Human Rights Policy

I. Our Commitment to Human Rights

McCormick & Company, Incorporated (“McCormick”) is committed to respecting internationally recognized human rights, as set out in the International Bill of Human Rights and the International Labour Organization (ILO) Core Conventions and reaffirmed in the Declaration on Fundamental Principles and Rights at Work. Our human rights due diligence strategy is aligned with the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises. Where applicable, McCormick complies with modern slavery and human rights reporting obligations under relevant national legislation as described in its annual modern slavery statement.

As a member of the UN Global Compact, we commit to implement universal sustainability principles that meet fundamental responsibilities in the areas of human rights, labor, environment, and anti-corruption.

McCormick complies with all applicable laws and regulations wherever we do business and this policy operates in conjunction with applicable local laws, regulations, collective agreements and applicable employee representation or consultation requirements. Where local law and international standards differ, we comply with local law and explore alternative ways to respect international human rights standards to the greatest extent possible.

II. Policy Scope

This Policy applies to McCormick and its majority-owned subsidiaries, business partners, suppliers and all employees worldwide (including part-time workers and directors). Its standards also apply to labor hire arrangements, subcontractors, and other third party workforce arrangements engaged in McCormick’s operations or supply chain.

All McCormick employees, business partners and suppliers are expected to uphold the standards set out in this Policy, to respect human rights across all aspects of our operations and value chain, and to report any suspected human rights violation within McCormick’s operations or supply chain. This Policy is publicly available on McCormick’s website.

McCormick integrates human rights and environmental due diligence into its operations, sourcing, procurement, and wider value chain. This Policy works alongside our Business Ethics Policy, Global Supplier Code of Conduct, Safety and Health Policy, Environmental Policy and Sustainable Agriculture Policy ensuring alignment across the organization.

III. Governance and Accountability

This Policy was approved by McCormick’s Purpose Led Performance (PLP) Council, a cross-functional senior leadership steering committee chaired by the Chief Sustainability Officer.

While the Board has general oversight of environmental, social and governance matters, the Charter of the Nominating and Corporate Governance Committee requires the committee to lead the oversight of our sustainability programs relating to such matters, except to the extent reserved for the full Board or another committee of the Board, as detailed below. As part of this oversight, the Board and its committees regularly review our material initiatives and policies related to such matters and assess progress with respect to our PLP commitments. The PLP Council is a cross-functional senior leadership steering committee with responsibility for establishing and driving a clear roadmap of initiatives to deliver on our commitments as well as integrating our PLP approach into our strategies to strengthen business fundamentals. The PLP Council is chaired by the Chief Sustainability Officer. It includes representatives from Quality & Regulatory, Research & Development, Supply Chain & Procurement, Commercial (Regional & Segment), Global Communications, Packaging, Controllership, Government Affairs and Sustainability. The Chair of the PLP Council reports regularly to the Board and Board Committees on various environmental, social and governance topics covering strategy and risks to major plans of action and key performance indicators. The PLP Council separately reports to McCormick's Management Committee, which is the top-level senior management committee

Core functions, including procurement and human resources, support these responsibilities by implementing our human rights policies within their operational areas.

IV. Human Rights Due Diligence and Prioritization

McCormick undertakes ongoing human rights due diligence to identify, assess, and prioritize risks across its operations and value chain. Our due diligence approach considers whether the company causes, contributes to, or is directly linked to human rights impacts, in line with the UNGPs. We work with external organizations to strengthen our human rights and environmental due diligence strategy and approach and conduct periodic assessments, including double materiality assessments, supply chain risk assessments and human rights impact assessments to update and deepen our understanding of the risks. We partner with key suppliers to identify, prioritize, prevent and mitigate human rights impacts.

Engagement with internal teams, suppliers, rightsholders, and external stakeholders continues to shape our understanding of emerging issues and guides our prioritization decisions. McCormick recognizes that certain individuals and groups may be at heightened risk of human rights impacts due to factors such as gender, age, race, ethnicity, disability, migration status, or Indigenous identity, and commits to giving due consideration to these groups across its activities and decision-making.

We support implementation of this Policy by providing targeted training and guidance to employees in relevant functions. We also engage business partners and suppliers through capacity building activities, training, and guidance on human rights expectations.

McCormick will review and refine its priority human rights issues periodically and when significant changes arise, to ensure continued alignment with global standards, evolving regulations, and stakeholder expectations. The following standards address McCormick’s current priority human rights issues.

A. Child Labor

McCormick adheres to minimum age requirements for employment under applicable law and under no circumstances will employ anyone under 15 years of age or under the age of completion of compulsory schooling or a mandatory age specified by the local law, whichever is higher under applicable law in the country of operation.

Workers aged 15–17 may only perform age appropriate, non-hazardous work. No person under 18 years of age will be permitted to perform work prohibited by applicable law or hazardous work that exposes them to undue health and safety risks that could cause physical, mental, or emotional harm or improperly interfere with their schooling. Prohibitions against night work, overtime, and requirements for mandatory rest periods will be observed in accordance with applicable law in the country of operation.

B. Forced Labor

We maintain a zero-tolerance policy and will not employ, use, or otherwise benefit from a situation of vulnerability, a state of dependency or involuntary or forced labor, whether indentured, bonded, enslaved, trafficked, imprisoned or otherwise in our operations or supply chain.

We prohibit the confiscation or withholding of workers’ identity documents (except where temporarily required by lawful government or immigration procedures) or any other personal valuables. We do not allow any practice that undermines human dignity or restricts a worker’s lawful freedom of movement.

We also prohibit the unreasonable withholding or diversion of workers’ wages. Under no circumstances may personal documents or wage practices be used to bind individuals to employment, coerce them into continued work, or otherwise limit their freedom.

C. Working Hours

McCormick ensures that all workers in our operations and supply chain work in compliance with all applicable laws and legally binding collective agreements (where applicable) pertaining to the number of hours and days worked and any record-keeping requirements in respect of the same. All workers will be provided with reasonable daily and weekly work schedules, and adequate allowance will be made for time off and rest periods in accordance with legal requirements. Overtime should be conducted and compensated in accordance with applicable law and legally binding collective agreements where applicable.

D. Compensation

Workers will be fairly compensated and provided with wages and benefits that comply with applicable laws and legally binding collective agreements, including appropriate compensation for overtime work and other premium pay situations required by applicable law. We will also ensure equal remuneration for work of equal value.

This means that all workers, whether full-time, part-time, contract, migrant, seasonal workers or otherwise, are paid in full and in a timely manner. Details of wages and benefits are clearly outlined in the terms of employment in an understandable and accessible format. Any deductions from wages must comply with applicable laws or regulations.

E. Discrimination and Harassment

We prohibit discrimination and harassment in all hiring and employment practices based on gender, sexual orientation/gender identity, race, color, religion, ethnic or national origin, disability, protected veteran status, age or any other status or characteristic protected by law.

We do not tolerate any harassment or discrimination, whether it is sexual or non-sexual in nature, of any of our employees, including by any supervisor, co-worker, employee or non-employee, vendor, client or customer of McCormick.

F. Workplace Safety and Health

McCormick recognizes that a safe, healthy, and sustainable work environment is fundamental to dignity, well-being, and human rights of workers and communities affected by our operations. We are committed to providing and maintaining safe and healthy working conditions for all personnel impacted directly by our operations.

McCormick drives a robust occupational safety and health performance through our Global Safety, Health and Environmental Management System (SHEMS), which establishes clear standards and accountability to identify, prevent, and mitigate risks across our direct operations and supply chain. Through this framework, we strive to prevent work-related injuries and illnesses, avoid adverse environmental impacts, and advance our overall goal of zero harm.

G. Freedom of Association

McCormick respects the right of all employees to freedom of association and is committed to complying with laws pertaining to freedom of association, consultation, and collective bargaining, and to promoting a work environment that fosters communication, productivity, and employee engagement.

H. Respect for the Environment

McCormick will conduct its business in a manner compatible with the environment and in accordance with applicable law. Reasonable standards of care shall be taken to protect the environment and to provide for the health and safety of employees and the communities in which its facilities operate. McCormick will take prudent steps to minimize solid waste by reducing, reusing, and recycling materials; encourage conservation of resources and energy; manage water depletion, intensity and quality; provide training and education for its employees, as appropriate; identify, set targets and implement action plans to establish policies intended to protect the environment within its operations. All employees must contribute to McCormick’s environmental stewardship initiatives by complying with all environmental laws and McCormick policies.

I. Climate Change

McCormick recognizes that climate change and human rights are closely connected, and that its impacts, both direct and indirect, are often felt most acutely by marginalized people and communities. As part of our commitment to responsible and sustainable business practices, McCormick aims to integrate a human rights perspective into our climate mitigation and resilience efforts, ensuring we proactively identify and address potential human rights impacts associated with a changing climate.

V. Supplier and Business Partner Expectations

The Supplier Code of Conduct sets out clear requirements relating to compliance with applicable laws and international human rights standards, such as prohibitions on forced labor, child labor and discrimination, as well as standards related to safe working conditions, compensation, working hours and freedom of association and collective bargaining. It also requires suppliers to identify, prioritize, and manage human rights risks within their operations and value chains and to ensure that their own suppliers uphold the same standards. McCormick provides training on the Supplier Code of Conduct when deemed appropriate.

McCormick verifies compliance with the Supplier Code of Conduct through a combination of internal and third-party due diligence mechanisms, such as audits, certifications and impact assessments. Where nonconformance is identified, we seek alignment on a time-bound corrective action plan with the supplier, support capacity building where needed, and monitor closure. Corrective action processes will be implemented in a manner consistent with local law including any applicable legally binding collective agreements. Where issues persist or are severe, McCormick reserves the right to terminate the relationship in accordance with applicable law as a last resort and only do so responsibly.

VI. Monitoring and Effectiveness

McCormick reviews and updates, as appropriate, this human rights policy at least every two years based on evolving risks and stakeholder feedback. We regularly assess and track the effectiveness of our due diligence processes to ensure they remain adequate and effective.

VII. Reporting and Stakeholder Engagement

McCormick reports on human rights risks and actions and engages stakeholders meaningfully to understand impacts and inform our decision-making and due diligence. McCormick has applied the following reporting frameworks: Task Force on Climate-related Financial Disclosures (TCFD), Sustainability Accounting Standards Board (SASB), Global Reporting Initiative (GRI) and CDP, as reported through our Annual Disclosures, and publishes an annual modern slavery statement where required by law, describing identified risks, actions taken, and how effectiveness is assessed.

As part of our stakeholder engagement approach, McCormick participates in industrywide initiatives to promote respect for human rights and support collective action, including the Consumer Goods Forum, the Sustainable Spices Initiative, and the Sustainable Vanilla Initiative.

VIII. Grievance Mechanism and Remedy

McCormick is committed to providing for, or cooperating in, the remediation of adverse human rights impacts where we cause or contribute to those impacts, consistent with all applicable laws, rules and regulations.

McCormick promotes an open-door policy where our supervisory and management employees, including all officers and directors of the Company, are available to anyone wanting to raise ethical or other concerns, questions or complaints without fear of retaliation.

We also maintain an accessible and confidential third-party administered business ethics hotline, EthicsPoint, which allows employees, business partners, and external stakeholders to raise concerns anonymously, where permitted by local law, and without fear of retaliation. All concerns, questions and complaints are taken seriously and handled promptly, confidentially and professionally.

We regularly review and evaluate the effectiveness of our grievance mechanisms to ensure they are transparent, predictable, equitable, rights-compatible, legitimate, a source of continuous learning, and accessible to all stakeholder groups including at risk or marginalized groups.

Nothing in this Policy limits statutory whistleblowing protections or rights to raise concerns through legally mandated employee representative or regulatory channels.