Kellanova : 2023/2024 Human Rights Milestone

2023 Milestones Global Human Rights

Updated: April 2024

2023 Milestones

Global Human Rights

Table of Contents

Overview

Our Commitment	3
Policies & External Alignment	4
Our Business	6
Corporate Governance	7
Approach
Risk-based Approach	8
Own Operations	9
Supply Chain Operations	9
Grievance Mechanism	10
ELEVATE Supplier Assessment	13
Case Studies
Sultanas in Türkiye	17
AIM-Progress	20
ASACAM/Verite	20
Conclusion	21

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OVERVIEW

Our Commitment

In October 2023, Kellogg Company separated its North American cereal business and became Kellanova, a leading company in global snacking, international cereal and noodles, plant-based foods, and North American frozen breakfast. The name "Kellanova" signals our ambition for the future, building on the strong brand equity and legacy built over the previous 117 years as Kellogg Company. Like Kellogg Company, Kellanova believes that a key to running a good business is doing good for our communities, planet and people. Kellanova is proud to continue the Better Days Promise social and environmental purpose strategy set forth by Kellogg Company, while increasing our ambitions with expanded commitments.

Kellanova Better Days Promise is our commitment to advance sustainable and equitable access to food by actively addressing the intersection of wellbeing, hunger, sustainability and equity, diversity and inclusion (ED&I). In doing so, we are committed to create better days for 4 billion people by the end of 2030 (from a 2015 baseline).

Globally, we have been working to protect and advance human rights for over a decade. As we have continued to strengthen our work in this area, in our own operations and direct and indirect supply chains, we have had the opportunity to partner with suppliers, industry peers, civil society, investors, and a broad range of stakeholders. We

know that we can't achieve change alone. To tackle issues like modern slavery and forced labor, we need to continue to

leverage best practices and support innovative solutions through continued collaboration.

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To better communicate our responsibilities, commitments and expectations, our Global Human Rights Policyaligns with

theUN Guiding Principles on Business and Human Rights (UNGPs). By taking a risk-basedapproach, we strive to ensure we are focusing on issues most relevant to our business and its operations where we can drive the most impact. Building on our global framework, Kellanova is using credible third-partydata to further our understanding of these salient risks and identify actions we can take to better prevent, mitigate and remediate adverse human rights impacts. Unsurprisingly, these risks are not dissimilar to those faced by peer organizations who operate in the food, beverage and grocery sector, which is why collaboration is so important to address systemic issues geographically and within specific commodities. This report details our approach to protecting and advancing human rights within our operations and supply chain and outlines some of the key actions we are taking globally in response to identified and potential issues. You can learn more about our workhere.

Policies & External Alignment

Our Global Human Rights Policy highlights salient rights risks within our operations and global supply chain and details our strategy for prevention and mitigation. These risks were identified through a detailed internal materiality analysis and with the support of a third-party consulting firm, ELEVATE. This policy supplements our other foundational policies, the Global Supplier Code of Conductand Policy Statement Prohibiting Involuntary Labor, that guide our operations and inform our expectations for supplier and supply chain partnerships.

Furthermore, Kellanova supports all internationally recognized human rights as codified in the UNGPs,International Bill of Human Rights(including the Universal Declaration of Human Rights) and the eight International Labour Organization (ILO) core conventions as set out in the Declaration on Fundamental Principles and Rights at Work. As signatories, we are also committed to upholding the ten principles of the United Nations Global Compactand the Women's Empowerment Principles. We also reference and follow the OECD Guidelines for Multinational Enterprises. Kellanova believes these rights are inherent for all human beings and we acknowledge that they are interrelated,

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OVERVIEW

interdependent and indivisible. We are committed to ensuring our operations do not infringe upon the human rights of others and that, should adverse impacts be discovered, we will seek remediation aligned with our policies, international standards, and the expectations of our customers, consumers and stakeholders.

"From our earliest days, we have been a purpose-driven organization. We've long believed and understood that a critical part of running a good business also is doing good for society. Today, as Kellanova, this vision continues to inspire our philanthropy, sustainability and social equity work. We work hard to make sure that our company and our business practices deliver benefits to people, to communities and to the planet. We take very seriously our commitments and our support of the communities we serve. It is the foundation of everything we do."

- Steve Cahillane, Chairman, President and CEO

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Our Business

Kellanova is a global consumer goods company with manufacturing operations in 20 countries and products marketed in 180 countries.

We work with over 20,000 Tier 1 suppliers. Agricultural commodities including corn, wheat, potato flakes, vegetable oils, sugar and cocoa are the principal raw materials used in our products. Carton board, corrugated and plastic are our principal packaging materials.

Our principal products are snacks, such as crackers, savory snacks, toaster pastries, cereal bars, granola bars and

bites, and convenience foods, such as ready-to-eat cereals, frozen waffles, veggie foods and noodles. We also

steward a suite of international cereal brands.

These foods are sold to retailers through direct sales for resale to consumers. We use broker and distributor arrangements for certain products and channels, as well as less-developed market areas or in those market areas outside of our focus.

Our snacks brands are marketed under brands such as Kellogg's, Cheez-It,Pringles, Austin, Parati, and RXBAR. Our

cereals and cereal bars are generally marketed under the Kellogg's name. Our frozen foods are marketed under the

Eggo and MorningStar Farms brands. Our international cereal brands include Kellogg's Frosties, Zucaritas, Special K,

Krave, Miel Pops, Coco Pops and Crunchy Nut, among others.

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Corporate Governance

At the board level, social issues are overseen by the Social Responsibility and Public Policy subcommittee of the Kellanova Board of Directors, which assists the Board in its oversight responsibilities of social and public policy issues.

At the executive level, human rights issues are overseen by the Chief Sustainability Officer, who reports to the Senior Vice President, Chief Global Corporate Affairs Officer. We also engage functions across the business such as Human Resources, Procurement, Environment Health & Safety, and Legal to assess and track our global activities to inform our strategy and actions. Each group is involved in decisions related to issues such as child labor, forced labor, freedom of association and collective bargaining, health and safety, land rights, water and sanitation, and women's rights.

At the daily work level, these topics are managed collaboratively by our Corporate Affairs, Procurement, Legal, Human Resources, and Supply Chain functions.

Accountability is an important aspect of the Kellanova's corporate culture. Our Office of Ethics and Compliance serves as a resource for clarification of Company policy or reporting issues related to ethics and business conduct. Employees and suppliers are encouraged to contact the Ethics Office without fear of retribution or retaliation. We protect the confidentiality of all reporting sources.

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Risk-Based Approach

We are committed to engaging and partnering with peers, suppliers, NGOs, and stakeholders to find solutions to issues within our extended and overlapping global supply chains. We set clear expectations, seek to drive accountability, and assess potential and actual risk that our operations may cause or contribute to, both directly and indirectly.

Kellanova utilizes a combination of publicly available indices from reputable sources, including SedexRadar, to assess forced labor risk, 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.

Kellanova high-risk priority ingredients and sourcing countries combinations:

According toU.S. Department of Labor ILAB

	Brazil
	Colombia	Ghana	Malaysia
	Thailand	Cote d'Ivoire	Indonesia
	Mexico
Sugar	Cocoa		Palm Oil
cane

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Own Operations

40	38%	27%
Total Owned	Facilities Considered High Risk	High Risk Facilities Audited in
Facilities		2023

In 2023, Kellanova performed annual third-party audits for four of our highest-risk facilities. As part of our ongoing efforts to identify, prevent, mitigate and remediate issues within our own operations, we are committed to expanding our audit capabilities to all our high-risk facilities to ensure continued compliance with internal and international standards of human rights due diligence.

Supply Chain Operations
	In-scope Suppliers Registered with Sedex
77%	82%	90%	68%
North America	AMEA	Europe	Latin America

As of December 2023, 79% of global in-scope suppliers have registered with the Sedex platform; of those, 79% have registered and linked all Kellanova supplying sites. We have annual goals to maintain 90% in-scope suppliers registered and active on the Sedex platform and 90% of all sites linked. This aids Kellanova to more accurately track Tier 1 supply chain locations and assess current audit status, including open non-conformances or pending actions. In- scope refers to suppliers within the Top 80% spend profile, all high-risk commodity suppliers (palm oil, cocoa, sugar cane), and/or those with high exposure to contract labor.

We are continuing to work with our suppliers to achieve completion of the Sedex Self-Assessment Questionnaire to better assist risk profiling and commodity/country risk exposure.

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Grievance Mechanism - Kellanova Ethics Line

Our Kellanova Ethics Lineoffers a confidential way for employees, suppliers, contractors and the general public to ask questions and report concerns regarding ethics, compliance or any other requirements in our Global Code of Ethics and Supplier Code immediately and anonymously 24 hours a day, 7 days a week via telephone, internet or mobile app. The Kellanova Ethics Line is operated for Kellanova by a third-party, confidential reporting company and is always available to Kellanova employees in 21 countries. The operator will listen to concerns or inquiries and provide a written summary to the 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.

2023 Kellanova Ethics Line Complaints (as of Dec. 31, 2023)*

Number of Complaint Tickets Received	580
Number & Percent of Complaint Tickets Closed	460 (79.3%)
Number & Percent of Complaint Tickets Substantiated	148 (25.5%)
* No forced labor complaints

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