Responsible Soy Procurement Policy

Last Updated: September 2025

BACKGROUND

As part of Colgate-Palmolive’s (Colgate) strategy to combat climate change and biodiversity loss, we are committed to an environmentally and socially responsible global soy supply chain. Colgate recognizes that soybean is one of the key commodities responsible for the majority of deforestation globally, and is a signatory to the Cerrado Manifesto Statement of Support.

In Brazil, Argentina, and Paraguay, expansion of soybean production is driving loss of highly biodiverse forest and grassland biomes, including the Amazon, the Cerrado, the Chaco, the Atlantic Forest, and the Chiquitano. Action from the soy industry is urgently needed to halt loss of native vegetation and help maintain environmental and social values. 

Colgate uses soy oil, soy meal, and soy-based derivatives in some personal care products and Hill’s Pet Nutrition products. Our soy based materials originate in the United States, Europe and South America. To address the impact of soy on global deforestation, Colgate has joined the Consumer Goods Forum - Forest Positive Coalition. As a Coalition member, we support the Coalition’s actions to eliminate deforestation and forest conversion associated with commodity supply chains, including soy.  Aligned with other Coalition members, Colgate is committed to delivering on goals as established in the Coalition’s Soy Roadmap.

To support Colgate’s overarching No Deforestation Policy we have implemented this commodity-specific soy policy that outlines our commitment, vision and actions we are taking for the responsible sourcing of soy-based materials.

SCOPE

This policy applies to all direct soy-based materials sourced by Colgate operations, subsidiaries, and joint ventures worldwide. The policy commitments extend to all direct soy products and soy derivatives Colgate purchases from third party suppliers. Colgate requires suppliers to apply this policy throughout their soy supply chain, including all direct soy products produced, purchased, or traded, and all operations including landholdings, joint ventures, and third party suppliers.

In addition to direct purchased soy-based materials, Colgate also has indirect or embedded soy in our soy supply chain footprint, primarily as feed for animal-based products used in our Hill’s Pet Nutrition Products.  Beginning in 2021 we included indirect / embedded soy in the scope of this policy and initiated the process of engaging with embedded soy suppliers within that extended supply chain.  

The policy applies across all geographies globally where soy is originated. Pursuant to the policy, we will initially focus on soy products originating in South America, particularly the Cerrado and the Amazon in Brazil, and the Chaco in Argentina and Paraguay. These biomes are priorities due to the high rate of native vegetation loss driven by soy production, and their significant environmental and social values, including biodiversity, carbon storage, hydrologic services, and cultural value.

OUR COMMITMENT

Colgate aspires to build a transparent and responsible soy supply chain, and contribute to industry level transformation. We commit to eliminating exploitation and conversion of native vegetation from our soy supply chain, and promote the protection of areas of significant environmental and social value.

Our specific commitments in the soy supply chain are as follows:

• No deforestation and no conversion of native vegetation

• No exploitation of people or local communities

• Good agricultural practices

• Legal compliance

No Deforestation and No Conversion of Native Vegetation

We commit to eliminating conversion of native vegetation with significant environmental or social value from our soy supply chain. This commitment prohibits both deforestation of forested biomes such as the Amazon, and conversion of native vegetation in grassland or savannah biomes such as the Cerrado. Wherever possible, soy production should occur on already converted or degraded land.  By year end 2030, Colgate’s sourcing of soy based materials will be deforestation and conversion free (DCF).    For the purpose of reporting on deforestation and conversion free supply, Colgate will align with the Consumer Goods Forum - Forest Positive Coalition’s (CFG-FPC) Soy DCF methodology.

We will use High Conservation Value (HCV) concepts to guide implementation of this commitment. We expect suppliers and soy growers to identify and protect areas with attributes aligned with the six HCV values, including significant concentrations of biodiversity; landscape level ecosystems; rare, threatened or endangered ecosystems; areas providing important ecosystem services; and areas critical to the cultural identity and needs of local communities.  Colgate encourages landscape approaches and multi-stakeholder land use planning to identify areas of significant social and environmental value.

We recognize that HCVs have not widely been identified across soy producing regions, and a scalable methodology does not yet exist for implementation of the HCV methodology in the soy supply chain. We encourage the industry to promote development of a scalable methodology for identification of areas of significant environmental and social value, particularly in South America. Colgate welcomes solutions developed through multi-stakeholder collaboration, and is open to adopting such solutions for implementation of this policy.

No Exploitation of People or Local Communities

Respect for Human and Labor Rights

Guided by the UN Declaration on Human Rights and the UN Guiding Principles on Business and Human Rights, under a policy of no exploitation, Colgate requires its suppliers at all tiers and across all global operations at a corporate group level to commit to: no child or forced/bonded labor; no unethical recruitment practices; and no discrimination or harassment in its supply chain. Suppliers must be compliant with all relevant laws and regulations and additionally commit to working conditions, health and safety, hours and wages that are in accordance with International Labour Organization standards. Written contracts, where required by law, will be provided to all workers in a language that they understand that details the nature of the work, rate of pay and pay arrangements, working hours, vacation and other leave, and other benefits of employment. Freedom of association and right to collective bargaining will also be guaranteed. Colgate supports the Consumer Goods Forum (CGF) Industry Resolution on Forced Labor and the Priority Industry Principles in which every worker should have freedom of movement, no worker should pay for a job and no worker should be indebted or coerced to work.  Colgate is a member of the CGF - Human Rights Coalition.

Land Tenure Rights

Colgate suppliers will respect the legal or customary land-tenure and use rights of indigenous and local communities, as well as their rights to give or withhold their free, prior and informed consent (FPIC) for operations affecting their land or resources.  Soybean growers in Colgate’s supply chain are expected to demonstrate legal title for the property where soybean originates, including official documents demonstrating the farm boundaries. Suppliers are expected to gather information about social conflict in their soy supply chain, and ensure they are not sourcing from growers involved in illegal land acquisition or conflict with local communities.

Conflict Resolution

• Colgate’s suppliers will resolve complaints and conflicts through a mutually agreed upon and transparently documented system that is implemented and accepted by all relevant parties.  

• Violence or retaliation by suppliers or upstream producers against human rights defenders or local communities will not be tolerated.

• Colgate acknowledges the human rights risks of those taking action to defend such rights. Human rights defenders play a critical role in the protection of human and labor rights and protection of the environment. A “human rights defender” can be any individual, community group or organization advocating for the protection and respect of human rights, including workers rights, land rights, freedom of expression, rights to livelihoods and the right to justice and the rule of law.  We believe in the protection of human rights defenders and do not tolerate threats, intimidation, physical or legal attacks, or reprisals against them.  Aligned with the UN Special Rapporteur on the situation of human rights defenders, we believe that both states and businesses should actively support and promote the role of human rights defenders and speak out when human rights defenders are targeted as a result of their important work.  We will take action as appropriate to address adverse impacts on human rights defenders within our own operations or as a result of our business relationships. We will seek to collaborate with other companies, civil society, worker representatives and trade associations as well as governments and other stakeholders to protect and respect human rights and those who work to defend the human rights of others. 

Good Agricultural Practices

Colgate encourages implementation of regenerative agriculture practices at the farm level. Good agricultural practices should contribute to improved soil health, carbon sequestration, and on-farm biodiversity. Relevant practices include responsible use of fertilizers, pesticides, and herbicides; responsible use of water; soil health practices; personal protective equipment; responsible waste management; and management of soil to prevent erosion and build soil health. Suppliers are expected to encourage good agricultural practices among soy growers, gather information about farmer practices, and share guidance on best practices appropriate to the local context.

Legal Compliance

Colgate commits to compliance with all applicable laws and regulations at the national and international levels. Suppliers must demonstrate compliance with legal requirements, e.g. the Brazilian Forest Code, and registration and compliance with the Rural Environmental Registry. We will exclude any soy produced on illegally deforested or converted land from our supply chain.

Our suppliers are expected to apply this policy at the corporate group level across all operations including landholdings, joint ventures and third-party suppliers.

Furthermore, it is expected that all suppliers of forest risk commodities, including palm oil, soy, pulp & paper packaging and beef and beef tallow; implement a NDPE policy aligned with our No Deforestation policy and this commodity specific soy policy.

TRANSPARENCY AND TRACEABILITY

Colgate is committed to transparency in the implementation of our Responsible Soy Procurement Policy.  Colgate strives to achieve visibility over our direct soy supply chain by gathering traceability information for our direct soy products. The objective of traceability is to identify soy origins and associated risks and facilitate monitoring. The ultimate goal of traceability is to reach the farm level in countries at higher risk of deforestation and conversion.  However, Colgate will gather interim levels of traceability while the industry builds greater visibility. Colgate will regularly report progress on traceability.

Colgate engages all direct soy and soy derivative suppliers on both policy implementation and CGF Forest Positive Coalition expectations, as well as traceability aligned with the Forest Positive Coalition soy road map.  This engagement accounted for approximately 58,000 MT  of soy and soy-based derivatives (glycerin), representing more than 99% of Colgate’s direct soy volumes.  Based on the Round Table on Responsible Soy (RTRS) calculation methodology, we have calculated our direct soy footprint shown in the table below.

Soy footprint in metric tons (2024 volumes):

The pathway to sourcing responsible soy materials differs depending on the type of material purchased and the risks associated with the countries of origin. In recognition of the differences among supply chains, Colgate reports progress on soy meal and oil separate from soy based glycerides. Through our supplier engagement and mapping exercise, we have been able to map 87.9% of our soy footprint to the country of origin and 86.4% to soybean crusher.  

Soybean Meal and Oil - Traceability to Country of Origin and Crusher (2024 volumes):

^{Note: Within the volumes listed above, 15.4% were traceable under an accepted control system, with the remainder being self disclosures without an associated control system.}

Soy Derived Glycerides Traceability to Country of Origin and Crusher (2024 volumes):

^{Note: The volumes listed above are based on self disclosures without an associated control system.}

We have identified that 35.6% of our traceable volumes originate from soybeans grown in high risk countries in South America (this excludes the 13.1% from unknown origins). We struggle to achieve high levels of farm traceability in our glycerides supply from South America but have identified the presence of these high risk biomes in our supply chains: Amazon, Cerrado and Gran Chaco. Our soybean meal and oil suppliers are able to provide Proterra certificates for 100% of the volumes that originate from South America. 

Traceability from At Risk Countries [Brazil, Argentina, Paraguay] (2024 volumes)

^{Note: Within the volumes listed above, 7.6% were traceable under an accepted control system with the remainder being self disclosures without an associated control system.}

WORKING WITH OUR SUPPLIERS

Colgate views our suppliers as partners in achieving a responsible soy supply chain and we collaborate with suppliers throughout the supply chain to implement our commitment. In 2024, we published an updated version of our responsible soy policy.  Suppliers of direct soy products to Colgate are required to meet the requirements of this policy and implement equivalent policies for their own operations. In addition to traceability, in 2024, we engaged our top direct soy and soy derivative suppliers, representing 99% of Colgate’s volume, on policy implementation and alignment with the Forest Positive Coalition (FPC) expectations.  

Colgate’s top direct soybean meal and oil and suppliers include:

Colgate’s top direct soy-based glycerin and suppliers include:

Priority upstream intermediate soy-based derivative suppliers include:

In 2024, we conducted a follow-up survey of suppliers to measure alignment with elements of Colgate’s policy and the FPC Soy Road Map expectations. The cumulative results of the 2022 and 2024 surveys are presented in the table below.

<sup>1. Eleven suppliers were evaluated in 2024.
2. Eight suppliers were evaluated in 2022.</sup>

We expect our suppliers to provide traceability data and to achieve traceability to the appropriate level of the supply chain based on country of origin. We also expect suppliers to implement no deforestation or conversion policies for their own operations and their supply chain. We will continue to engage with and measure performance against our policy expectations.  In the event of non-compliance with this policy, Colgate will work with suppliers to create an action plan outlining time bound commitments to meet our requirements. If a supplier is unable or unwilling to take the necessary actions to conform to the expectations outlined in our policy, Colgate may terminate the business relationship with the supplier.

Indirect / Embedded Soy

In 2020, we conducted an initial soy footprint for our indirect soy volumes, which we have recently updated to reflect our 2022 volumes.  During 2021, working with our partner Earthworm Foundation, we conducted an initial engagement on policy implementation with one of Colgate’s largest suppliers of poultry based materials, representing approximately 20% of our embedded soy footprint.  Based on our 2022 indirect/embedded soy analysis we identified that approximately 98,000 metric tonnes fall in the indirect soy footprint.  For our indirect soy footprint, we followed RTRS soy conversion and footprint calculation methodology and the Consumer Goods Forum (CGF) Soy Measurement Ladder (Tiers Definitions).  Colgate’s Soy footprint, by % tier, is shown in the table below indicating that our indirect soy footprint represents approximately 86% of Colgate’s total soy footprint.  

Colgate’s Soy Footprint by Tier (%):

MONITORING AND VERIFICATION

The goal of this policy is to monitor and verify direct  supplier compliance. Traceability information informs the appropriate monitoring and verification approach based on country of origin and subnational jurisdiction. Colgate expects suppliers to demonstrate compliance with the policy in their own supply chain, including conducting geospatial monitoring and verification of their supply base. We will give preference to suppliers whose soy products have been independently verified to comply with Colgate’s soy policy.

Our step-wise approach to verifying compliance is aligned with the CGF-FPC Soy Road Map. In 2024, Colgate and EF began implementing the Deforestation and Conversion Free (DCF) Methodology developed by the CGF-FPC to categorize volumes from suppliers. In addition to tracking DCF compliance, we monitor several non-DCF categories such as “Progressing” towards one of the DCF Methodology pathways which indicates a supplier is providing material that is low risk, but key elements of verification are missing. We use these categorizations to prioritize our engagement and support of suppliers as they work to close gaps in policy compliance. Colgate’s current DCF score on soy based volumes is 7.1% with 7.6% Progressing towards DCF and an additional 45.8% from low risk countries which do not yet have an accepted approach to addressing DCF risks. Below is an overview of the categorizations over the previous two years.

Soybean Meal and Oil - Deforestation & Conversion Free (DCF): 

<sup>1. Volumes certified under an accepted sustainability standard. In this case, the Proterra certification standard, site level mass balance.
2. Volumes from a jurisdiction with negligible risk of native vegetation conversion to soybean production. In this case, Colgate has identified the jurisdictions in Europe to be negligible risk relative to materials from South America. The traceability control systems used by our suppliers are various 3rd party standards which ensure country of origin.
3. The exact criteria for farm-level DCF is under discussion with key soy stakeholders. Generally, this approach utilizes an accepted spatial monitoring system to establish no conversion of native vegetation on each soybean farm.
4 Volumes from suppliers that demonstrated significant progress on one of the three DCF pathways. In this case, the supplier sources from European countries but lacks an accepted control system.
5. Volumes from countries that have been identified as low risk utilizing the Earthworm Foundation Country Priority Matrix and where no accepted approach exists for addressing DCF risks. In this case, the volumes are from suppliers in the US and Canada without an accepted control system.</sup>

Soybean Derived Glycerides - Deforestation & Conversion Free (DCF):

^{6 Volumes from suppliers that demonstrated significant progress on one of the three DCF pathways. In this case, from a supplier progressing towards Farm Level DCF but without an accepted control system.
7 Volumes from countries that have been identified as low risk utilizing the Earthworm Foundation Country Priority Matrix and where no accepted approach exists for addressing DCF risks. In this case, the volumes are from suppliers in the US and Canada without an accepted control system.
8 Volumes traceable to countries in South America where suppliers have not demonstrated significant progress towards one of the DCF pathways.
9 Volumes from a supplier unable to provide traceability for 2024 which is not providing volume in 2025.}

TRANSFORMATION

Colgate seeks to support projects that contribute to improving the lives of farmers, communities and ecosystems connected to our soy supply chains in at-risk countries. Colgate has mapped our soy supply chains to at least 100 municipalities in Brazil and nearly half of which are on the CGF’s list of municipalities at risk for deforestation and conversion. We will use this data to identify future landscape initiatives in Brazil. Utilizing our traceability data, Colgate identified its connection to farmers in Sorriso municipality in Mato Grosso State, Brazil which is on the CGF list of at-risk municipalities. In 2023 Colgate supported a spring restoration project in Sorriso. Colgate is currently considering additional impact opportunities in the region for 2025 and beyond.

COLLECTIVE ACTION

Colgate recognizes the need for industry collaboration to achieve a transparent and conversion free soy supply chain. We will continue to support existing efforts to minimize deforestation due to soy expansion in Brazil, such as the Soy Moratorium. 

Colgate as a member of the CGF - Forest Positive Coalition will continue to work with member brands and retailers to drive change within our supply chains and engage beyond the coalition with NGOs, CSOs, governments, local communities and other stakeholders to transform social and environmental practices in the soy industry. 

Colgate will support multi-stakeholder efforts to develop methodologies to identify and monitor high conservation value areas. Colgate recognizes the importance of farmer incentives to implement sustainability standards beyond legal requirements, and will participate in discussion of industry funding mechanisms for conversion and deforestation-free soy. 

Colgate encourages industry collaboration on transformation, and through our participation in the CGF Forest Positive Coalition, we will seek opportunities to collaborate in landscape and jurisdictional projects focused on driving transformation in the soy industry.

Moving forward, planned implementation activities include:

• Building on our most recent traceability learnings; Gather additional traceability data from prioritized expanded list of suppliers reaching further upstream in the supply chain; (2024-2025)

• Continue to drive aligned DCF approaches for lower risk countries such as the US and Canada where approaches have not been defined. 

• Secure support for Identified soy-focused landscape opportunities  utilizing our traceability and risk assessment data (2025-2025)

• Continue to Socialize Colgate’s soy policy and Forest Positive Coalition expectations with direct  suppliers; (ongoing)

• Based on prior indirect soy footprint learnings,  pivot to collaborative engagement with FPC members to overcome barriers with indirect / embedded soy suppliers to understand supply chain and indirect soy risk (2025-2026)

• Continue engaging suppliers on traceability of all direct soy back to the 1st aggregator or crusher in origin country (100% traceable to aggregator or crusher in country by 2025)

• Provide technical support to suppliers in South America to advance their progress towards DCF (2025-26)

We will provide updates on our progress against the above implementation actions in annual updates to this soy policy.