Supply Chain

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 vice president – Sustainability, with executive oversight by our senior vice president – Chief Product Supply 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.

Ethical Practices

Our sustainability strategy covers how we work with our business partners on key issues such as ethical business conduct and practices. We are committed to driving environmental and social compliance, workplace safety and quality assurance, as these are all integral to the long-term success of our company and our partners. We also have grievance mechanisms available, including the Clorox compliance hotline, to ensure that individuals have a forum to raise concerns about compliance with the standards set out in our Codes of Conduct.

Supply Chain Risk and Auditing Program

Clorox’s formal risk assessment and auditing program for our direct material suppliers helps to identify higher risk suppliers and address concerns regarding adherence to the principles described in the Clorox Business Partner Code of Conduct. It also encourages suppliers to apply these same standards to their supply chains.

As part of the program, we conduct an annual assessment of our direct material suppliers using several criteria to identify suppliers at higher risk for social and/or environmental sustainability issues. We audit higher risk suppliers leveraging our membership in Sedex, a nonprofit organization which provides a globally recognized audit methodology to help ensure sustainable business and responsible sourcing practices. Suppliers are required to conduct or share their most recent Sedex Member Ethical Trade Audit (SMETA) four-pillar audit or approved audit equivalent. The audits, which are conducted by an independent third party, assess suppliers’ activities in the areas of labor rights, health and safety, environmental sustainability and business ethics.

For a supplier to remain in a good-standing with Clorox, they must appropriately address non-compliances identified during an audit in a timely and satisfactory manner.

Training and Risk Mitigation for Human Trafficking

To further our commitment to eradicating modern slavery and human trafficking in our global supply chains, we annually provide training to all global employees to assist in identifying and addressing potential risks of slavery and human trafficking in our supply chain. Additionally, for some supply chains we engage suppliers in the development of their own training and risk mitigation programs to combat human trafficking and slavery in global supply chains. Additional information about our efforts can be found in our California Transparency in Supply Chains Act and UK Modern Slavery Act disclosure statements.

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 determine and report whether the covered minerals, which may be necessary to the functionality or production of our products, were acceptably sourced from recycled or scrap sources in the Democratic Republic of the Congo (DRC) region; or have not originated in the DRC or adjoining countries. For a full explanation of our country of origin assessment, see our SEC Form SD Filing.

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Areas of Focus

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Supplier Footprint

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Forest Commodities

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Ethical Practices

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