Overview

Purpose

At Chobani, we believe that business can be one of the most powerful forces for good in the world. That extends to how we make our product, how we treat our people and how we conduct business. Beyond adhering to the highest legal and ethical standards in the industry and observing and adhering to all applicable laws and regulations, we strive to raise the bar with every decision we make. That, we believe, is how we can continue to make a difference.

This belief extends outside of just our company. As business partners of ours, we expect direct suppliers and all parties who provide goods and services to Chobani to join our commitment and conduct business in a manner that reflects and adheres to the principles and ethical standards from which our company was built. For the purposes of this Chobani Supplier Code of Conduct, suppliers and their subcontractors, agents, business partners and the like will collectively be referred to as “Supplier” or “Suppliers”.

It is an honor to have you as part of the Chobani supply chain, working together to ensure our companies positively impact our communities, our planet and our people.

Policy and Procedures

Responsible Sourcing

Suppliers must have ethical and responsible sourcing practices in place and source only from companies that satisfy the requirements of this Supplier Code of Conduct.

Grievance Procedures

Suppliers shall maintain internal programs for handling reports of workplace grievances that are anonymous, unbiased, responsive, confidential, and communicated to employees. Such reports shall be investigated, and corrective action should be taken where necessary. Procedures shall prohibit retaliation. Any reports concerning Chobani’s business are to be directed to suppliercodeofconduct@chobani.com.

Audits and Assessments

Chobani reserves the right to audit compliance with this Supplier Code of Conduct. Such audits may be conducted by Chobani or its auditing agency, and Supplier must respond within the allotted time to all audits. If an audit identifies a violation of this code, Supplier shall act promptly to correct the situation to Chobani’s satisfaction. Chobani reserves the right to suspend or terminate a Supplier who fails to correct violations.

Modifications

Chobani reserves the right to review this Supplier Code of Conduct from time to time and modify as relevant or necessary, as posted on www.chobani.com.

Human Rights and Labor

Violence and Harassment in the Workplace

Chobani believes that all workplaces should be free of violence and harassment. Suppliers shall not threaten or subject workers to harsh or inhumane treatment, including but not limited to verbal abuse, psychological abuse, mental and physical coercion, and sexual harassment. Harassment and violence towards other parties by our Suppliers is also prohibited. In addition, harassment in any communication form, includes but is not limited to: e-mail, voicemail, chat rooms, internet use or history, text messages, pictures, images, writings, words or gestures.

Non-Discrimination and Equal Opportunity

Chobani is an equal opportunity employer. As such, Suppliers shall also provide working conditions for their employees that are free from discrimination, based on factors including but not limited to age, race, religion, ethnicity, national origin, sexual orientation, gender, sex, disability, pregnancy, predisposing genetic characteristics, military status, veteran status, marital status and any other characteristic protected by federal, state or local law. Suppliers should also ensure that there are no discriminatory practices throughout the employment cycle (including hiring, compensation, promotions and terminations). Suppliers should pay special attention to vulnerable workers including but not limited to women, young workers and migrants.

Freely Chosen Employment

Chobani’s Suppliers must ensure their workforces are free from any forms of forced labor, including but not limited to slave, indentured, bonded, prison labor, or any form of human trafficking. Suppliers are expected to fully comply with the requirements of applicable slavery, forced labor, and human trafficking laws. Any restrictions for workers to voluntarily end their employment, such as notice periods in excess of legal requirements, withholding of identity papers or substantial fines for terminating their employment contracts, are prohibited

Child Labor and Young Workers

Child labor is prohibited. Suppliers must comply with all applicable laws and regulations, including ensuring all employees are above the legal employment age in the country of their employment, as well as requirements related to hiring, wages, hours worked, overtime, and working conditions.

Freedom of Association and Collective Bargaining

Chobani’s Suppliers must respect their employees’ legal rights to freedom of association and collective bargaining in accordance with valid laws and provisions. In addition, Suppliers must ensure rights of workers to make an informed decision as to whether to associate or not with any worker organization, including trade unions, are respected. Suppliers shall not retaliate in response to the exercise of such rights, and no remuneration or payment whatsoever shall be offered to workers in order to hinder the exercise of such a right.

Wages, Benefits and Work Hours

Employees are to be compensated with wages, overtime and benefits that meet or exceed legally mandated minimum standards. Compensation and benefits shall be provided in a way that is prompt, paid in full and in a language easily understood by all workers. Wages shall not be subject to deductions as a disciplinary measure. Chobani encourages Suppliers to offer their employees sufficient training and educational opportunities. Suppliers shall ensure that work schedules and overtime are consistent with applicable laws and collective bargaining agreements, whichever affords the greater level of protection, including maximum hour and rest period laws.

Workplace Safety

At Chobani, there is nothing more important than the safety of our team members. We continuously engage with our employees to develop preventative measures, set clear accountability guidelines and standards for managing safe behaviors in the workplace. Everyone’s safety matters to us and, as such, we expect our Suppliers to ensure a safe working environment for their employees. Suppliers must comply with all applicable laws, codes and regulations applicable to its locality related to safety policies. Chobani expects its Suppliers develop and implement occupational health and safety procedures and provide ongoing training to protect the health and safety of all employees in such employees’ primary language.

Environment

We believe in doing business the right and responsible way. Chobani observes and respects all applicable environmental laws and regulations. We continue to explore and implement ways to be more efficient with our consumption of natural resources and to minimize our environmental footprint. We expect our Suppliers to share in this commitment to protect and preserve the environment for future generations. Suppliers must join us and comply with all applicable environmental laws, codes and regulations of its locality.

Chobani has put in place a robust sustainability management structure focused on material ESG areas. When applicable, Chobani will work with suppliers to ensure they have the information needed to better make decisions to align with our environmental principles.

Water Use. Suppliers shall use water responsibly, especially in regions where water resources are significantly under stress. Suppliers shall also comply with local government's mandated water use, consumption and conservation policies and regulations. Waste Management. Suppliers shall responsibly manage waste generated from operations prior to its disposal. Suppliers shall dispose of waste material in an environmentally responsible manner and in compliance with all applicable laws and regulations. Energy Management. Suppliers shall manage all energy consumption that produces carbon emissions and strive to reduce consumption.

Business Ethics

Animal Welfare

At Chobani, animal welfare is more than a business practice: it is an ethical and moral imperative. Chobani does not fund, conduct, or commission any tests on animals unless they are explicitly required by law. Additionally, we support National Dairy’s FARM Program (Farmers Assuring Responsible Management). All farms supplying milk to Chobani must participate in the FARM program. We work closely with cooperatives and local farms to ensure the safety and humane treatment of the cows that provide us fresh milk. We expect all of our Suppliers to uphold this commitment.

Bribery, Corruption and Sanctions

Suppliers shall comply with all applicable anti-corruption and anti-bribery laws, including the United States Foreign Corrupt Practices Act and the OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions. Suppliers shall not engage in corrupt or unethical practices, such as offering or accepting bribes, kickbacks, favors or use of any improper influence when dealing with governmental officials or in any business arrangement. Additionally, Suppliers must fully comply with all applicable U.S. and non-U.S. export control laws and shall not engage in business with any country or region subject to comprehensive embargo sanctions by the United States, European Union or United Nations or to any individual or entity on the U.S. Department of the Treasury’s Office of Foreign Assets Control list of Specially Designated Nationals and Blocked Persons, the U.S. Department of State’s List of Debarred Parties or on the U.S. Department of Commerce’s Entity List, Denied Persons List or Unverified List.

Competition and Fair Dealing

At Chobani, we seek to outperform our competition fairly and honestly. We strive to gain competitive advantages through superior performance, not through unethical or illegal business practices. Stealing proprietary information, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures by past or present suppliers of other companies is prohibited. All Suppliers should respect the rights of, and deal fairly with Chobani’s customers, other suppliers, competitors and Chobani employees. No Supplier should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other intentional unfair-dealing practice.

Conflicts of Interest

Business, personal, or family involvement with a competitor, client, contractor, vendor, Chobani employee or anyone that may pose a potential or actual conflict with a Supplier’s contractual obligations to Chobani should be avoided.

We expect Suppliers to conduct their personal affairs in such a fashion that their responsibilities to Chobani are not jeopardized and/or legal questions do not arise with respect to their association or work with Chobani. Conflicts of interest should be avoided by all Suppliers.

Anti-Retaliation

Suppliers shall prohibit unlawful retaliation, including, but not limited to, threats, intimidation, and attacks, against individuals who report a compliance or ethical issue learned during the course of work performed for Chobani, who cooperate in good faith with the investigation of a complaint, or who defend environmental or human rights. Suppliers shall create a mechanism for employees to submit their grievances anonymously and demonstrate that their complaints are reviewed and investigated.

Last Updated 11/15/22