to empower farmers and create thriving communities in our cocoa supply chain. Through Cocoa Life and other elements of our strategy to Protect the Well-being of People and the Planet, we work with many experts to help us tackle these issues, since we recognize that we cannot solve these challenges alone.