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Risk Mapping

Tier 1 Supplier Program Risk Assessment: Hershey used the Risk Segmentation tool developed in partnership with Verité to

assess all our Tier 1 raw material and packaging suppliers as well as co-manufacturers, co-packers, licensees and labor service

providers. We assessed more than 1,300 suppliers and 100% of spend in the aforementioned areas through this tool to develop

a prioritized list for due diligence.

Priority Ingredients and Materials Risk Assessment: In addition to our Tier 1 suppliers, Hershey uses the Risk Segmentation

tool to assess risks across the full value chain of our ingredients and materials. In 2020, we conducted an internal gap analysis

to assess which risks our Responsible Sourcing specific ingredient and material policies and programs currently address.

Through this, we defined priority ingredients and materials which will be revisited annually to assess possible reprioritization

based on i) changes in our supply chain, ii) developments in the environmental and human rights strategies, and iii) changes in

sustainability risks.

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"Hershey performs due diligence on our own facilities and on high-risk suppliers based on the results of our risk assessment process described above.

• Onsite Audits:.... • Worker Voice Surveys:......"

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"Our Responsible Sourcing Supplier Program (“Supplier Program”) verifies our Tier 1 suppliers’ compliance with our Supplier Code. 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."

"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"

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"Pre-Qualification Process: In 2021, we assessed 32 potential suppliers and licensees through our new human rights risk screening as part of our supplier qualification process."

"Hershey has also developed a more comprehensive approach to human rights due diligence in priority ingredients, including cocoa, palm oil and sugar. This due diligence process includes country of origin risk assessments, supplier sustainability assessments, and manufacturing site risk assessments using the SMETA audit protocol. We work with our suppliers to create action plans based on results from these various assessments."