Modern Slavery Statement

Addressing the California Transparency in Supply Chains Act, the United Kingdom Modern Slavery Act, the Australian Modern Slavery Act of 2018 and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act of 2023.

Signed: September 25, 2023

Board Approved: September 25, 2023

About this Statement

This is a statement of the steps General Mills has taken in an effort to ensure slavery and human trafficking are not taking place in our supply chain or business and covers General Mills’ fiscal 2023, the period of 12 months ending on May 28, 2023. The following document serves as a statement complying with the Australian Modern Slavery Act of 2018, the UK Modern Slavery Act of 2015, the California Transparency in Supply Chains Act, and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act.

The process of preparing this statement involved the participation of a wide range of internal stakeholders across many functions of General Mills. For the purposes of the Australian Modern Slavery Act, this is a joint statement for the reporting entity, General Mills Holding (Australia) Pty Ltd, and the entity submitting the statement, General Mills, Inc. For the purposes of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, this is a joint statement for the reporting entities, General Mills Canada Corporation, Yoplait Liberté Canada Co. and General Mills Canada Holding One Corporation and the entity submitting the statement, General Mills, Inc.

Our Company, Structure, and Supply Chain

General Mills is a leading publicly traded, global manufacturer and marketer of branded consumer foods and wholesome natural pet food sold through retail stores. We are also a leading supplier to the North American foodservice and commercial baking industries. In addition to our consolidated operations, we have 50% interests in two strategic joint ventures that manufacture, and market food products sold in approximately 130 countries worldwide: our Cereal Partners Worldwide joint venture with Nestlé S.A. competes in the ready-to-eat cereal category in markets outside North America, and our Häagen-Dazs Japan, Inc. joint venture competes in the super-premium ice cream category in Japan. General Mills generated fiscal 2023 net sales of U.S. $20 billion, and General Mills’ share of non-consolidated joint-venture net sales totalled U.S. $950 million. As of May 28, 2023, General Mills had approximately 34,000 employees.

Headquartered in Minneapolis, Minnesota, USA, General Mills owns our principal executive offices and main research facilities. We operate numerous manufacturing facilities and maintain many sales and administrative offices, warehouses, and distribution centers around the world. We manufacture our products in 10 countries and market them in more than 100 countries. As of May 28, 2023, we operated 45 food production facilities. Of these facilities, 27 are located in the United States, 4 in the Greater China region, 1 in the Asia/Middle East/Africa Region, 2 in Canada (1 of which is leased), 5 in Europe/Australia, and 6 in Latin America and Mexico. We also operate numerous grain elevators in the United States. We utilize approximately 16 million square feet of warehouse and distribution space that primarily supports our North America Retail and Pet segments. As part of our Häagen-Dazs business in our Europe & Australia and Asia & Latin America segments, we operate 450 (all leased) and franchise 382 branded ice cream parlours in various countries around the world.

Our Supply Chain

We work within a large, diverse value chain of business partners and stakeholders. Our supplier base is large, complex, and global, with thousands of suppliers in more than 25 countries. The principal raw materials we use are grains (wheat, oats, and corn), dairy products, sugar, fruits, vegetable oils, meats, nuts, vegetables, and other agricultural products. We also use substantial quantities of carton board, corrugated, plastic, and metal packaging materials, operating supplies, and energy. Most of these inputs for our domestic and Canadian operations are purchased from suppliers in the United States. In our other international operations, inputs that are not locally available in adequate supply may be imported from other countries. 

Australia

In Australia, General Mills brands include 25° South™, Old El Paso™, Latina™ Fresh, Betty Crocker™, Nature Valley™, Häagen-Dazs™, Fibre One™, and Pecks™. As of May 28, 2023, we employed 226 people across our headquarters in Melbourne and at our manufacturing site in Rooty Hill, NSW. Our primary manufacturing sites relevant to our products imported for sale and made and sold in Australia are located in Australia, Spain, Portugal, France, and Greece. Additionally, we partner with third party manufacturing and distribution centers in Australia, New Zealand, and France.

General Mills Holding (Australia) Pty Ltd is the reporting entity for the purposes of the Australian Modern Slavery Act. This statement also covers its wholly owned subsidiaries General Mills Manufacturing Australia Pty Ltd and General Mills Australia Pty Ltd.

Canada

In Canada, General Mills brands include Annie’s™, Betty Crocker™, Bisquick™, Blue Buffalo™, Cheerios™, Chex Cereal™, Cinnamon Toast Crunch™, Dunkaroos™, Fibre One™, Häagen-Dazs™,Liberté™ Yogurt, Lucky Charms™, LäraBar™, Muir Glen™, Nature Valley™, Old El Paso™, Pillsbury™, Trix™, and Yoplait™. As of May 28, 2023, we employed 778 people and our main office is in Mississauga, Ontario with a regional office in Anjou, Quebec in addition to two manufacturing sites located in Saint-Hyacinthe, Quebec and Winnipeg, Manitoba. Most of these inputs for our Canadian operations are purchased from suppliers in the United States.

General Mills Canada Corporation, Yoplait Liberté Canada Co. and General Mills Canada Holding One Corporation are reporting entities for the purposes of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act.

United Kingdom

In the United Kingdom, General Mills brands include Häagen-Dazs™, Old El Paso™, Nature Valley™, Fibre One™, Betty Crocker™, Green Giant™, and Pillsbury™. As of May 28, 2023, we employed 270 people in the UK, all of whom are based in our Uxbridge office. Our primary manufacturing sites relevant to our products imported for sale in the UK are located in France, Spain, Greece, the U.S., and India. Additionally, we partner with third party manufacturing and distribution centers in the UK, France, Spain, Portugal, Holland, Mexico, Peru, and Ecuador.

Our Approach to Human Rights

General Mills is committed to respecting human rights and strives to positively impact all the people we depend upon across our full value chain. To better understand our human rights risks and guide our work, we are following a strategic framework (see below) to strengthen our ability to assess, address, and prevent potential impacts across our value chain and are taking a thoughtful approach in each step of our journey. We aim to know and show our human rights risks and take them into account in business decisions. We are focused on developing human rights due diligence capabilities to proactively identify where the risks for potential impacts on people in our value chain are most severe, prioritize actions, track progress, and communicate. Our strategy is modeled on the United Nations Guiding Principles for Business and Human Rights.

Governance

The General Mills leadership team has ultimate accountability for the company’s global responsibility programs and performance. The Board has made it a priority to ensure sustainability and global responsibility are taken seriously at all levels of the company. The Board of Directors’ Public Responsibility Committee provides oversight and receives regular updates from the operating teams. Our Chairman and CEO convenes the Global Impact Governance Committee, which consists of officers of the company, at least three times per year to monitor and approve strategies, policies, and key investments related to sustainability and social responsibility initiatives.

At General Mills, we have resources appointed to enhance our human rights strategy. The role of Director of Global Impact – Operations Integration has accountability for advancing respect for human rights across our value chain and reports to the Chief Sustainability and Global Impact Officer. The Director of Global Impact – Operations Integration also oversees the Human Rights Integration Team, a global, cross-functional team advancing General Mills’ work on human rights. The Global Responsible Sourcing program has a dedicated team and is part of our Global Sourcing Operations and Capabilities (GSOC) group. GSOC reports to the Chief Procurement Officer and is focused on integrating key capabilities into Sourcing processes for General Mills globally.

Commitments, Policies, and Training

Respect for human rights is fundamental to our purpose of making food the world loves and to our commitment to ethical business conduct. 

We respect and acknowledge internationally recognized human rights principles. We are working diligently to implement the United Nations Guiding Principles on Business and Human Rights (UNGPs) throughout our business. We have been a signatory to the United Nations Global Compact (UNGC) since 2008 and are guided by the UNGC’s 10 principles regarding human rights, labor, the environment, and anti-corruption. We are also a signatory to the United Nations Women’s Empowerment Principles. We recognize governments are ultimately responsible for establishing the legal framework to protect human rights within their jurisdictions. 

Our Human Rights Policy states the standards for our company, suppliers, and partners regarding the protection of human rights. These standards are based in part on the International Labor Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

Consistent with the principles outlined in our Employee Code of Conduct and Supplier Code of Conduct we:

• Prohibit forced labor, child labor, and discrimination
• Work to establish safe and healthy working conditions, including freedom of movement
• Value diversity and consider it core to our business strategy
• Seek to compensate employees competitively and operate in compliance with applicable wage, work hours, overtime, and benefits laws
• Respect the principles of freedom of association and collective bargaining
• Recognize the importance of land rights as well as the principle of free, prior, and informed consent (FPIC) and support implementation of FPIC by national authorities.

   

Employee Code of Conduct

Our Employee Code of Conduct outlines our ethical expectations and provides practical tips and examples for how to act with integrity in every decision, every action, every day. 

Employee Training and Communication

We communicate our expectations through training opportunities and educational modules on our company intranet. Employees participate in live and online scenario-based training to illustrate ethical decision-making in daily business activities. Posters highlighting key messages from our Code of Conduct are posted in manufacturing facilities and offices. The code and posters are available in 10 languages for our global workforce. Employees also have access to an intranet site dedicated to Ethics & Compliance information and resources.

Supplier Code of Conduct

The standards we hold for our suppliers are laid out in our Supplier Code of Conduct, which covers four pillars of responsible sourcing: human rights, health and safety, the environment, and business integrity. Our Supplier Code of Conduct was updated in fiscal 2022 to include additional standards, including respect for land rights and freedom of movement. We expect all suppliers to uphold our Supplier Code of Conduct.

Supplier Training and Communication

To ensure alignment across the function, all Sourcing employees complete mandatory annual online learning on our Supplier Code of Conduct. Training is also expanded to other internal teams, including our Global Impact and Innovation, Technology & Quality teams. Additionally, in fiscal 2023 we launched this training to our external suppliers. The human rights section of the training includes education on modern slavery, forced labor, and child labor, as well as descriptions of other human rights issues.

Stakeholder Engagement and Collaboration

We recognize that we are part of a broader community wherever we operate and believe engaging stakeholders is fundamental to our respect for human rights. We are committed to engaging with relevant parties in an effort to understand, assess, and address areas of concern. We are also committed to collaborating with our suppliers and our business partners to eradicate modern slavery. We have engaged with numerous groups on human rights issues, including:

• AIM-PROGRESS, a forum of consumer goods manufacturers focused on responsible sourcing
• BSR Human Rights Working Group, a coalition of companies across all sectors sharing best practices and experiences implementing the UNGPs
• The World Cocoa Foundation’s Cocoa & Forests Initiative (See the Cocoa section below)
• CARE International Côte D’Ivoire and CARE International Ghana (See the Cocoa section below)
• Proforest (See the Cocoa, Palm Oil, and Sugarcane sections below)
• Shift (see the Risk Assessment and Salient Issues section below)

Risk Assessment 

General Mills partnered with Shift, the leading center of expertise on the UN Guiding Principles on Business and Human Rights, to assess our salient human rights risks. We conducted an initial assessment of human rights-related issues inherent to a complex supply chain like General Mills to identify and prioritize future due diligence on the most salient human rights risks to people throughout our value chain. The Shift assessment began in fiscal 2020 and was completed in fiscal 2021.

This initial assessment was conducted in line with the UN Guiding Principles on Business and Human Rights and included:

• Desktop research including a review of all relevant internal policies and programs underway
• Internal stakeholder interviews with individuals from across the company
• External stakeholder interviews of leaders from non-profit organizations
• Workshops with internal stakeholders to review research findings and prioritize the list of salient issue
• Peer benchmarking 

   

This assessment identified forced labor and child labor as the most salient issues associated with our value chain. Shift also identified wages, earnings, and working hours; freedom of association and collective bargaining; and land rights as important salient issues. A variety of factors may increase human rights risks, including temporary or seasonal work status and weak enforcement of legal protections. As General Mills continues to advance respect for all human rights, we are prioritizing efforts that can reach the most vulnerable people.

Human Rights Due Diligence in our Own Operations

The risk of modern slavery in our owned operations is low due to policies and practices aligned with our corporate value of putting people first, strong auditing programs, interviews with third-party labor vendors for manufacturing plants, and accountability for remediation of any findings. 

Grievance – The Ethics Line

Our Ethics Line, hosted by an independent reporting service, is available 24 hours a day, 7 days a week, from any location worldwide and is multi-lingual. Those using the line can choose to remain anonymous. The Ethics Line is available on our Corporate Website and can be used by anyone wishing to raise a concern or question. Ethics Line cases are routed to Ethics & Compliance to triage for initial review, who then align an investigation team (HR, Global Security, Global Internal Audit, Finance or Law) depending on the report.

While the Ethics Line is open to all General Mills stakeholders to report concerns about any part of our value chain, it is primarily used for employees to report concerns of Employee Code of Conduct violations. Along with robust, standardized operations and human resources policies, training, and oversight, the Ethics Line helps us feel confident that the risk of modern slavery in our owned operations is low.

General Mills encourages all leaders to foster an environment of productive discourse where employees feel comfortable raising concerns. Employees are encouraged to raise concerns with their manager, and they are also reminded that their HR business representative, a lawyer at General Mills, a member of the Ethics & Compliance group, and the Ethics Line are all available for receiving concerns.

Assessing the Effectiveness of the Ethics Line

Semi-annually, Ethics & Compliance presents to the Audit Committee of the Board of Directors on the Ethics & Compliance program, including a report of employee incidents. The report includes details of the incident, results of the investigation, and outcome. Our external auditor KPMG receives a similar report quarterly and reviews it with Ethics & Compliance. In fiscal 2023, there were no reports or questions related to modern slavery.

Each year, the company conducts an annual Ethical Culture Survey, which gathers employees’ perceptions of our ethical culture and Ethics & Compliance resources. The Ethical Culture Survey goes to a randomly selected group representing 25% of employees worldwide. Our survey results indicate that employees feel comfortable raising concerns without fear of negative consequences, and they are confident that if they report an inappropriate business practice or ethical issue something will be done about it. 

Another area we measure is employees’ comfort in speaking up. We reference the Navex Global Risk and Compliance Benchmark Report according to which a low percentage of anonymous reports indicates comfort in the reporting process. Our Ethics Line receives an anonymous reporting rate significantly lower than the industry average, which, combined with the scores related to comfort in reporting we see in our Ethical Culture Survey, provides a reasonable indicator that our employees feel safe in raising complaints and concerns.

Human Rights Due Diligence in our Supply Chain

Responsible Sourcing Audits

The Global Responsible Sourcing program manages compliance of our owned manufacturing locations, co-packers, premiums and licensing, and Tier 1 direct suppliers. We expect all suppliers to uphold our Supplier Code of Conduct, and we use responsible sourcing audits and self-assessment questionnaires (SAQs) to assess and understand suppliers’ business practices.

We use the 4-pillar Sedex Members Ethical Trade Audit (SMETA) protocol or mutually recognized responsible sourcing audits to assess our supply chain on social and environmental practices. SMETA is a prescriptive audit procedure covering Health and Safety, Labor Standards (including audit criteria on forced labor and human trafficking), Environment, and Business Ethics. The audit covers human rights by assessing the extent to which businesses understand and manage their human rights impacts through the lens of the UNGPs. The SMETA framework is widely recognized by companies across many sectors, which enables suppliers to share audit results with multiple customers to improve efficiency and reduce audit burden. Accredited third-party auditors perform these audits and ensure timely creation of Corrective Action Plans (CAPs) and closure of identified non compliances within a specified time frame.

Our owned manufacturing locations are audited using the 4-Pillar SMETA Sedex Members Ethical Trade Audit (SMETA) protocol at minimum every three years, and we require our co-packers to submit an updated audit every three years. During fiscal 2023, 159 of our owned locations and co-packers were audited, representing about 53% of the total locations.

Tier 1 direct suppliers (suppliers that provide ingredients used in our food products or packaging) are rated by inherent country and goods risk using external data sources. To segment our Tier 1 suppliers into different risk levels, we consider factors including geography, ingredient category, and the results of prior responsible sourcing audits from around the world, covering health and safety, human rights, business integrity, and the environment.

All suppliers are expected to comply and participate in the program by submitting a SMETA-compliant audit or SAQ when requested.

Responsible Sourcing Audit Overview

In fiscal 2023, 216 audits were conducted as required by GMI Responsible Sourcing audit program and 237 audits were mutually recognized for a total of 453 audits. These occurred across General Mills company owned manufacturing, co-manufacturers, and Tier 1 suppliers.

*Significant incidents require the supplier to go through a root cause analysis and submit a Corrective Action Plan (CAP). In addition, a documented review by the audit company validating that the finding has been closed properly is required.

Remediation

Responsible sourcing audit findings are addressed via an internal escalation process that requires leadership team approval and sign-off. We are building consistent processes for the remediation of human rights violations, which are informed by the UNGP framework of “cause, contribute to, and directly linked to”.

High-Risk Ingredient Sourcing

Some raw materials have a higher likelihood of modern slavery risks due to conditions in the countries in which they are grown and/or the typical practices associated with their production. General Mills is conscious of this – especially concerning cocoa, vanilla, palm oil, seafood, and sugarcane – and has a range of measures in place to address those risks. These approaches are described in the following section. 

Cocoa

We work with key suppliers to provide direct support to cocoa-growing communities in West Africa, addressing systemic challenges and enforcing our Supplier Code of Conduct, which prohibits forced and child labor.

We are a member of the World Cocoa Foundation (WCF), which works with the food industry to address social and environmental issues in the cocoa supply chain. Since signing on to WCF’s Cocoa & Forests Initiative in March 2017, we have worked closely with suppliers, NGOs, and Proforest to identify strategic actions to protect and restore forests, increase sustainable production, and promote social and community engagement. In fiscal 2023, we published renewed action plans for Côte d’Ivoire and Ghana through calendar year 2025. We also engage our cocoa suppliers to implement programs in cocoa growing communities that support smallholder farmers, their families, and their communities.

In addition to supplier programs, General Mills and Care International launched the Cocoa Sustainability Initiative (CSI) in 2014 to improve smallholder cocoa farmers’ livelihoods and well-being in Ghana and Côte d'Ivoire. The program addresses low agricultural incomes and productivity through Good Agricultural Practices (GAP) Training, improved access to inputs, and strengthening of agricultural cooperatives. Activities including Village Savings and Loans Associations (VSLAs), Women’s Groups, and Community Development Committees aim to increase agency, resiliency, and self-efficacy of communities and individual beneficiaries. Program activities include initiatives that create community awareness around child labor for mitigation and prevention, through educating parents about the risks of child labor, the importance of children under 15 returning to school, and the provision of birth certificates. General Mills also partners with PUR to support smallholder cocoa farmers with clean cookstoves for improved health, income diversification and stronger livelihoods, and ecological resilience through agroforestry programs in Ghana and Côte d'Ivoire.

As we assess the effectiveness of our approach, we learned from a 2020 third-party evaluation of our partnership with CARE under the Cocoa Sustainability Initiative that child labor awareness programs are most effective when coupled with initiatives to address the financial and institutional barriers to schooling. For example, cooperative and community leaders indicated that the continued economic empowerment of women is key to reducing child labor, as women are more likely to invest their money in children’s education and wellbeing. These steps are often more effective than conducting sensitization training alone, which is often a focus of community development activities.

Palm Oil 

The palm oil supply chain can have significant impacts on workers, communities, and the environment. We are dedicated to sourcing palm oil in a socially and environmentally responsible manner to help move the industry forward. We partner with Proforest, a non-profit focused on sustainable and responsible sourcing, to advance our strategy, which has several key components: certification, supplier engagement, supply chain traceability, grievance management, as well as sectoral collaboration and investment at origin. 

Certification

Since fiscal 2015, all of our palm oil has been sourced through purchases meeting Roundtable on Sustainable Palm Oil (RSPO) standards, which includes human rights criteria. We have continued to shift from certificates to mass balance and segregated palm oil, which together accounted for over 99% of our purchases in calendar year 2022. In cases where certificates are needed, we use the industry standard of RSPO PalmTrace credits.

Supplier Engagement

Proforest supports us to evaluate the performance of our Tier 1 suppliers each year, in order to ensure compliance with our palm policy commitments and to help drive improvement through the supply chain. Proforest also supports us to investigate grievances and provides recommendations for Tier 1 supplier follow up.

Collaboration at Origin: Indonesia, Brazil and Guatemala

General Mills is collaborating with Musim Mas Group to implement a program designed to integrate independent smallholders from villages neighboring the Leuser Ecosystem in Aceh Singkil, Sumatra, Indonesia, into the sustainable palm oil supply chain to reduce deforestation and improve livelihoods. We recognize the opportunity for industry investment at origin in partnership with key upstream suppliers to support smallholders in addressing environmental, social, and economic challenges, and we are now putting this into practice in the Aceh Singkil region. We are pleased to partner with Musim Mas to invest in a smallholder hub program, working in collaboration with local government to improve the economic security of smallholders and assisting smallholders on their journey towards sustainable production, through collaboration with local government. Investment from General Mills supports the capacity building of village extension officers who provide Good Agricultural Practices, financial literacy, and NDPE (No Deforestation, No Peat, No Exploitation) training and resources to smallholders.

In fiscal 2023, General Mills also joined the Aceh Landscape program stewarded by Earthworm Foundation in Aceh Indonesia: Aceh Selatan, Aceh Singkil and Subulussalam. Together with a coalition of government, corporate, and NGO partners, the program vision is to create a resilient landscape which presents a compelling case for the feasibility of balancing commodity production, forest conservation, sustainable livelihoods, and good social and workforce practices at scale. Philanthropic investment from General Mills supports community land rights initiatives, contributing to participatory mapping and land tenure studies as well as technical support on solving land tenure issues.

General Mills has also partnered with Earthworm Foundation for additional investments in Brazil and Guatemala to advance land rights and forest protection in these key palm supply sheds. Through these investments, we remain committed to working with our suppliers, peers and partners to support the development of forest-positive and people-positive palm oil supply chains.

Supply Chain Traceability

In 2023, we continued working with Proforest to trace our palm oil supply chain, identify risks, and ensure responsible sourcing. At the end of 2022, 97% of our palm oil volume was categorized as traceable to the extraction mill. We are driving toward increased public transparency regarding upstream supply and expect all of our palm oil suppliers to follow a similar practice.

Palm-Specific Grievance Management

Since 2018, we have received an increasing number of producer related grievances relating to non-compliance with our policies on respect for land and labor rights. To ensure the effective handling of these cases, we introduced our internal Grievance Handling Process and our public Palm Oil Grievance Tracker. Our internal grievance management system encompasses grievances related to human rights. We have quarterly grievance committee meetings with Proforest to discuss and monitor grievance reports, agree on actions where there is verified non-compliance with our policy, and thereby ensure remediation and future compliance. Where there is persistent failure to cooperate in delivering timely remediation of noncompliance, as a final resort, we take steps to remove those producers from our supply chain.
Read more about our Statement on Palm Oil here: https://www.generalmills.com/how-we-make-it/healthier-planet/sustainable-and-responsible-sourcing/palm-oil

Sugarcane

Our goals in responsible sourcing of sugarcane are to address the following:

• Labor rights, including child and forced labor, and working conditions related to worker health, safety, and hours
• Improving visibility to the origin of purchased sugarcane 
• Addressing soil health issues related to agriculture

   

We leverage our Bonsucro membership and the organization’s Production Standard, plus related credits to help farmers and mills measure increased productivity while reducing key environmental and social impacts. We also partner with Proforest to identify and advance strategic actions for social and environmental impact, including engaging with Proforest in an origin-level program in Mexico to improve the working conditions and the safety and well-being of workers alongside improved production practices for ecological impact.

Vanilla

Economic viability, the ability of smallholder farmers to earn enough from the crop to support their families, is a challenge in vanilla farming. We work to advance sustainable vanilla in the Sava region of Madagascar. We support smallholder farmer co-op development in key sourcing communities and fund People Power Inclusion to administer capacity-building Village Savings and Loan Associations. We also partner with Duke University’s SAVA Conservation program to engage vanilla growing communities in order to advance regenerative agriculture practices, improve farmer livelihoods, and protect forests and natural resources in the Sava region.

Seafood

The breadth and global scope of seafood source geographies and supply chains drive significant complexity for both social and environmental issues. In fiscal 2022 and 2023, General Mills engaged the NGO Conservation International as a third-party partner to review and strengthen our engagement in seafood supply chains, including risk assessment and mitigation strategies and identification of potential environmental and social impact opportunities.

Assessing Effectiveness

Human rights abuses are complex issues requiring comprehensive approaches. In fiscal 2020, we assessed the effectiveness of our existing approach to human rights by conducting an internal review and partnering with Shift to assess our strengths and opportunities. We then developed our updated strategy on human rights to address the identified challenges. Our cross-functional Human Rights Integration Team meets bi-weekly to discuss progress and challenges to implement our plans, in addition to external events, which might require additional actions. As we work to address human rights risks, we continue to partner with local NGOs and stakeholders to assess effectiveness.

Looking Ahead

Our journey to advance human rights is one of continuous improvement. As we grow our capacity and develop our program, we plan to expand our disclosures in line with the UNGP reporting framework. Our focus in the coming year includes:

• Continue building due diligence capabilities to proactively identify risks where impacts on people are most severe across our value chain
• Building on the enhancements to date to our Responsible Sourcing program, we plan to pilot program expansion to indirect and Tier 2+ suppliers
• Re-assessing our most salient human rights risks to build on and update existing analysis
• Integrating human rights considerations into environmental strategies and Climate Transition Action Plan
• Increasing employee awareness of our human rights strategy
• Integrating expectations into standard business processes

Hereby signed,

Jeff Harmening

Chairman of the Board and CEO, General Mills, Inc.