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pg. 10

"Assess & Remediate: Across all three of our programs, we use customized approaches to assess risk and where issues are identified, we have processes in place to support remediation – by Mars and through suppliers."

"We will continue to evaluate our facilities on a routine basis while expanding our efforts to address potential risks. We engage independent auditors with expertise in labor issues to assess our human rights performance in our workplaces."

pg. 11

"We conducted new assessments at 48 manufacturing sites across 17 countries in 2020, using a remote approach to continue due diligence even when COVID-19 restricted on-site access"

It states of an assessment tool but the tool is used to assess suppliers' compliance and not modern slavery risks.

pg. 12

"We assess the sustainability performance and social compliance results of prioritized suppliers using the EcoVadis online platform, leveraging this widely recognized supplier evaluation tool while also unlocking increased visibility and insights for Mars and our suppliers to put into action."

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A foundational step in our human rights due diligence approach is supply

chain mapping and traceability analysis, which provides us with essential

information about our extended supply chains. As we increase our

understanding and level of traceability, we work with partners such as Verité

and Verisk Maplecroft to better understand human rights risk at the country

and regional level.

We use publicly available data from sources such as the U.S. Department of

Labor, United Nations Development Program, public media and civil society

reports, and proprietary analysis provided by Verisk Maplecroft’s team of

human rights risk analytics experts. This includes the identification of unique

regional risks, such as the significant migrant labor workforce in the Middle

East. This analysis drives the creation of human rights risk scorecards that

inform the development of our human rights action plans.

Based on the specific risks identified, our global human rights team advises

and supports colleagues across the business on additional due diligence tools.

This due diligence, often implemented with independent human rights

experts, may include further desk research, validated self-assessment

questionnaires, audits, or human rights risk assessments at specific sites and

supply sheds.8