EMPTY STATE
COMPARISON TOOL

Kellogg 66/100

(NYSE:K) 2 of 38 (2018)

Kellogg Co. (Kellogg), a manufacturer and marketer of cereal and convenience foods, ranks second out of 38 companies, disclosing more information on its forced labor policies and practices than its peers across all themes. Compared to 2016, the company improved its rank from seventh to second. Since 2016, the company improved by disclosing management and accountability for its supplier code, supplier training, and information on responsible purchasing practices. Further the company improved by updating its supplier code to integrate the Employer Pays Principle, by expanding its auditing scope to include some recruitment agencies used by suppliers, and by providing details on corrective action plan processes for suppliers. Notably, the company has the highest score on the themes of commitment and governance and purchasing practices. Additional steps the company could take to address forced labor risks in its supply chains, include strengthening its disclosure and practices on the themes of recruitment, worker voice, and monitoring.

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66 /100

2018 Ranking: 2 of 38

HOW DO THEY COMPARE?

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32

Kellogg was evaluated both in 2016, when it ranked seventh out of 20 companies, and in 2018, when it ranked second out of 38 companies. Since 2016, the company has improved by disclosing management and accountability for its supplier code, supplier training, and information on responsible purchasing practices. Further, the company improved by updating its supplier code to integrate the Employer Pays Principle, by expanding its auditing scope to include some recruitment agencies used by suppliers, and by providing details on corrective action plan processes for suppliers. Kellogg had the largest improvement of any company evaluated in both 2016 and 2018, increasing from a score of 32/100 to 66/100.

2016 BENCHMARK

66

The average score for the sector was 30/100, matching the average score in the 2016 benchmark. Compared to 2016, the number of companies assessed in 2018 increased from 20 to 38. Since 2016 the methodology has been strengthened, making it harder for companies to achieve the same score. The 19 companies benchmarked in both 2016 and 2018 saw their average score increase from 30/100 to 33/100, which is positive given the changes to the methodology.

METHODOLOGY

2016

32

Kellogg was evaluated both in 2016, when it ranked seventh out of 20 companies, and in 2018, when it ranked second out of 38 companies. Since 2016, the company has improved by disclosing management and accountability for its supplier code, supplier training, and information on responsible purchasing practices. Further, the company improved by updating its supplier code to integrate the Employer Pays Principle, by expanding its auditing scope to include some recruitment agencies used by suppliers, and by providing details on corrective action plan processes for suppliers. Kellogg had the largest improvement of any company evaluated in both 2016 and 2018, increasing from a score of 32/100 to 66/100.

2016BENCHMARK

2018

66

The average score for the sector was 30/100, matching the average score in the 2016 benchmark. Compared to 2016, the number of companies assessed in 2018 increased from 20 to 38. Since 2016 the methodology has been strengthened, making it harder for companies to achieve the same score. The 19 companies benchmarked in both 2016 and 2018 saw their average score increase from 30/100 to 33/100, which is positive given the changes to the methodology.

METHODOLOGY

THEME AND INDICATOR SCORE

The benchmark methodology has seven themes, selected to capture the key areas where companies need to take action to eradicate forced labor from their supply chains. There are a total of 23 indicators across the seven themes. For each theme, a company can score a total of 100 points.

Commitment and Governance

This theme evaluates a company's commitment to addressing forced labor, whether it discloses supply chain standards, and to what extent it has management processes and board oversight, training programs, and engagement with stakeholders on forced labor in place.

OVERALL 95
INDICATORS
Commitment
100
Supply Chain Standards
100
Management and Accountability
100
Training
100
Stakeholder Engagement
75

Traceability and Risk Assessment

This theme measures the extent to which a company demonstrates an understanding of its suppliers and their workforce by disclosing relevant information (such as supplier names or sourcing countries) and assesses and discloses forced labor risks across its supply chains.

OVERALL 63
Traceability
50
Risk Assessment
75

Purchasing Practices

This theme assesses to what extent a company adopts responsible purchasing practices (such as providing price premiums and procurement incentives) and integrates supply chain standards into supplier selection and supplier contracts, and whether it cascades them down the supply chain.

OVERALL 90
Purchasing Practices
60
Supplier Selection
100
Integration into Supplier Contracts
100
Cascading Standards through the Supply Chain
100

Recruitment

This theme measures a company's approach to reducing the risk of exploitation of supply chain workers by recruitment agencies, eliminating workers' payment of fees during recruitment processes throughout its supply chains, and protecting the rights of migrant workers.

OVERALL 58
Recruitment Approach
30
Recruitment Fees
50
Monitoring and Ethical Recruitment
75
Migrant Worker Rights
75

Worker Voice

This theme measures the extent to which a company engages with workers in its supply chains, enables freedom of association, and ensures access to effective and trusted grievance mechanisms.

OVERALL 47
INDICATORS
Communication of Policies
100
Worker Voice
25
Freedom of Association
12.5
Grievance Mechanism
50

Monitoring

This theme evaluates a company's process for auditing suppliers (including whether audits include non-scheduled visits, review relevant documents such as wage slips or contracts, interview workers, and audit lower-tier suppliers) and providing disclosure on the outcomes of supplier audits.

OVERALL 50
Auditing Process
70
Audit Disclosure
30

Remedy

This theme measures the extent to which a company has corrective action plan processes for non-compliant suppliers and ensures remedy is provided to workers in its supply chains who are victims of forced labor. Publicly available allegations of forced labor in a company's supply chains that occurred in the past three years, and how a company has responded to and addressed those allegations, are also assessed as part of this theme.

OVERALL 63
Corrective Action Plans
100
Remedy Programs and Response to Allegations
25

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