pg. 2

"The Hershey Company approach to human rights due diligence is guided by the United Nations Guiding Principles (UNGPs)and is an ongoing risk management process that allows us to identify, prevent and mitigate human rights risks throughout our value chain"

pg. 3

"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."

"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."

pg. 6

"Joining the Responsible Labor Initiative (RLI), a multi-stakeholder, multi-industry initiative focused on ensuring that the rights of workers who are vulnerable to forced labor in global supply chains are consistently respected and promoted. Through our participation in the RLI, Hershey has the opportunity to leverage industry best practices and tools, including

training resources, risk assessment tools, and migration corridor data and research, among other resources. Participating in the RLI also allows Hershey to support advocacy efforts and larger initiatives to address the root causes of forced labor and recruitment-related issues. In 2020, Hershey leveraged the RLI E-learning Academy to train Hershey employees on forced labor and suppliers of labor services on responsible recruitment practices."