THE HERSHEY COMPANY HUMAN RIGHTS POLICY ©The Hershey Company 2021COVID-19: Finally, the COVID-19 pandemic has only underscored the importance of protecting and promoting human rights and the need to urgently deploy resources to those most impacted. We used the guidance of the UNGPs to identify and help address broad COVID-19 related human rights vulnerabilities amongst workers in our supply chain as well as our own employees. More information on our Response to COVID-19 can be found here.Due DiligenceHershey performs due diligence on our own facilities and on high-risk suppliers identified through our risk assessment process described above. Hershey Facilities: Hershey facilities undergo the Sedex Member Ethical Trade Audit (SMETA) 4-Pillar audits on at least a three-year cadence, and more frequently as needed per customer requests. Zero instances or evidence of forced or child labor identified through these audits to date. Tier 1 Suppliers: Our Responsible Sourcing Supplier Program verifies our Tier 1 suppliers’ compliance to our Supplier Code of Conduct. The program is aligned with our saliency assessment of our most significant human rights issues and leverages third-party verification tools, including self-assessment questionnaires (SAQ) and independent third-party audits to check compliance. Suppliers in Hershey’s program are required to complete or update their facility’s Sedex SAQ or equivalent on an annual basis and undergo the SMETA 4-pillar social compliance audit or equivalent on a cadence determined by risk and historic performance. The Program also promotes ongoing training and capability-building and works to drive suppliers’ continuous improvement.When a Supplier Code of Conduct violation is identified, the Hershey Global Responsible Sourcing team reviews the findings and suppliers are asked to develop a corrective action plan that includes addressing the root cause of the issues. A follow up audit is then required to verify that the violation has been addressed. In instances where a supplier is unwilling or unable to remediate violations in the appropriate timeframe, Hershey reserves the right to suspend or remove the supplier.In 2020, 82 initial, periodic and follow-up audits were completed by high-risk suppliers. The top three categories of non-compliances identified through audits included health and safety, working hours, and wages & benefits. All non-compliances require a corrective action plan to be closed out via a desktop or follow up onsite audit. More information about the results of our Tier 1 Responsible Sourcing Supplier Program can be found in ourSustainability Report. Zero instances of forced or child labor have been identified amongst Tier 1 suppliers to date.Responsible Recruitment: Our Responsible Recruitment and Employment program verifies labor service providers’ compliance with our Responsible Recruitment Policy and our commitment to the Employer Pays and Priority Industry Principles. Suppliers in the program are required to complete a recruitment specific self-assessment questionnaire and corrective action plan for identified non-compliances and receive access to training through the Responsible Labor Initiative E-learning Academy. Suppliers are further assessed via audits of Hershey’s own facilities. In 2020, Hershey assessed 30 labor service providers in India, Malaysia, and the United States and identified 25 findings on recruitment-related policies and management practices. Approximately 25% are fully remediated with the remainder in progress, supported by training through the Responsible Labor Initiative E-Learning Academy. Zero instances of forced or child labor have been identified to date

Hershey Facilities: Hershey facilities undergo the Sedex Member Ethical Trade Audit (SMETA) 4-Pillar audits on at least a three-year cadence, and more frequently as needed per customer requests. Zero instances or evidence of forced or child labor identified through these audits to date. Tier 1 Suppliers: Our Responsible Sourcing Supplier Program verifies our Tier 1 suppliers’ compliance to our Supplier Code of Conduct. The program is aligned with our saliency assessment of our most significant human rights issues and leverages third-party verification tools, including self-assessment questionnaires (SAQ) and independent third-party audits to check compliance. Suppliers in Hershey’s program are required to complete or update their facility’s Sedex SAQ or equivalent on an annual basis and undergo the SMETA 4-pillar social compliance audit or equivalent on a cadence determined by risk and historic performance. The Program also promotes ongoing training and capability-building and works to drive suppliers’ continuous improvement.

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"Farmers and farmer groups also receive independent announced and unannounced audits from third-party certification bodies."