Supply Chain Transparency

At The Estée Lauder Companies, (“we”, “us”, “our”, or the “Company”), we respect human rights and support transparency in our supply chain. We are committed to upholding the principles contained in the United Nations Universal Declaration of Human Rights and the California Transparency in Supply Chains Act of 2010.

Under law in jurisdictions such as California and the United Kingdom, companies like ours are required to publicly disclose the steps we are taking to identify and eradicate forced labor in our supply chain. The following describes our efforts:

Verification

We require our suppliers to operate in compliance with all applicable laws, including laws pertaining to child labor. Under no circumstances does our Company allow suppliers to use child labor, prison labor, indentured labor, bonded labor, or use corporal punishment or other forms of mental and physical coercion as a form of discipline.

Our work in this area is governed by our Global Supplier Relations (GSR) team, which has representatives in each of our regions. GSR and the Responsible Sourcing Team, in partnership with Global Quality Assurance, Research & Development, Global Regulatory Affairs and Global Corporate Citizenship and Sustainability, is are responsible for ensuring that the suppliers with whom we do business meet the expectations for ethical behavior outlined in our Supplier Code of Conduct.

Our Supplier Code of Conduct is the foundation we use to set expectations. It is the basis for how we evaluate and help our suppliers meet our high ethical standards in the procurement of our product and packaging ingredients and materials. The Supplier Code of Conduct, in conjunction with our standard purchasing contracts, requires that suppliers be in full compliance with all applicable governmental, legal, regulatory and professional rules and regulations. The Supplier Code of Conduct includes the Company’s prohibition on employing children, using or benefiting from human trafficking, prison labor, indentured labor or bonded labor and engaging in any kind of physical, verbal, psychological or sexual abuse, harassment or any other forms of intimidation or misconduct.

Forced labor and child labor are included as a risk category in our supplier risk evaluations, and when necessary, we use a third-party firm to assess the potential presence of child labor or forced labor in the supply chain.

Audits

All new suppliers must agree to comply with our Supplier Code of Conduct before they are awarded our business.

We contract with third parties to conduct on-site audits for suppliers that we select based on criteria such as the location of the operations, type of material being sourced and the impact to our business. The auditors utilize our Supplier Code of Conduct Audit Standard and report format. If non-compliance is discovered, then the remedies may include, among other things, termination of business with The Estée Lauder Companies or the development and implementation of a corrective action plan that would need to be implemented within a certain fixed time period. The Estée Lauder Companies may follow such implementation by an audit, as it deems appropriate.

Certification

In addition to requiring our suppliers to comply with our Supplier Code of Conduct, the Company has used certification programs, providing third-party verification that certain raw materials we purchase are produced without the use of forced labor, including the Roundtable on Sustainable Palm Oil (RSPO) and the Forest Stewardship Council (FSC).

Internal Accountability and Training

Select employees responsible for engaging with suppliers are trained on our Responsible Sourcing Program.

Regarding our employee base, the Company is committed to the highest standards of professional and personal conduct. All employees, members of the Board of Directors and company officers are expected to conduct themselves within the letter and spirit of our Code of Conduct at all times.

All newly hired employees must sign an acknowledgment that they have received the Code of Conduct, understand its contents, and agree to comply with its terms throughout their employment with The Estée Lauder Companies. In addition, on an annual basis, certain management employees are required to re-certify their compliance with and continued commitment to compliance with the Code of Conduct.

An employee who violates a provision of the Code of Conduct, condones or knowingly fails to report a possible violation, intentionally makes a false report or fails to cooperate fully in any investigation of any violation will be subject to disciplinary action, up to and including termination of employment.

Because of the significant ethical and legal consequences of noncompliance with the Code of Conduct, disciplinary action may be taken with respect to not only those who violate the Code of Conduct but also those who, through lack of diligence or supervision, fail to prevent or report violations.