We Speak Up To Report Concerns

Non-retaliation Policy

It is Colgate’s policy and practice to maintain the highest ethical standards, and to create a workplace free of inappropriate or unlawful behavior, in which people are encouraged to share their concerns with the Company without fear of retaliation. Consequently, at Colgate, no adverse action will be taken against any employee, former employee, agent or third party for complaining about, reporting, participating or assisting in the investigation of a suspected violation of the Company’s Code of Conduct, Company policy, or applicable law, unless the allegation made or information provided is found to be intentionally false or not made or provided in good faith. To the maximum extent possible, Colgate will maintain the confidentiality of all complaints. All allegations of retaliation will be investigated, and if appropriate, disciplinary action will be taken, up to and including termination.

All information provided to Global Ethics and Compliance is reviewed and, if it relates to the Code, the matter is promptly and thoroughly investigated by Global Ethics and Compliance and/or the Global Legal Organization. It is imperative that reporting persons do not conduct their own investigations, as investigations may involve complex legal issues. Acting on your own may compromise the integrity of an investigation and adversely affect both you and Colgate.

Reports can be made anonymously where local law permits. But, we encourage you to identify yourself when calling in order to help us to facilitate the investigation and follow-up. There are laws in some countries that restrict the type of information you may report. If these laws apply to your situation, a Global Ethics and Compliance representative will refer you to someone in your business unit who can assist you with your question or concern.

However, keep in mind that if you wish to identify yourself, the Company will take all appropriate steps to keep an individual’s identity and the information submitted confidential, and will only disclose information on a need-to-know basis when the disclosure is:

• Necessary in order to conduct an effective investigation, answer your questions or take appropriate action; or 
• Otherwise required by applicable law. 

A report or complaint may contain personal data. For the purpose of investigating a violation or suspected violation, it may be necessary, subject to local law, to transfer personal data collected in one country to other countries, including the United States. In such cases, personal data may be used by Company employees and Colgate entities that participate in the operations of Global Ethics and Compliance to investigate the report, but only for such period as is reasonably necessary for this purpose (and thereafter such personal data will be destroyed or retained only as required by Company policy or by law).

Global Ethics and Compliance Investigation Process

Colgate people are expected to provide their complete cooperation when participating in any Company investigation.

• An Investigator Is assigned based on subject matter expertise and objectivity
• Interviews Are Conducted and documents are reviewed by the Investigator
• Factual findings are developed based on the collected information
• Corrective actions are recommended based on the findings
• General Feedback about the outcome of the investigation is provided