12 The Hershey Company | 2021 ESG Report The Big Picture Our Company Cocoa Responsible Sourcing and Human Rights Environment Our People Youth Community About This Report Our Company Our Policies All contributions are disbursed pursuant to Our Code of Conduct (the Code) reflects our internal contribution guidelines and in who we are and what’s important to us, accordance with applicable election laws. All and emphasizes our commitment to acting PAC contributions are bipartisan and given ethically. It provides the policies and guidelines equally to both major political parties at the that define how we do business, including, federal and state levels. among others, those with respect to anti- Corporate funds are used to support or corruption, antitrust, whistleblower protection advocate for issues, legislation or referenda of and health and safety. All our directors and importance to Hershey and our shareholders. employees receive annual training on the Code These funds, classified under the U.S. Internal and must verify that they have read and agree Revenue Code as non-deductible lobbying with the principles it outlines. expenditures, are paid primarily to industry We also maintain several policies that control trade associations and support the salaries of how we responsibly source key ingredients our internal Government Relations personnel. and the standards and behaviors we expect In accordance with the Lobbying Disclosure from our suppliers. Other ESG policies relate Act of 1995, our company files quarterly to environmental management, human rights, lobbying reports, outlining the company’s food safety and other key concerns for our federal-level advocacy work. We also company. Our policies are publicly available on publish an Annual Report of Lobbying and our website. Advocacy Expenditures on the Investors section of our website annually. Lobbying and Transparent Policy Consistent with our Code, Hershey does not make political contributions and only engages in corporate political activities through the Hershey Political Action Committee (PAC). Funds raised through the PAC, which is made up of voluntary employee contributions, are used to support elected officials who demonstrate a commitment to the growth and prosperity of our business, the communities in which our employees live, and whose values and goals align with The Hershey Company’s vision and Code of Conduct.
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