The Wm. Wrigley Jr. Company takes great pride in making high quality confectionery products. We believe it is our social responsibility to conduct business in a manner that is consistent with the highest standards of business ethics and to hold our suppliers to the same high standards. This commitment is the foundation of our values and the "Wrigley Way" of doing business. To maintain the Wrigley Way, our suppliers are expected to comply with the following standards and are encouraged to exceed the requirements set forth in this Code of Conduct.

Child Labor

Supplier does not employ individuals below the age of 16 years old, except if allowed by local law and such exception is consistent with International Labor Organization guidelines. Supplier maintains verifiable documentation of each individual's date of birth or has some legitimate means of confirming each individual's age.

Guidelines:

• Supplier complies with the laws and regulations related to minimum working age. No employee of any age, including apprentices or vocational students, may be employed in breach of local regulations governing the minimum age for work or the compulsory age for schooling.
• Where independent documents are not available, Supplier employs other legitimate and reliable means for determining employees' ages.

Compensation

Supplier fairly compensates all employees by providing wages and benefits as required by all applicable laws.

Guidelines:

• Supplier ensures that wages paid for all hours worked meet at least the legal minimum wage or the local industry minimum standards for compensation, whichever is higher.
• Supplier meets all legal requirements for the payment of overtime and incentive rates.
• Supplier provides all legally mandated benefits without illegal deductions.
• Supplier communicates, orally or in writing, to all employees: wages, incentives, benefits, and bonuses to which all employees are entitled in that facility and under the applicable law.

Fair and Equal Treatment

Supplier does not engage in the use of physical, sexual, psychological, verbal or other abuse. In addition, all employees are treated with respect and dignity. Supplier's terms and conditions of employment, including hiring, training, working conditions, compensation, benefits, promotions, discipline, termination or retirement, are based on the individual's qualifications, performance, skills, and experience.

Guidelines:

• Supplier maintains workplaces that are free from discrimination on the basis of race, age, gender, caste, political opinion,  religion, marital status, sexual orientation, disability, maternity, or other status of the individual unrelated to the ability to perform the job.
• Supplier complies with all applicable laws that pertain to disciplinary practices.
• Supplier complies with all applicable laws that pertain to harassment and abuse.

Freedom of Association

Supplier respects the right of employees to form and join trade unions and bargain collectively in a lawful and peaceful manner in accordance with applicable law.

Guidelines:

• Supplier complies with all applicable laws that pertain to freedom of association and collective bargaining.
• Supplier does not subject its employees to harassment, intimidation, or retaliation in their efforts to freely associate or bargain collectively.
• Supplier provides confidential means for employees to raise grievances.

Health and Safety

Supplier complies with all applicable laws that pertain to health and safety in the workplace. Supplier adequately trains employees on applicable local workplace safety practices.

Guidelines:

• Supplier provides a safe, clean, healthy, and productive work environment, and - if provided - a safe and healthy living space, including appropriate lighting, temperature, ventilation and toilet facilities.
• Supplier properly manages handling of all dangerous substances and machinery.
• Supplier does not assign a job that by its nature or circumstances is likely to harm the health and safety of the employee.
• Supplier provides systems and training designed to help prevent accidents and injuries.
• Supplier provides appropriate personal safety equipment, adequate medical facilities, fire exits and extinguishers and safety equipment, well-lit and comfortable workstations, and clean restrooms.

Voluntary Employment

Supplier employs all employees on a voluntary basis and does not use any prison labor or slave labor, inflict any physical abuse, or engage in any other forms of compulsory labor.

Guidelines:

• Supplier does not require employees to deposit original passports, identity papers, travel documents or any other personal legal documents upon commencing employment with Supplier.
• Supplier does not use any forced labor, whether prison, bonded, indentured or otherwise. Forced overtime is prohibited.
• Supplier does not confine or subject employees to restrictions on freedom of movement.

Working Hours

Supplier complies with all applicable laws regarding regular working hours, overtime hours and benefits.

Guidelines:

• Supplier provides documentation to all employees indicating compensation, time worked (including overtime hours), pay rate, benefits, and any deductions.
• Supplier provides mandated rest days, holidays and vacation days.
• Under normal circumstances, Supplier grants to all employees a minimum of one day off within each seven-day period and does not require a work week over 60 hours.

Environment

Supplier complies with all applicable environmental laws and regulations of the country of its business.  Supplier continually strives to improve environmental performance.

Guidelines:

• Supplier documents and maintains records related to such laws and regulations including environmental permits and reporting requirements.
• Supplier properly handles and stores hazardous materials and waste, and disposes of them in a safe and legal manner.

Other Responsibilities

Suppliers must not use subcontractors in the manufacturing of Wrigley products or product components without Wrigley's approval, and only after the subcontractor has agreed to comply with this Code of Conduct.

Suppliers are obliged to communicate the contents of these standards to their employees.

Compliance

Supplier complies with the legal requirements and standards of its industry under all applicable laws, and maintains accurate books and records demonstrating compliance with such laws and these standards, to the extent permitted by law.

To measure Supplier's compliance with these standards, Wrigley reserves the right to conduct announced and unannounced on-site independent third-party audits of Supplier's facilities, operations, books, and records and conduct confidential worker interviews in connection with such audits.

Upon receipt of any unsatisfactory audit results and Supplier's failure to implement Wrigley's recommended corrective actions, Wrigley, in its sole discretion, reserves the right to suspend any purchases from Supplier until corrective actions are implemented, or to terminate its relationship with Supplier.