Human Rights

Our founder W.K. Kellogg said: “Dollars have never been known to produce character, and character will never be produced by money. I'll invest my money in people.”

As a global company, Kellogg has a responsibility to respect and advance human rights. Our commitments extend throughout our value chain – from our operations, to our supply chain, to the farmers that grow our food, the workers that make our products, and to the people that enjoy our foods every day. 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, for 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 where we can and support innovative solutions through continued collaboration.

Policies and external alignment

To better communicate our responsibilities, commitments, and expectations, we updated our Global Human Rights Policy in 2020 to align with the UN Guiding Principles on Business and Human Rights (UNGPs). By taking a risk-based approach we strive to ensure we are focusing on issues that are most relevant to our business and its operations where we can drive the most impact. Building on our global framework, Kellogg is using credible third-party data 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.

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 Conduct and Policy Statement Prohibiting Involuntary Labor, that guide our operations and inform our expectations for supplier and supply chain partnerships.

Furthermore, Kellogg is committed to, aligned with, and 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 Compact and the Women’s Empowerment Principles. We also reference and follow the OECD Guidelines for Multinational Enterprises. Kellogg believes these rights are inherent for all human beings and we acknowledge that they are interrelated, 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 Kellogg policies, international standards, and the expectations of our customers, consumers, and stakeholders.

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.

Kellogg utilizes a combination of publicly available indices from reputable sources, including Sedex Radar, 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.

Grievance mechanism

Our Ethics Hot Line offers a confidential way for employees, suppliers, contractors and the general public to ask questions and report concerns in relation to 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 Ethics Hot Line is operated for Kellogg by a third-party, confidential reporting company and is always available to Kellogg 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.

Click here to learn more about Kellogg’s Ethics Line or to report a concern.

ELEVATE supplier assessment

In 2019, Kellogg partnered with ELEVATE to develop a comprehensive long-term, data driven responsible sourcing strategy that addresses salient rights risks within priority Tier 1 ingredient and packaging supply chains. For the first two phases of this program, we concentrated on segmentation and categorization of in-scope* suppliers and execution of risk assessments for prioritized Tier 1 supplier sites.

Based on the initial segmentation results, Kellogg and ELEVATE partnered with 16 suppliers representing 27 individual site locations to administer four types of risk assessments. Each site location was assigned at least one assessment type. The type of assessment administered was chosen based on criteria such as geographical location, primary facility operation, migrant worker presence, and inherent social risks. These assessments included:

Worker Voice Survey:
- Worker Sentiment Survey, or
- Critical Issues Survey
On-site Social Assessment – ELEVATE Responsible Sourcing Assessment (ERSA)
Child Labor Self-Assessment Questionnaire (SAQ)

Our goal for the execution phase of the program was to partner with our Tier 1 suppliers to gain a deeper understanding of potential and actual human rights risks present within our direct supply chain. By using assessment types that focus on targeted information related to inherent social risks we sought to go beyond standard audit data collection and achieve actionable insights to address issues that directly affect workers on site.

The assessment execution phase ran primarily from November 2020 through April 2021, with full site completion by the end of 2021. For results and analysis, please see our 2020 Human Rights Milestones report here.

In 2022, we kicked off phase three—remediation and capacity building—with participating supplier sites. During this phase, supplier site representatives had the opportunity to work back with the Elevate team to action on issues found during the assessment process. The goal for the remediation and capacity building engagements was to help each site understand the results of the specialized assessment, build internal capacity to manage and further investigate risks, remediate identified issues, and implement effective preventive actions to mitigate future risk.

Beginning with a review of the site’s specialized assessment results, the ELEVATE team and site representatives worked to identify potential root causes for issues, identify areas for improvement, participate in eLearning courses to share best practices, and support development of a timebound action plan to remediate issues identified through the assessments.

The remediation phase concluded at the end of 2022 and results and analysis will be available in Q3 2023.

Learn more

Click here to view our Global Human Rights Policy and our latest Human Rights Milestones document, which contains comprehensive information on our approach and outcomes. The ESG A to Z 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