Responsible Sourcing and Sustainability
We have a strong commitment to ethical business practices; treating people with dignity, respect and equal opportunity; and conducting business in a responsible way that promotes good stewardship of our planet. Business partners are expected to comply with our Business Partner Code of Conduct. The Code details our expectations regarding adherence to the Human Rights Commitment and other expectations related to human rights and labor, health and safety, the environment, and business conduct and ethics.
As part of our IGNITE Strategy, we are focusing on climate stewardship as one of our critical environmental, social and governance (ESG) priorities. This focus extends into our upstream supply chain, where we have committed to setting science-based scope 3 greenhouse gas emissions reduction targets that require us to engage heavily with our suppliers to reduce their carbon footprints. This priority is in addition to ongoing efforts to help ensure there is no deforestation in our forest commodity supply chains.
Our responsible sourcing and supply chain sustainability program – including our related commitments and progress – is led by our VP, Chief Sustainability Officer, with executive oversight by our EVP, Chief Growth Officer. The Nominating, Governance and Corporate Responsibility Committee (the NGCRC) of our board of directors oversees programs relating to corporate responsibility and sustainability ESG matters. Our full board also reviews and discusses ESG topics regularly – including progress toward meeting our specific ESG goals – and oversees risks, opportunities and strategy related to ESG issues that are priorities for our business such as sustainable supply chain management, product safety and other significant areas.
In looking at the forest commodities in our supply chain, we’ve identified wood-based fiber use and sourcing for our packaging as the areas where we can have the greatest impact on reducing the pressure on natural forests. As well, we recognize that responsibly sourcing palm oil ingredients plays a key role in protecting human rights while conserving the environment, including our forests.
Ninety percent of our fiber use is in our packaging, both the primary package that contains some of our products and the secondary packaging in which we ship our products. Our strategy to minimize the impact of our fiber sourcing leads with reducing the amount of fiber we use. Next, we strive to maximize recycled fiber to meet the majority of our needs. When virgin fiber is required for our packaging, we trace the fiber we purchase to the country of origin and seek sustainable forestry certifications to ensure responsible forestry practices have been followed.
In 2019, 99% of the fiber used in the packaging we purchased was recycled or certified virgin material, with 45% recycled fiber and 54% virgin fiber from certified sources.
Certifications for the volume of virgin material in the packaging we purchased included SFI (80%), FSC (15%), and PEFC (5%). We’ve made great progress in our commitment to recycled or certified virgin fiber, and we continue to work toward finding innovative ways to reduce the environmental impact of our fiber-based packaging as part of IGNITE, where we’ve set a goal for 50% combined reduction in virgin plastic and fiber packaging by 2030.
In addition to packaging, we use wood-based fiber in some of our products —namely Clorox® disinfecting wipes, Green Works® compostable cleaning wipes, Burt’s Bees® towelettes and Burt’s Bees® baby wipes. Although we don’t purchase this fiber directly, approximately 97% of the tree-based material in our wipes are from FSC certified sources.
The palm oil industry has a significant impact on biodiversity, climate change, people and communities. Clorox takes seriously our commitment to the responsible sourcing of palm oil ingredients and to enhancing our own and consumer packaged goods industry practices. To further our pursuit of industry change, in 2020 we’ve enhanced our commitments to better address deforestation and peatland protection, business ethics and human rights and traceability.
Clorox’s global purchases of palm oil ingredients are 99% palm derivatives. The amount and source fluctuates from year to year based on our business needs. This total reflects the low volume of ingredients containing palm oil, palm oil derivatives, or palm kernel oil derivatives that are sourced by Clorox from various suppliers. The palm derivatives we purchase contain derivatives of refined palm oil, made from the fruit, and palm kernel oil, made from the kernel or the pit of the palm fruit. These palm derivatives can be present in very small percentages as sub-components of surfactants, fatty alcohols, emulsifiers or fragrances in some of our bio-based and conventional cleaning products, food flavorings and fragrances or natural personal care products.
Clorox’s total purchased palm oil ingredient volume represents less than 0.003% of palm oil produced globally each year. While our use is small, we are committed to continuing to ensure our sourcing of palm-derived materials does not contribute to deforestation or infringe upon the rights of workers and indigenous peoples. Therefore, our goals and commitments extend globally to all types of palm materials and ingredients that we currently purchase, or will purchase in the future, for our manufacturing operations in all countries where we operate.
For our most recent progress update, click here.
Our Goal for Palm Oil Sourcing
Our goal is to be a leader in environmental sustainability. In conjunction with our IGNITE strategy environmental, social and governance (ESG) goals and our Environmental Policy, we have refreshed our palm oil commitments to ensure respect for human and labor rights, local communities and biodiversity throughout the palm oil supply chain.
Clorox is a member of the Roundtable on Sustainable Palm Oil (RSPO), a nonprofit organization that unites stakeholders from the palm oil industry, and is committed to continuing to support RSPO standards and certification as a means to drive Certified Sustainable Palm Oil (CSPO) and to contribute to the transformation of practices in communities to produce responsibly sourced palm ingredients.
- Source CSPO for palm oil and its derivatives through RSPO physical supply chains by 2025, and report on our progress through our RSPO Annual Communication of Progress (ACOP) and other public disclosures.
- Ensure suppliers sourcing palm oil and palm kernel oil in our supply chain have public sustainable palm oil commitments aligned with the RSPO Principles and Criteria, including what is commonly referred to as NDPE (No Deforestation, No Peat and No Exploitation):
- No deforestation and no development of high conservation value or high carbon stock areas
- No development on peat lands
- The protection of human rights including the respect for the rights of indigenous and local communities to give or withhold their free, prior and informed consent to operations on lands to which they hold legal, communal, or customary rights
- Public grievance process and response procedures for cases of non-compliance
- Continue to hold suppliers accountable to the principles outlined in our Business Partner Code of Conduct, including compliance with all applicable laws and regulations in the countries of operation, and respect for human rights throughout the value chain
- Continue mapping, tracing and/or monitoring the supply chain of our palm ingredient suppliers and ensure adherence to Clorox and their own sourcing commitments and practices
- Continue engaging with our suppliers, industry peers, shareholders, non-governmental organizations and other stakeholders to promote sustainable palm oil supply chains, including collaborations to strengthen certification and verification mechanisms
- Report annually on our progress against these commitments.
These commitments apply to all palm oil ingredients we purchase globally. Our ability to achieve these commitments depends heavily on the changing practices of the palm industry and the future market availability of the palm derivatives used in our products.
Clorox requires that our palm ingredient suppliers and their upstream supply chains fully support our ability to achieve the above commitments. They must:
- Source only CSPO through RSPO physical supply chains by 2025
- Incorporate our Commitment criteria in their supplier selection process
- Comply with all RSPO Principles and Criteria
- Comply with The Clorox Company Business Partner Code of Conduct.
Suppliers failing to reasonably meet above requirements or remediation plans (if applicable) will be subject to non-renewal and/or termination of contracts.
Business Ethics and Human Rights
Clorox holds direct suppliers of palm ingredients accountable to the following business practices listed in The Clorox Company Business Partner Code of Conduct. We also meet with priority suppliers further upstream, and expect all direct and indirect suppliers to meet or exceed our standards:
- Comply with all applicable laws and regulations in the countries of operation
- Prohibit child labor, forced and/or bonded labor
- Compensate workers in accordance with all applicable laws and regulations—including those pertaining to minimum wage, overtime, maximum hours, benefits and leave
- Prohibit discrimination, harassment and inhumane treatment in employment or occupation
- Create safe working conditions and a healthy work environment for all workers
- Respect workers’ rights to freedom of association and to collective bargaining
- Prevent and prohibit corruption, including extortion and bribery
- Use ethical recruitment practices, in which recruitment processes are documented and transparent, and costs charged to the workers are transparent, justified and legal
- Identify and implement efforts to reduce environmental footprints
- Provide safe work procedures and appropriate personal protective equipment to prevent chemical exposure, and where possible, eliminate worker exposure to harmful chemical, biological and physical agents.
Clorox is committed to establishing and maintaining traceability of our palm supply chains to first refiner and mill level. We recognize we must have visibility of the ingredient supply to ensure our palm commitments are effectively communicated and in practice throughout the supply chain to origin regions where palm is grown and harvested. We focus on our high volume priority suppliers (~85% of our purchases) and have greatly improved our traceability success by working closely with our suppliers and NGO partners. Our traceability work supports our efforts to educate suppliers throughout our supply chains as well as the verification of our sourcing requirements.
Below are the percentages by year of our priority supplier volume traced to first refiner and mill:
In 2020, Clorox worked with our NGO partner to conduct a supply chain risk profile to better understand specific supplier and regional risks in detail. We have been able to do this because of our advanced traceability efforts outlined above. We will continue to focus on engaging suppliers utilizing the 2020 risk assessment to ensure transparent NDPE policies and work on specific transformation activities that support a positive influence through the supply chain.
On The Ground Investment (Landscape Approach)
Clorox has supported Earthworm Foundation’s Areas for Priority Transformation (APT), a program advancing long-term, landscape-level sustainability transformation in the Indonesian region of Aceh Tamiang, Sumatrasince 2016.
The APT program:
- Focuses on deforestation in the Indonesia region of Aceh Tamiang
- Strengthens NDPE policies and practices by commercial actors
- Improves the livelihood prospects by communities
- Builds capacity of local government to conduct spatial planning and district development processes that are inclusive and data driven.
In 2019, Clorox increased its leadership efforts in APT, by joining the APT Coalition Team providing strategic input for supporting the multi-year strategy impacting forests, workers, livelihoods, industry and partnerships with governments, society partners and private sector actors and donors.
In 2020, we joined a new multi-stakeholder project, facilitated by Business for Social Responsibility, which focuses on ensuring safety and well-being of workers in palm growing and harvesting in Indonesia. We also supported a series of workshops to deepen understanding of labor issues and identified a set of palm oil producers in Indonesia who are committed to collaboration to improve plantation management practices related to working conditions and worker welfare.