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Hershey Responsible Sourcing Program and Supplier Code of Conduct

Hershey Responsible Sourcing Program and Supplier Code of Conduct: Establish cocoa traceability, emissions disclosure and procurement-driven Scope 3 governance

Maílis Carrilho
Written by Maílis Carrilho
Published Apr 21, 2026

Summary

Hershey’s supplier framework operates as a procurement-driven climate governance system combining traceability, emissions disclosure, and audit enforcement. Suppliers must manage environmental performance, provide data, and ensure upstream compliance. High-impact agricultural suppliers face stronger expectations due to their contribution to Scope 3 emissions and deforestation risk. Procurement integration ensures that environmental performance directly affects supplier qualification and long-term sourcing relationships.

Details

Jurisdictions
  • Global
Mandatory for

Mandatory: Supplier Code of Conduct compliance.

Functionally mandatory: traceability, environmental monitoring, data reporting.

Enhanced requirements: cocoa and high-impact suppliers.

Implementation varies by supplier category, but baseline compliance is required.

Deep dive

4 min read
Updated Apr 22, 2026

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What’s Required

Hershey’s framework functions as a procurement-driven private regulatory system, embedding environmental, climate and agricultural governance into supplier contracts, sourcing standards, and long-term supplier relationships.

The architecture integrates:

  • Supplier Code of Conduct (contractual compliance baseline).

  • Responsible Sourcing Program (commodity-specific governance, especially cocoa).

  • Supplier engagement and monitoring systems.

This creates a multi-tier governance structure spanning farm-level production, processing and product manufacturing.

1. Emissions Disclosure, Measurement, and Reduction

Suppliers are required or expected to:

  • Measure and report greenhouse gas emissions (Scope 1 and Scope 2).

  • Track energy consumption and environmental performance.

  • Implement measures to reduce emissions and improve efficiency.

For strategic suppliers, expectations extend to:

  • Participation in disclosure platforms such as CDP.

  • Alignment with science-based targets via the Science-Based Targets initiative.

  • Provision of emissions data supporting Scope 3 accounting.

This creates a functional requirement for carbon accounting systems.

2. Scope 3 Governance and Value Chain Integration

Hershey explicitly links supplier performance to its Scope 3 emissions profile.

Suppliers must:

  • Provide emissions data linked to cocoa, ingredients, packaging, and manufacturing.

  • Reduce emissions intensity across production and processing.

  • Align operations with Hershey’s climate commitments.

This creates a structural dependency:

  • Agricultural emissions dominate Scope 3.

  • Supplier performance directly affects corporate reporting.

This represents a commodity-driven Scope 3 governance model, particularly focused on cocoa.

3. Cocoa Traceability and Deforestation Risk Management

A defining feature of Hershey’s framework is cocoa traceability and sourcing governance.

Suppliers must:

  • Ensure traceability of cocoa to the farm or cooperative level.

  • Avoid sourcing from areas linked to deforestation.

  • Implement sustainable farming practices.

  • Participate in monitoring systems for land use and sourcing.

This creates a land-use governance system, where supplier compliance affects:

  • Deforestation risk.

  • Agricultural emissions.

  • Corporate sustainability commitments.

Suppliers must maintain visibility across:

  • Farmers and cooperatives.

  • Processing facilities.

  • Supply chain intermediaries.

4. Environmental Data Systems and Reporting Infrastructure

Suppliers must:

  • Provide environmental data through structured reporting systems.

  • Maintain documentation on emissions, sourcing, and resource use.

  • Support Hershey’s ESG and sustainability disclosures.

This requires:

  • Standardized data collection methodologies.

  • Centralized environmental data management.

  • Ability to provide auditable, verifiable information.

Traceability systems are closely integrated with environmental reporting.

5. Audit, Verification, and Compliance Enforcement

Hershey enforces compliance through:

  • Supplier self-assessments.

  • Third-party audits and verification.

  • Field monitoring (especially in cocoa supply chains).

  • Corrective action plans.

Suppliers must:

  • Provide access to facilities and sourcing data.

  • Demonstrate compliance with environmental and sourcing standards.

  • Address non-conformances within defined timelines.

This creates a verification-based compliance regime, combining audits and field-level monitoring.

6. Procurement Integration and Supplier Segmentation

Environmental performance is embedded into procurement through:

  • Supplier onboarding and qualification.

  • Ongoing performance evaluation.

  • Sourcing and contract decisions.

Suppliers are segmented based on:

  • Commodity type (especially cocoa).

  • Environmental and deforestation risk.

  • Contribution to Scope 3 emissions.

High-impact suppliers face:

  • Mandatory traceability requirements.

  • Increased disclosure and reporting obligations.

  • Greater audit scrutiny.

This creates a tiered governance system.

7. Upstream Cascade Requirements

Suppliers are required to:

  • Extend Hershey standards to farmers and upstream producers.

  • Ensure compliance across agricultural supply chains.

  • Maintain traceability and transparency.

This extends governance into multi-tier agricultural networks, particularly in cocoa sourcing regions.

8. Lifecycle and Product-Level Implications

The framework directly influences:

  • Raw material sourcing (cocoa, sugar, ingredients).

  • Processing emissions.

  • Product environmental footprint.

Supplier performance affects:

  • Product carbon intensity.

  • Land-use and deforestation impacts.

  • Corporate ESG disclosures.

This aligns supplier operations with product-level and corporate climate strategies.

Important Deadlines

Key timelines include:

  • 2030 emissions reduction targets aligned with Hershey’s climate commitments.

  • Deforestation-free sourcing targets (aligned with industry timelines).

  • Annual supplier reporting cycles.

  • Continuous improvement milestones.

Suppliers are expected to demonstrate progressive alignment.

Current Status

The framework is active and highly focused on agricultural governance, with increasing emphasis on:

  • Cocoa traceability.

  • Supply chain emissions transparency.

  • Integration with climate and biodiversity commitments.

Hershey continues to strengthen supplier climate governance.

Penalties for Non-Compliance

Enforcement is procurement-driven and includes:

  • Corrective action requirements.

  • Reduced sourcing volumes.

  • Loss of preferred supplier status.

  • Contract termination.

This creates a direct link between environmental performance and commercial viability.

Examples of Known Violations

Typical failure modes include:

  • Lack of cocoa traceability.

  • Non-compliance with deforestation-free sourcing requirements.

  • Failure to disclose emissions data.

  • Inconsistent environmental reporting.

  • Failure to address audit findings.

These failures directly impact supplier eligibility.

Resources


Maílis Carrilho
Added by:
Maílis Carrilho
Sustainability Research Analyst
Maílis Carrilho is a Sustainability Research Analyst (Intern) at Net Zero Compare, contributing research and analysis on climate tech, carbon policies, and sustainable solutions. She supports the team in developing fact-based content and insights to help companies and readers navigate the evolving sustainability landscape.
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Added on Apr 21, 2026 by Maílis Carrilho · Updated on Apr 22, 2026