Responsible Soy Procurement Policy

Background

As part of Colgate-Palmolive’s 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 Colgate and 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.(2) 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 RTRS calculation methodology, we have calculated our direct soy footprint shown in the table below.

Soy footprint in metric tons

Ingredient Type	Footprint	% of CP Total
Soybean Meal/Oil	33,474	42%
Soy-based Glyceride	46,033	58%
Total	79,508	100%

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 96% of our soy footprint to the country of origin.

Soy Meal and Oil - Country of Origin and % Volume Risk Category

Countries of Origin	Negligible Risk Countries		At Risk Countries		Unknown Country
Control system	System	No System	System	No System	No System
USA	0%	81%	0%	0%	13%
Brazil	0%	0%	6%	0%	13%
Total	0%	81%	6%	0%	13%

Note: Control systems ensure the accuracy of traceability declarations. Relative to South America origins, Colgate has designated the USA to be negligible risk countries. Suppliers in the USA tend to not have country of origin control systems in place.

Soy-based Glycerides - Country of Origin and % Volume Risk Category

Countries of Origin	Negligible Risk Countries		At Risk Countries		Unknown Country
Control system	System	No System	System	No System	No System
USA	0%	23%	0%	0%	30%
Argentina	0%	0%	3%	15%
Brazil	0%	0%	5%	24%
Risk Type	0%	23%	8%	39%	30%

Based on our traceability exercise, approximately 81% of our non-certified soy meal and oil volume was traceable to the crusher in the country of origin. Approximately 60% of our soy-based glycerides were traceable to crusher in the country of origin.

Of the volumes identified as originating from high risk countries (34%) with limited biome and farm traceability, we identified the presence of high risk biomes based on supply chain nodes provided, likely including the Amazon, Cerrado and Gran Chaco. To mitigate sourcing risk from high risk geographies, Colgate sources 100% of our direct soybean meal and oil from South America as certified sustainable soy under the Proterra Certification standard.

Traceability and Certification of Volumes from At Risk Countries (Brazil, Argentina)

Material from At Risk Countries	Material type	Traceable to crusher presence		Traceable to Municipality		Traceable to Farm		Proterra Certified
Control system		System	No System	System	No System	System	No System	System
Soy oil & meal	3%	0%	0%	0%	0%	0%	0%	3%
Glycerine	31%	12%	19%	10%	12%	10%	0%	0%
Global Sub Totals	34%	12%	19%	10%	12%	10%	0%	3%
Global Totals	34%	31%		22%		10%		3%

Note: Volumes from unknown origins equals 22% of global volume.

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 2023, 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 2023, 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:

Cargill	Olenex
ADM	Bunge

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

Caramuru	Olfar
ICOF/Musim Mas	ADM
La Fama	Aceitera General Deheza

Priority upstream intermediate soy-based derivative suppliers include:

Caramuru	Bunge
ADM	LDC

We executed this engagement through direct supplier meetings and a survey to measure alignment with elements of Colgate’s policy and the FPC expectations. The cumulative results of the survey are shown in the table below.

Response	Soy policy	Report farm level traceability - direct	Report farm level traceability - indirect	Time bound implementation plan	Methodology for prioritizing, assessing and engaging suppliers	Target date for no conversion supply	Landscape or sectoral level transformation projects
No	57%	57%	57%	57%	57%	57%	33%
Yes	43%	43%	43%	43%	43%	43%	67%

Response	Grievance Mechanism	Public grievance reporting	Non-compliant supplier mechanism/ process	Progress reporting on time bound implementation	Types of No Deforestation and/or No Exploitation monitoring - Spatial monitoring	Types of No Deforestation and/or No Exploitation monitoring - Audits	Types of No Deforestation and/or No Exploitation monitoring - Independent verification
No	29%	57%	29%	57%	57%	57%	57%
Yes	71%	43%	71%	43%	43%	43%	43%

We continue to work with our direct suppliers to source deforestation and conversion-free soy products. We expect our suppliers to provide traceability data for their soy supply chain and to achieve traceability ultimately back to the farm when sourcing from high risk biomes and municipalities. 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 our 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 (%)

Soy Tier	% Volume
Tier 1	13%
Tier 2	62%
Tier 5	24%

Monitoring and Verification

The goal of this policy is to monitor and verify direct supplier compliance. Traceability information will facilitate monitoring land use change at farm level. Colgate expects suppliers to demonstrate compliance with the policy in their own supply chain, including conducting verification and geospatial monitoring of their supply base. We will give preference to suppliers whose soy products have been independently verified to comply with Colgate’s soy policy.

We will take a step-wise approach to verification. As an interim measure, Colgate will strive to procure only soy products from South America that have been verified low-risk of contributing to deforestation by credible certification schemes, such as Proterra and RTRS. Site-level mass balance chain of custody under these certification schemes will be acceptable until 2025 as part of our incremental approach leading to our 2030 deforestation and conversion-free soy commitment. Colgate will consider soy that is certified as sustainable through our suppliers’ own programs as“progressing” towards our compliance commitment if the program has passed the independent ITC benchmarking process against the European Feed Manufacturers' Federation (FEFAC) Soy Sourcing Guidelines 2023. Since 2018, 99% of the direct soybean meal and oil products Colgate purchases in South America are Proterra certified. In 2023 glycerin supplied by Caramuru in Brazil is considered “progressing” under their Sustentar program.

Deforestation and Conversion Free (DCF) progress in at-risk countries (direct purchases)

Soy Material	DCF	Progressing to DCF	Total Progress
Meal & Oil	3%	0%	3%
Glycerides	0%	10%	10%
Total	3%	10%	13%

Note: Proterra certified volumes represent DCF. Caramuru’s Sustentar program represents Progressing to DCF.

In addition to our progress in at-risk countries, approximately 46% of soy-based materials were from negligible risk countries according to declarations from suppliers without control systems in place.

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, and we are seeking additional impact opportunities in the region for 2025 and beyond.

Name of the initiative:	Sorriso Spring Restoration Project
Location of the initiative:	Sorriso Landscape, State of Mato Grosso. The project is within the Matto Grosso Produce, Conserve and Include (PCI), Jurisdictional Governance program.
Project Webpage	https://catsorriso.org.br/projeto-aguas-do-lira-contempla-revitalizacao-de-nascente-localizada-na-area-urbana-de-sorriso/ https://catsorriso.org.br/wp-content/uploads/2023/07/PROJETO-LIRA.pdf
Project timeframe:	2022-2024
Colgate participation since:	2023 (Stand-alone field project)
Other partners involved:	Grupo Bimbo, John Deere, Agro Baggio, Ministério Público do Estado do Mato Grosso.
Type of contribution	Disbursed financial support
Goals of the initiative that contribute to forest positive elements:	Forest restoration Promote restoration of riparian vegetation in a soy producing landscape. Directly restored area of 8,100 m² with 3,100 trees planted. Indirectly impacted area of approximately 7.6 hectares including the area downstream from the intervention point to the confluence with the Tenente Lira River.
Goals of the initiative that contribute beyond forest positive elements:	Work and families Estimated number of beneficiaries: 3,000, including beneficiaries downstream of the restoration point; neighboring beneficiaries around the source, beneficiaries through environmental education; etc.

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)
Expand our risk assessment to identify sourcing areas with social and environmental risk; (2024-2025)
Identify opportunities to support soy-focused landscapes utilizing our traceability and risk assessment data (2025)
Continue to Socialize Colgate’s soy policy and Forest Positive Coalition expectations with direct suppliers; (ongoing)
Based on prior indirect soy footprint, continue engagement with priority indirect / embedded soy suppliers to understand supply chain and indirect soy risk (2025)
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)

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

Last Updated: August 2024