Sustainability in our Supply Chain

We have a strong commitment to ethical business practices and treating people with dignity, respect and equal opportunity. We expect the same commitment from business partners. Our Business Partner Code of Conduct is critical to helping ensure our business partners’ commitments in these areas mirror our own. And our Responsible Sourcing and Sustainability program helps us assess our own upstream supply chain against social and environmental impacts.

Business Partner Code of Conduct

The foundation of Responsible Sourcing & Sustainability is our Business Partner Code of Conduct, which articulates our expectations of our business partners regarding human rights and labor, health and safety, the environment, and business conduct and ethics. Adherence to the Code is required to do business with us, and we believe it’s imperative to the long-term success of our company and our partners. All new contracts require material compliance with our code. Key Clorox business partners started self-certifying compliance to Supplier Code in 2011, with re-certification to our code in 2014, and subsequent re-certification expected regularly. Additionally, we support our code with site visits, self-assessments and third-party audits to ensure we are meeting our stated commitments. Our responsible sourcing and sustainability program plays an important role in helping us develop important partnerships to drive social compliance, sustainability, workplace safety and quality assurance.

Industry Collaboration

We continue to expand our involvement with various organizations and stakeholders to help drive responsible sourcing improvements throughout the consumer packaged goods industry.

One example is our participation with AIM-Progress, a forum for leading consumer goods manufacturers and suppliers to help improve responsible sourcing practices, build supply chain capability, share ethical sourcing audits and collaborate on human rights and other supply chain activities. Our collective action seeks to positively impact people’s lives through combined leadership of responsible sourcing practices throughout our supply chains. We are also a member of SEDEX and use Sedex Member Ethical Trade (SMETA) Audits for collecting and analyzing information on ethical and responsible business practices in the supply chain. Through our mutual recognition approach, our selected business partners complete one self-assessment and/or audit that may be shared with multiple customers, including AIM-Progress members. In this way, AIM-Progress manufacturers and suppliers, including Clorox business partners, concentrate their efforts on improving responsible sourcing practices through the supply chain and less on preparing for duplicative audits. In effort to advance collaboration in natural ingredient supply chains, we are members of Natural Resources Stewardship Circle, which focuses on developing unifying projects with values shared with our businesses and our suppliers to have a positive impact on the sourcing of natural ingredients for the beauty industry.

Training and Risk Mitigation for Human Trafficking

In support of the California Transparency in Supply Chains Act and UK Modern Slavery Act, we’ve trained more than 200 global product supply team members in identifying and addressing potential risks of slavery and human trafficking in our supply chain. Additionally, we are mentoring suppliers and customers in the development of their own training and risk mitigation programs to combat human trafficking and slavery in global supply chains.

Being Mindful of Conflict Minerals

We conduct annual assessments of our supply chain related to the use of conflict minerals (tin, tantalum, tungsten and gold). Based on these assessments, we determined that either (1) the covered minerals necessary to the functionality or production of our products were from recycled or scrap sources, or (2) we have no reason to believe these minerals originated in the Democratic Republic of the Congo or adjoining countries. See our SEC Form SD filing for a full explanation of our country of origin assessment.