Supplier Code of Conduct

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Introduction and Objectives

Our Sustainability Position: Our Healthy Lives Mission is our commitment to meet the evolving health and well-being needs of our consumers, act responsibly with the earth’s natural resources and the impacts we create, and govern our business with a strong sense of accountability, which includes our relationships with suppliers. Our goal is to advance human health and manage potential risks in the supply chain while mitigating impacts to the environment. Quite simply, we cannot care for people without caring for our planet. We are actively committed to improving the environmental impact of our products, packaging, operations and supply base. These are our responsibilities and involve colleagues working across every function and geography, including our suppliers.

Our Commitment to Building a Responsible Supply Base: We are committed to working with those who align with and reflect our values and principles, support our Healthy Lives Mission and uphold high standards for responsible sourcing and corporate citizenship. In line with the Kenvue Values, we are committed to doing business with suppliers who uphold the same high standards of integrity, ethics, and responsible business practices that we do, including complying with applicable laws and regulations, in the countries in which we, and our suppliers, operate.

Purpose and Scope of this Document: Inspired by our Healthy Lives Mission and underpinned by international standards, this Supplier Code of Conduct (the “Code”) sets forth the values, principles, and expectations regarding the ethical, social and environmental conduct we expect from our suppliers. In addition to adhering to the expectations outlined in this document, we expect our suppliers to uphold similar requirements in their own business partnerships, to encourage those partnerships to cascade our expectations to their suppliers, and to make reasonable efforts to disclose information to Kenvue, where relevant to the Code. We are committed to engaging with our suppliers in constructive and collaborative ways, including assisting suppliers with capability-building and advancing shared goals through innovative partnerships. Adherence to this Code is validated via our monitoring and audit approach, and in support of international standards, we will also ask suppliers to share relevant data with us, including, for example, on supply chain transparency, to ensure that we are able to comply with the complex legal and regulatory requirements that apply to us.

Healthy People

Our Commitment to Human Rights in the Supply Chain: As a global company, we are committed to protecting and respecting human rights as defined by internationally recognized human rights standards, including the International Bill of Human Rights, the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work and the UN Guiding Principles on Business and Human Rights. We expect our suppliers to uphold the same high standards for the protection of human rights. All suppliers shall comply with the Human Rights Principles outlined below, and our due diligence processes which include assessing and managing human rights risks across our supplier base, and monitoring supplier compliance with labor, employment, environmental and business ethics standards. In support of these standards and protocols, we may ask suppliers to share relevant information in order to allow us to comply with our own legal and regulatory obligations.

Hours, Wages and Benefits: Ensure that working hours are reasonable, workers are paid fair wages for all hours worked and are provided with adequate benefits. Suppliers shall:

  • Pay fair and equitable wages and provide benefits (statutory or negotiated) that meet or exceed the legal minimum for all hours worked.
  • Not require employees to work more than the regular and overtime hours stated in local laws and regulations.
  • Compensate overtime at a premium rate in line with the law as a minimum standard.

Freedom of Association and Collective Bargaining: Respect employees’ right to choose, form, and/or join a trade union and engage in collective bargaining. Suppliers shall:

  • Protect and respect the rights of workers to associate, organize and bargain collectively in a lawful and peaceful manner without penalty or interference.
  • Enter discussions and negotiations in good faith and not discriminate against worker representatives and/or union members.

Forced Labor and Human Trafficking: Strictly prohibit any use of human trafficking or forced labor under any circumstances. Suppliers shall:

  • Not accept or condone any aspect of forced or compulsory labor.
  • Ensure that all employment is conducted based on freely agreed upon and documented terms of employment.
  • Ensure all workers have freedom of movement and do not have to pay fees or deposits in connection with obtaining employment.
  • Strictly prohibit their employees, suppliers, and other business partners from engaging in human trafficking-related activities.

Child Labor and Young Workers: Prohibit child labor and protect young workers in compliance with laws and international standards. Suppliers shall:

  • Support and comply with all applicable child labor laws and regulations across their operations and own supply bases.
  • Protect young workers in an approach consistent with the ILO labor standards outlined in ILO Conventions No. 138 and 182.

Non-Discrimination and Anti-Harassment: Create and maintain workspaces that are free from all forms of discrimination and harassment, including physical, sexual, verbal, and psychological/ mental abuse, harassment, or coercion. Suppliers shall:

  • Ensure that no workers are subject to any form of discrimination or harassment based on gender, race, ethnicity, religion, age, disability, sexual orientation, gender identity, pregnancy, marital or parental status, nationality, political affiliation, trade union membership or any other status protected by applicable law.
  • Make employment decisions based on merit, considering qualifications, skills, and achievements.
  • Implement systems to prevent, identify, and remediate prohibited worker treatment and impose disciplinary measures that are proportionate and fair, including safe channels to speak up and grievance mechanisms free from the risk of retaliation.

Safe and Healthy Workplace: Proactively maintain safe and healthy workplaces. Suppliers shall:

  • Respect the entitled right of all employees to work in a clean, orderly, and safe environment and comply with all applicable health and safety laws and regulations.
  • Maintain compliance with applicable workplace safety and industrial hygiene standards, as mandated by applicable laws and regulations.

For more information on Kenvue’s principles and approach, please visit our position on human rights and our position on quality, safety and compliance.

Healthy Planet

Our Commitment to Sustainability and Environmental Stewardship Across the Supply Chain: We are committed to continuously improving our sustainability efforts through our brands, products, packaging, and operations, delivering on current requirements that reflect the values of today’s consumers, and we know that we cannot achieve this without the partnership of our suppliers. Accordingly, suppliers are expected to operate in a sustainable and environmentally responsible manner, as set forth in the principles below, including continually working to reduce and mitigate the environmental impacts of their operations, implementing programs that ensure compliance with relevant environmental laws and regulations, and encouraging their supplier bases to do the same. We may ask suppliers to share relevant information in order to allow us to comply with our own legal and regulatory obligations on environmental matters.

Water and Waste: Embrace the responsible management and stewardship of water and waste and take proactive steps to assess and address pharmaceuticals and personal care products in the environment. Suppliers shall:

  • Comply with all relevant laws and regulations pertaining to the treatment and safe disposal of water and waste.
  • Encourage environmental stewardship by implementing programs, where relevant to their business, to identify and mitigate issues related to water management.
  • Where relevant to their business, commit to controlling the concentrations of active pharmaceutical ingredients or other relevant substances that may enter the environment from manufacturing plants, and managing waste responsibly through generation, collection, storage, transportation, and disposal.

For more information on Kenvue’s approach to environmental impact please visit our position on the impact of pharmaceuticals and personal care products in the environment.

Plastics and Packaging: Take steps to reduce dependency on single-use plastics and prioritize the improvement of the environmental profile of packaging materials. Suppliers shall, where relevant to their business:

  • Implement programs to promote the circular design of products and packaging to be reused, recycled, or composted and increase recycled content in products and packaging materials.
  • Ensure transparency of plastic and other relevant materials’ inventories (including paper, or raw materials or ingredients which may contribute to deforestation) and engage in traceability efforts including providing relevant plastics or other materials’ data.

Raw Materials and Conflict Minerals: Uphold human rights standards and environmental standards related to materials across the supply chain, work to detect and eliminate conflict mineral sources and to understand and reduce environmental harm or degradation, including in relation to materials that may contribute to deforestation or human rights abuses.

Suppliers shall, where relevant to their business:

  • Ensure (1) key agricultural materials, including those derived from plant and forest materials, are sourced and/or produced in line with laws and regulations related to the use and protection of natural resources, (2) appropriate standards of facilities have been determined, and (3) appropriate due diligence and verification have been carried out on the origin, source and chain of custody for materials that may come from areas that are at risk for deforestation or human rights abuses.
  • Conduct due diligence and provide verification on the origin, source, and chain of custody of minerals which may come from conflict-affected or high-risk areas, including areas for which applicable laws and regulations provide reporting requirements and/or usage, import or export restrictions (‘conflict minerals’).

For more information on our approach to materials, please visit our position on responsible materials management, palm oil sourcing and paper and wood fiber.

Climate Action: Operate in an environmentally responsible manner to reduce greenhouse gas emissions. Suppliers shall:

  • Optimize the use of natural resources and materials, improve energy efficiency, transition toward low-carbon energy sources and manage and measure greenhouse gas (GHG) emissions associated with their business operations and products.
  • Seek opportunities to reduce their GHG emissions and share information on these efforts with Kenvue.

Biodiversity: Conduct business in a manner which protects, preserves, and restores nature and biodiversity. Suppliers shall:

  • Implement policies or programs to prevent deforestation, pollution, or species endangerment in connection with the supply of their materials.
  • Where relevant, develop systems and processes that maintain, enhance or restore the integrity, connectivity and resilience of all ecosystems and halt or restore biodiversity loss, in accordance with the UN Global Biodiversity Framework.

Healthy Practice

Our commitment to ethics and business integrity in the supply chain: To realize the extraordinary power of everyday care, we are committed to building trust with our stakeholders by holding ourselves accountable to high ethical standards in everything that we do. Our core values of putting people first and earning the trust of our customers and consumers are extended to our suppliers, who are expected to uphold fair business practices, to act in full compliance with applicable laws and regulations, and to meet Kenvue’s requirements as set out below.

Product Safety and Quality: Deliver end-to-end quality excellence and safety across all stages of the product lifecycle, in line with the Kenvue Quality System Principles. Suppliers shall:

  • Adhere to Kenvue Quality System Principles and any additional safety and quality specifications agreed upon in relevant Quality Agreements, purchase orders, or contracts.
  • Have systems, processes and requirements in place to ensure that their quality, purity and manufacturing meet laws, regulations and industry standards.
  • Align with industry-accepted norms of scientific and technological ethics for conducting research and development, and operating any business, responsibly.

For more information on our approach to product safety and quality, please visit our position on quality, safety and compliance.

Legal Compliance: Uphold legal and regulatory standards in every aspect of business, and comply with the laws, policies and standards that guide activities around the world. Suppliers shall:

  • Comply with all applicable laws and regulations of the countries, states, and localities in which they operate. This includes, but is not limited to, laws and regulations related to ethical business practices, anti-trust or competition law, quality, labor and employment practices, health and safety, environmental protection, data privacy and protection, and economic sanctions (including embargoes), and any other laws that are otherwise applicable to the products and/or services provided to Kenvue.
  • Abide by industry standards of conduct relevant to the areas described in this Code.
  • Obtain, maintain, and operate in accordance with all applicable permits, licenses, and registrations.

Non-retaliation: Support an open environment where individuals feel comfortable asking questions and reporting concerns. Suppliers shall:

  • Have a system in place to empower workers to report concerns or grievances in the workplace, free from fear or threat of reprisal, retaliation, intimidation, and harassment.

Anti-Corruption and Bribery: Operate with high standards of business integrity as a global and socially responsible company by opposing bribery and corruption in all forms. Suppliers shall:

  • Comply with all applicable anti-bribery laws, including but not limited to the U.S. Foreign Corrupt Practices Act (“FCPA”).
  • Not offer, promise or give anything of value to government official or private person in return for a business advantage, nor ask for or accept anything in return for Kenvue business. This includes kickbacks, facilitation payments and other illegal payments.
  • Control, account for and report on all transactions with accuracy and transparency in compliance with applicable laws, regulations and industry standards.

For more information on our zero-tolerance approach to corruption and bribery, please visit our Anti-Corruption and Anti-Bribery Position.

Data Privacy and Responsible Use of Technology: Support privacy as a fundamental human right and commit to protecting private personal information including of customers, consumers, employees, research participants and all those who do business with us. Suppliers shall:

  • Comply with all applicable data privacy and data protection laws and collect, process, use, store and retain personal information obtained from Kenvue or about Kenvue employees, consumers, customers, suppliers, and other business partners only as necessary for legitimate business purposes and in accordance with Kenvue guidelines.
  • Ensure the legal and trustworthy use of technology when processing personal information through automated processing, data analytics, machine learning and artificial intelligence, including operating appropriate cyber security practices in line with industry practices, including complying with any relevant cyber requirements set out in Kenvue’s terms and conditions or other agreements.
  • Report any incident or suspected incident that impacts the confidentiality and integrity of personal information to the Kenvue Integrity Line or to a Kenvue employee.

For more information on our approach to data privacy, please visit our Privacy Policy.

Conflicts of Interest: Prevent conflicts of interest and make business decisions based on the interest of the supplier’s company and not for personal gain or benefit. Suppliers shall:

  • Abide by all relevant laws, including those related to exchanges of value and any other special ethics rules, disclosure obligations, and conflict of interest provisions.
  • Prior to establishment of a business relationship with Kenvue, proactively and promptly disclose to Kenvue any actual or perceived conflicts of interest, including any material ownership or beneficial interest by a public official, representative of a political party, or Kenvue employee or their relatives that may influence the business relationship between a supplier and Kenvue.
  • Have systems in place to ensure all business transactions are free from conflicts of interest.

For more information on our approach to conflicts of interest, please visit our Anti-Corruption and Anti-Bribery Position.

Animal Welfare: Promote the use of non-animal alternatives when possible and use animal testing only as a last resort. Suppliers shall:

  • Use non-animal alternatives whenever feasible during the research or development of products, ingredients, and materials supplied to Kenvue.
  • When animal testing cannot be avoided, adhere to Kenvue’s principles of animal testing as communicated periodically.

For more information on our approach to animal welfare, please visit our position on animal testing.

Compliance, Monitoring and Audit

Compliance Monitoring: To verify compliance with the expectations outlined in this Code, and to support our compliance with applicable laws, Kenvue has established a compliance and audit approach that applies to suppliers that provide materials, products, and services to Kenvue. As further described in our terms and conditions, or other agreements with suppliers, this verification process may include audits performed by Kenvue representatives and/or third parties, supplier-self assessments, or other necessary measures of due diligence. This process may be modified based on the size of the supplier, the types of goods or services being provided, the country of operations and the findings from the supplier’s risk assessment. We recognize the importance of collaboration and constructive engagement to support our suppliers in building capacity to achieve the standards outlined in this Code, including corrective action plans.

Asking Questions and Reporting Concerns

We invite our suppliers to join us in the commitment to creating an open environment where individuals feel comfortable asking questions and reporting concerns, and actively encourage suppliers to prevent, mitigate, and remedy negative impacts. Any suspected violations of this Code, other Kenvue policies, or applicable laws and regulations must be reported through the Kenvue Integrity Line, our independent, secure and confidential global channel for reporting questions or concerns, or to a Kenvue employee. The Kenvue Integrity Line is available 24 hours a day, 7 days a week and in 24 languages. We will not tolerate threats or acts of retaliation in any circumstance and expect suppliers to have similar grievance mechanisms and non-retaliation provisions.

Additional Resources

The following principles, standards, and resources were used in the development of Kenvue’s Supplier Code of Conduct and should be consulted for additional reference:

Last updated: February 2024