Human Rights

Kellanova is committed to protecting, respecting and advancing the cause of human rights across our value chain in our work internally, externally and in our corporate priorities. Our Global Human Rights Policy highlights salient human rights risks within our operations and global supply chain and details our human rights strategy for how we are working to prevent and mitigate high-risk issues. This policy supplements our other foundational policies – the Global Supplier Code of Conduct and Policy Statement Prohibiting Involuntary Labor – that guide our operations and inform our expectations for supplier and supply chain partners.

Kellanova’s Human Rights Policy was crafted in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises. We are committed to upholding the rights enshrined in the International Bill of Human Rights (including the Universal Declaration of Human Rights) and the eight International Labour Organization (ILO) fundamental conventions as set out in the Declaration on Fundamental Principles and Rights at Work. This includes our commitment to the four core conventions - Freedom of association and the effective recognition of the right to collective bargaining (Convention No. 87 & No. 98), the elimination of all forms of forced and compulsory labour (Convention No. 29 & No. 105), the effective abolition of child labour (Convention No. 138 & No. 182), and the elimination of discrimination in respect of employment and occupation (Convention No. 100 & No. 111). Kellanova is a signatory of the United Nations Global Compact and we intend to communicate our progress annually.

Risk-Based Approach

We are committed to engaging and partnering with peers, suppliers and civil society to find solutions to issues within our global supply chains – this is essential to our work in human and workplace rights. We set clear expectations, seek to drive accountability and assess potential and actual risks that our supply chain operations may cause or contribute to, both directly and indirectly. Kellanova utilizes a combination of publicly available indices from reputable sources, including Sedex Radar and the Department of Labor’s Bureau of International Labor Affairs (ILAB), to assess forced labor and other salient risks for supplier operations by region and commodity.

• Risk factors include regional location of operations, sector or commodity, degree of salience to industry identified issues, and supplier specific information.
• Targeted facilities are asked to complete a self-assessment questionnaire detailing policies and procedures related to labor practices to identify gaps that could indicate the possibility of, or potential for, human rights abuses or nonconformance.
• Targeted facilities are also subject to audits upon request.
• We primarily use the SMETA audit scheme, which includes on site worker interviews based on the most recent methodology to determine the percentage of workers interviewed.
• We also administer worker voice surveys for in-scope supplier sites and support remediation and capacity building based on outcomes with our implementation partner ELEVATE

Grievance Mechanism

The Kellanova Ethics Hotline offers a confidential way for employees, suppliers, contractors and the general public to ask questions and report concerns about ethics, compliance or any other requirements in our Global Code of Ethics and Supplier Code. The Hotline, which is operated by a third-party, confidential reporting company, is available immediately and anonymously 24/7 via telephone, internet or mobile app in 21 countries and in local languages. The operator listens to concerns or inquiries and provides a written summary to our Office of Ethics and Compliance for investigation and further action, as appropriate.

Regional compliance leaders review and resolve complaints and inquiries consistent with our investigation protocols. All complaints and inquiries are monitored and subject to review at the corporate level. Most investigations can be completed quickly. Our goal is to complete investigations within 30 days. However, completion timelines may vary depending upon additional factors such as the availability of witnesses, etc. Appropriate action is taken based on investigation findings. Lessons learned are leveraged to prevent and detect future misconduct, ensure compliance, and identify any other opportunities for improvement.

Click here to learn more about Kellanova's Ethics Hotline or to report a concern.

ELEVATE Supplier Assessment

In 2019, Kellogg Company began a partnership with ELEVATE to support the implementation of a comprehensive long-term, data driven responsible sourcing strategy that addresses salient human rights risks within priority Tier 1 ingredient and packaging supply chains. Kellanova has proudly continued this program and partnership.

The Elevate led supplier assessment and engagement program consists of two phases:

1) Administration of one of four specialized assessments:

• Critical Issues Worker Voice Survey
• Worker Wellbeing Worker Voice Survey
• Labor Issues Worker Voice Survey
• On-site Social Assessment – ELEVATE Responsible Sourcing Assessment (ERSA)

2) Remediation and capability building

• Based on results of the specialized survey, Elevate supports the site through a three-month engagement to aid in the development of action plans to prevent, mitigate, or remediate identified areas of potential risk and root causes

Aggregated and anonymized results are reported annually through Kellanova’s Social and Environmental Report and Human Rights Milestones.

Learn more

Click here to view our Global Human Rights Policy and our Human Rights approach. The Policies and Guidelines contains a comprehensive list of our policies and guidelines.

^{* Top 80% global spend suppliers plus all suppliers within high-risk categories for cocoa, palm oil, and sugar cane}