California Supply Chain Transparency Act Disclosure

December 2020

Olam is a leading food and agri-business supplying food, ingredients, feed and fibre to 25,000 customers worldwide. Our 87,000 -strong team around world spans over 60 countries and our value chain includes farming, processing and distribution operations, as well as an estimated sourcing network of 5 million farmers (direct and indirect procurement).

Olam, which includes Olam Americas Inc. and Olam West Coast, is committed to providing a workplace where all employees are treated with dignity and fairness, and to respecting the rights of people and communities where we operate. We have zero tolerance for slavery, forced labor or human trafficking in our organization and our supply chains.

This disclosure sets out examples of verification, audit, certification, internal accountability, and training deployed by Olam to help identify, eliminate and prevent abuses across our value chains, and in the markets, where we operate.

Sustainability is integral to our Purpose

Respecting labor and human rights is an intrinsic part of Olam’s Purpose of Re-imagining Global Agriculture and Food Systems to enable prosperous farmers, thriving rural communities and healthy ecosystems to coexist.

Across our business and our supply chains, we are committed to protecting human rights, providing a workplace where all employees are treated with dignity and fairness, and to respecting the rights of people and communities.

We acknowledge the role we can play and we are committed to playing our part to work with other stakeholders – industry, government and NGOs – to tackle discrimination, eliminate unsafe and illegal labor practices for children and adults, promote fairness and equality, champion inclusion and diversity, while improving the livelihoods of farmers and communities.

Verification

To advance our commitments, we have embedded human rights within our Policies including our Fair Employment Policy and our Code of Conduct which are in line with the Conventions of the International Labour Organization (ILO) and the United Nations Guiding Principles on Business and Human Rights. We are also a signatory to the UN Global Compact.

In 2019, we published a revised version of our Code of Conduct, which is the cornerstone of Olam’s commitment to integrity, setting out our commitment to “do what is right”, founded on the values and everyday behaviors that build our distinctive culture and setting the standard that is embedded in every aspect of Olam’s business. This includes our commitments to people, labor and human rights within our own workplaces and in the communities and supply chains where we operate.

Certification

We recognize the importance of working with our suppliers to develop supply chains that respect people and human rights. Olam’s Supplier Code sets out our expectations for sourcing raw materials, products and services in an ethical, socially responsible and environmentally sustainable manner and in compliance with all relevant applicable laws and regulations.

Our Supplier Code of Conduct sets out a comprehensive set of conditions which include

• Being strictly prohibited to use child labor. It is a prerequisite to comply to the International Labor Organization (ILO) Convention 138 on the Minimum Age of Employment and Convention 182 on the Worst Forms of Child Labor;
• Being strictly prohibited to use forced, involuntary and slaved labor, including bonded, indentured and involuntary prison labor; as well as trafficked human beings;
• Creating an inclusive work environment that avoids any form of discrimination. All forms of harassment, including sexual harassment, intimidation, and abuse or threat are not permissible;
• Acknowledging employees’ rights to form and join unions or other associations, and to bargain collectively; unless prevented by local applicable laws;
• Providing fair wages and benefits that are in accordance with applicable laws, industry standards or related agreements;
• Complying with all applicable ILO standards, national legal requirements and industry standards pertaining to working time;
• Providing a safe and hygienic work environment and accommodation (when the case may be) in accordance with applicable health and safety laws and international conventions;
• Preventing accidents and injury arising out of, associated with, or occurring in the course of work, by minimizing causes of hazards in the work environment;
• Encouraging gender equality, equal access and empowerment of women.

Audit

Suppliers signing our Supplier Code may be subject to announced inspections to ensure compliance. Where remediation measures are required, we work with suppliers to develop and implement corrective action plans. Any supplier found to be in breach of these standards and who does not commit to, and implement, remediation measures may be subject to suspension.

Internal Accountability

We have an established Grievance Procedure in place to report and address breaches of relevant Olam Policies or Codes . This Procedure applies to our own operations and third-party suppliers to enable concerns to confidentially raised about breaches of our policies. Feedback and inputs from all our stakeholders are important to drive improvements and best practices, as well as increasing transparency in our supply chains. All grievances are logged and investigated with status updates, and actions, reported.

Training

Conducting business in an ethical, socially responsible and environmentally sustainable manner must be embedded in every aspect of Olam’s business. To strengthen our ethical and compliance standards, we have established the Olam Ethical Business Programme (EBP), which supports learning and training to ensure employees understand the standards and behaviors expected and detailed in the Olam Code of Conduct, as well as our specific policies regarding slavery and human trafficking. For those employees with direct responsibility of supply chain management, we also endeavor to ensure they receive appropriate training and resources.