Ethics and Compliance

Supplier Guiding Principles

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Purpose

In order to continue to be one of the world's premier food companies, Heinz has developed a set of Global Principles which convey to its employees and to the public Heinz's values and commitments. In addition to the Global Principles and as part of Heinz's efforts to foster relationships with suppliers who share similar values, Heinz is introducing its Supplier Guiding Principles for suppliers with whom the H. J. Heinz Company and its affiliates have a contractual relationship. The Supplier Guiding Principles restate our requirements and emphasize good workplace policies that comply with local labor laws, as well as applicable environmental laws.

Scope

These Supplier Guiding Principles apply to all suppliers with whom Heinz and its affiliates worldwide have a contractual relationship, including contractors, suppliers of goods and services, co-packers and joint venture partners.

Heinz has approximately 8,000 domestic suppliers and 35,000 suppliers globally.

The Company’s Supplier Guiding Principles ensure consistency across our operations with regards to upholding uniformly high standards of quality and service. The principles also require compliance with local labor and environmental laws. For example, Heinz believes suppliers should protect the health and safety of their workers and refrain from hiring anyone under the legal age for employment. Suppliers are asked to certify their compliance to our principles. Heinz conducts unannounced on-site inspections to verify compliance.

Heinz is attaching the Supplier Guiding Principles to all new and renewed contracts with suppliers including contractors, suppliers of goods and services, co-packers and joint venture partners around the world. In the United States all of our contracts already include these guidelines. We certify suppliers’ compliance with these principles and maintain regular communication through proprietary software.

Heinz severs relationships with suppliers that fail to follow these principles.

1. Legal Requirements
   Suppliers will comply with all applicable laws and regulations in providing goods and services to Heinz.
2. Employment Practices
   Minimum Age for Employment- Suppliers will not employ anyone under the legal working age as defined by local law.
   • Forced Labor- Suppliers will not use forced or involuntary prison labor.
   • Abuse and Harassment- Suppliers will not use corporal punishment or other forms of physical or sexual harassment or abuse of their employees.
   • Discrimination- Suppliers will not discriminate on the basis of any condition or characteristic which is protected by applicable law or regulation.
   • Freedom of Association- Suppliers will recognize and respect each employee's right to associate with any legally sanctioned organization. The rights of labor unions must be respected.
   • Work Hours, Work Week and Payment of Wages- Suppliers will comply with all applicable local laws.
   • Health and Safety - Suppliers will provide employees with working conditions that are in compliance with all applicable laws and regulations regarding worker health and safety.
3. Environmental Practices
   Our suppliers will be expected to meet applicable environmental laws and regulations in their operations and to develop and implement plans and programs to correct any non-compliant practices.
4. Communications
   We expect our suppliers to take appropriate steps to communicate these "Supplier Guiding Principles" to their employees, including posting these Principles in the local language in an accessible place.
5. Monitoring and Compliance
   As part of the implementation of these Supplier Guiding Principles, these Principles will be incorporated into all new or renewed commercial agreements between suppliers and Heinz and its affiliates. Suppliers will be expected to certify their compliance with these Supplier Guiding Principles at Heinz's request and to authorize Heinz and its designated agents (including any third parties) to engage in monitoring activities, including unannounced on-site inspections.

When Heinz becomes aware of any actions or conditions not in compliance with these Supplier Guiding Principles, such actions or conditions will be reviewed, and appropriate corrective measures will be implemented.