17 OUR COMMITMENT TO SOCIAL IMPACT & SUSTAINABILITY ETHICS We promote a culture of uncompromising ethics and integrity. Our standards help us uphold the principles and ideals that make us a global leader in prestige beauty. We expect our employees and business partners to conduct business in compliance with applicable laws and regulations and with the high ethical standards and policies set forth in our Code of Conduct (“Code”) and Supplier Code of Conduct . Our Code helps to protect our reputation as an ethical corporate citizen. Newly hired employees are required to sign an acknowledgement that they have received, read, and will comply with the Code. In addition, annually, employees above certain levels are required to complete Ethics and Anti-Bribery and Corruption trainings and acknowledge the Code. From time to time, we conduct trainings on the Code for groups of our employees. Employees are expected to raise questions or concerns about conduct that may be inconsistent with the law, the Code, or other policies to their supervisor, Human Resources contact, the Global Ethics team, and through The Estée Lauder Companies’ Integrity Helpline. Employees are able to communicate and report suspected violations confidentially and anonymously, where permitted by law. Employees can raise questions or concerns by calling the toll-free number, visiting the Integrity Helpline website, or sending a text message (text communication available in North America only). Additionally, questions or concerns related to questionable accounting, internal controls, or auditing matters can also be raised directly to the Audit Committee of the Board of Directors. We have standard operating procedures to manage reports to ensure consistent investigation and response procedures across incident types and reporting channels. Serious violations are reviewed by the Company’s Ethics and Compliance Committee, which oversees implementation of the Code. The Ethics and Compliance Committee reports to the Audit Committee on a regular basis regarding the effectiveness of our Global Ethics Program. The Company’s Internal Audit function periodically reviews business unit operations using a risk-based audit plan. Internal Audit regularly assesses the effectiveness of the Company’s Ethics and Anti-Bribery and Corruption programs through routine and targeted audits of business functions and/or sales affiliates. OUR VIEW ON HUMAN RIGHTS The United Nations Guiding Principles on Business and Human Rights provide a framework to help us identify and prioritize our human rights risks and impacts. Proactive human rights due diligence is an ongoing process, and we have policies, processes, training, and systems in place to identify, assess, monitor, and mitigate or eliminate actual or potential human rights impacts. Our Code of Conduct outlines our expectations for promoting a respectful workplace, engaging in ethical business practice, and operating in a socially responsible and fair manner. We require our employees, business partners, service providers, and suppliers to operate in compliance with all applicable laws, including, but not limited to, employment laws pertaining to child labor, minimum wage, overtime compensation, hiring, and occupational safety. Our Supplier Code of Conduct sets forth the basic requirements we expect of suppliers, including vendors, service providers, independent contractors, and consultants, as a condition of doing business with our company. It is based on internationally recognized standards, including the Universal Declaration of Human Rights and International Labour Organization’s Conventions. Read more about our Supplier Code of Conduct on page 69.