Pg. 5

“Risk Assessment General Mills partnered with Shift, the leading center of expertise on the UN Guiding Principles on Business and Human Rights, to assess our salient human rights risks. We conducted an initial assessment of human rights-related issues inherent to a complex supply chain like General Mills to identify and prioritize future due diligence on the most salient human rights risks to people throughout our value chain. The Shift assessment began in fiscal 2020 and was completed in fiscal 2021.

This initial assessment was conducted in line with the UN Guiding Principles on Business and Human Rights and included:

Desktop research including a review of all relevant internal policies and programs underway, Internal stakeholder interviews with individuals from across the company, External stakeholder interviews of leaders from non-profit organizations, Workshops with internal stakeholders to review research findings and prioritize the list of salient issues, Peer benchmarking”

pg. 7

“From fiscal 2018 to fiscal 2020, inherently high-risk Tier 1 direct suppliers were asked to complete a self-assessment questionnaire followed by an audit for the subset of Tier 1 suppliers identified as the highest risk suppliers. In fiscal 2021, we simplified our program by eliminating the self-assessment questionnaire and only require a SMETA complaint audit to decrease supplier time and resource requirements and improve the effectiveness of the program.”

For fy 2021 self assessment questionnaires are no longer used. Instead a SMETA (SEDEX) audit is used. P. 7