Boulder Brands Responsible Palm Oil Commitment At Boulder Brands, we believe that palm oil can and should be responsibly sourced and sustainably produced. Since 2010, we have been increasing the amount of responsible palm oil we source every year, while also actively working to drive change and innovation in responsible palm oil production. As such, by the end of 2015 we plan to source 100% of our palm oil products from companies whose entire palm oil operations are independently verified as meeting responsible palm oil requirements set forth by the Palm Oil Innovation Group (POIG) in support of the Roundtable on Sustainable Palm Oil (RSPO) – the leading organizations dedicated to solving the palm oil issue. Boulder Brands will also be working closely with respected international agencies like Greenpeace, Rainforest Action Network, the World Wildlife Fund and the Orangutan Land Trust, among others, to develop standards and innovations that will change the face of the palm oil industry. As an edible plant-based oil, palm oil provides unique functional health and performance benefits, and is an essential ingredient in many of our foods, including but not limited to buttery spreads and sticks, gluten-free goods, pure and simple frozen entrees and convenient snack foods. The Boulder Brands family of brands is dedicated to leading change and improving lives. One way we endeavor to uphold this mission is to focus on the quality of our ingredients to help change “the way America eats” for the better. While there are options for replacing palm oil, such as hydrogenated and interesterified oils, those alternatives would compromise the health and product quality of our products, which is a compromise we’re unwilling to make. In total, Boulder Brands is a very small player in the global vegetable oil commodity business, purchasing a tiny amount of the palm oil that is imported in the US (less than one percent in 2014). The announcement of our responsible palm oil commitment is another exciting step in this journey. Our Commitments Boulder Brands’ palm oil sourcing commitment requires its suppliers to comply with these underlying parameters: 1. Environmental responsibility and conservation 2. Community partnerships and the respect for human rights 3. Traceable and accountable supply chains and transparent reporting and improvement metrics We commit to only purchasing palm oil from suppliers who operate in accordance with the following responsible palm oil requirements: 1. Environmental responsibility and conservation - No Deforestation: Suppliers must not contribute to deforestation of high conservation value (HCV) areas or high carbon stock (HCS) forests. - No Development on Peat Lands: Suppliers must protect peat lands of any depth from development, fires and drainage, and support strategies to restore peat land ecosystems. - Greenhouse Gas (GHG) Accountability: Suppliers must publicly report on all GHG emissions in conjunction with the parameters set forth in the POIG charter. - Pesticide Use Minimization: Suppliers must avoid the use of highly toxic, bioaccumulative and persistent pesticides. Suppliers must be accountable and fully transparent about the use of any pesticide or chemical fertilizers. - No GMOs: Suppliers must prevent the cultivation of GMOs. - Water Accountability: Suppliers must have in place a responsible water management system that minimizes and discloses water use, eliminates pollution, considers catchment level impacts of irrigation and ensures equity with other users. - Wildlife Protection and Conservation: Suppliers must conduct biodiversity surveys and ensure the protection and survival of all rare, threatened or endangered species within their concession land. 2. Community partnerships and the respect for human rights - Respect Human Rights: Suppliers must fully respect the right of Indigenous Peoples and local communities to give or withhold their Free, Prior and Informed Consent (FPIC) to any palm oil development on their land via their own freely chosen representatives. - Food Security: Suppliers must support land use choices that assures food security for indigenous and local communities. - Conflict Resolution: Suppliers must respect the right of indigenous peoples and rural communities to have access to a balanced, accountable, mutually agreed upon and documented conflict resolution system to deal with complaints or grievances. - Social Conditions: Suppliers must support social programs to prevent human rights violations, social conflicts or land grabbing, and address key social equity issues including housing, health care, education and empowerment of women. - Worker Rights: Suppliers must respect the rights of all workers, including contract, temporary and migrant workers, and workers of all genders, in accordance with the International Labor Organization (ILO) requirements for “decent work” and core conventions on child labor, forced or compulsory labor, freedom of association, and elimination of discrimination. - Support Palm Oil Smallholders: Suppliers must support the inclusion of smallholders and ensure all contracts with smallholders are based on a fair, transparent and accountable partnership. 3. Traceable and accountable supply chains and transparent reporting and improvement metrics - Transparency and Corruption: Suppliers must publicly commit to prohibit any form of corruption, including during the concession acquisition process and within their operations, and support efforts to establish and comply with anti-corruption legislation where this exists. - Traceability: Suppliers must build fully traceable supply chains to ensure that all sources of palm oil are traceable to the plantation of origin and to their mills. - Report on Social, Labor and Environmental Performance: Suppliers must disclose social, labor and environmental performance using the guidance of the Global Reporting Initiative or equivalent approach. - RSPO Certification and Company Operations: Suppliers must commit to achieving 100% RSPO certification within two years. This shall cover all palm oil operations, subsidiaries, acquisitions of existing plantation and fresh fruit bunch purchases from third parties, with possible alternatives to full RSPO certification for small independent producers. - Responsible Supply Chains: Suppliers must independently verify and report on compliance with these requirements and measures set forth by the POIG charter and RSPO standard. Boulder Brands will cease to do business with any suppliers in serious violation of its policy, and with suppliers that do not take immediate remedial action to correct those violations. Our implementation target: We plan to be 100% compliant with our responsible palm oil commitment by the end of 2015. Resources: Palm Oil Innovation Group (POIG): www.poig.org - POIG statement on Boulder Brands support Roundtable on Sustainable Palm Oil: www.rspo.org Rainforest Action Network: www.ran.org Greenpeace: www.greenpeace.org World Wildlife Fund: www.worldwildlife.org Orangutan Foundation International: www.orangutan.org