Colgate-Palmolive has a long standing policy against making contributions to political parties or candidates, which is set forth in both our Code of Conduct and our internal Business Practices Guidelines. These policies prohibit the use of Company resources for contributions to any political party or candidate, whether Federal, state or local. This prohibition covers not only direct contributions but also indirect assistance or support through buying tickets to political fundraising events or furnishing goods, services or equipment for political fundraising or other campaign purposes. Colgate-Palmolive’s policy also prohibits volunteer work by Colgate-Palmolive people within normal business hours and the use of Colgate-Palmolive facilities for fundraising or political purposes.

Similar to most multinational companies, Colgate-Palmolive belongs to trade and industry associations in the United States to which the Company pays annual dues. To help ensure that the trade associations do not use any portion of the dues or other funds paid by Colgate-Palmolive for political contributions, Colgate-Palmolive’s Chief Ethics and Compliance Officer annually informs the U.S. trade associations of our policy prohibiting such contributions. In addition, the Company’s Chief Ethics & Compliance Officer requests each U.S. trade association to which the Company pays in excess of $10,000 annually to provide: (i) a written confirmation that the Company’s dues or other payments were not used for contributions to political parties or candidates and (ii) a breakdown of any portion of the Company’s dues which are not deductible pursuant to the Internal Revenue Code, to additionally verify that no amounts are being used for political contributions.

For the calendar year 2018, all the U.S. trade associations to which we pay dues or make other payments in excess of $10,000 annually have satisfied the Company’s request for information regarding their non-deductible expenses and confirmed their compliance with our policy.

Colgate-Palmolive thanks Boston Common Management, whose concerns about the potential use of trade association dues for political parties or candidates prompted the Company to adopt this annual procedure.