To the Board of Directors and Stockholders of The Clorox Company

We have reviewed the schedule of selected quantitative performance indicators (the “Subject Matter”) included in Exhibit A and as identified by the “” symbol presented in The Clorox Company’s (“Clorox” or “the Company”) Annual Report (the “Report”) for the year ended December 31, 2019 or June 30, 2020, in accordance with the criteria also set forth in Exhibit A (the “Criteria”). We did not review all information included in the Report. We did not review the narrative sections of the Report, except where they incorporated the Subject Matter. The Clorox Company’s management is responsible for the Subject Matter included in Exhibit A and as also presented in the Report, in accordance with the Criteria. Our responsibility is to express a conclusion on the Subject Matter based on our review.

Our review was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants ((AICPA) AT-C section 105, Concepts Common to All Attestation Engagements, and AT-C section 210, Review Engagements). Those standards require that we plan and perform our review to obtain limited assurance about whether any material modifications should be made to the Subject Matter in order for it to be in accordance with the Criteria. A review consists principally of applying analytical procedures, making inquiries of persons responsible for the subject matter, obtaining an understanding of the data management systems and processes used to generate, aggregate and report the Subject Matter and performing such other procedures as we considered necessary in the circumstances. A review is substantially less in scope than an examination, the objective of which is to obtain reasonable assurance about whether the Subject Matter is in accordance with the Criteria, in all material respects, in order to express an opinion. Accordingly, we do not express such an opinion. A review also does not provide assurance that we became aware of all significant matters that would be disclosed in an examination. We believe that our review provides a reasonable basis for our conclusion.

In performing our review, we have also complied with the independence and other ethical requirements set forth in the Code of Professional Conduct and applied the Statements on Quality Control Standards established by the AICPA.

As described in Exhibit A, the Subject Matter is subject to measurement uncertainties resulting from limitations inherent in the nature and the methods used for determining such data. The selection of different but acceptable measurement techniques can result in materially different measurements. The precision of different measurement techniques may also vary.

Based on our review, we are not aware of any material modifications that should be made to the selected quantitative performance indicators for the year ended December 31, 2019 or June 30, 2020 in order for it to be in accordance with the Criteria.

San Francisco, CA
October 6, 2020

Exhibit A:
The Clorox COMPANY Schedule of Selected Quantitative Performance
Indicators For the Year Ended Dec. 31, 2019, or June 30, 2020
Indicator Name Scope Unit Value1 Criteria
Scope 1 Greenhouse Gas (GHG) Emissions2, 3, 4 Global Absolute metric tonnes carbon dioxide equivalent (tCO2e) 64,484 The World Resources Institute/ World Business Council for Sustainable Development (WRI/WBCSD) Greenhouse Gas (GHG) Protocol Corporate Standard
Scope 2 GHG Emissions, location-based-method2, 4, 5 Global 170,370 WRI/WBCSD GHG Protocol Corporate Standard, GHG Protocol Scope 2 Guidance
Scope 2 GHG Emissions, market-based-method2, 4, 5 Global 170,370
Scope 3 GHG Emissions2, 6 See footnote6 283,651 WRI/WBCSD GHG Protocol Corporate Value Chain (Scope 3) Standard
Energy consumption2, 4 Global Absolute megawatt hours (MWh) 2019 666,112 Refer to criteria for Scope 1 & 2 GHG Emissions above
Water consumption2, 4 Global Absolute megaliters of water consumed 2019 2,904 Global Reporting Initiative (GRI) Standard 303 and Management’s criteria as follows: Water consumption includes water at all global manufacturing sites, offices and research development centers used in 1) products sold to customers, 2) the manufacturing process, 3) irrigation and 4) water consumed by employees during office hours for personal needs (e.g., restrooms, break rooms). Water sources include city/municipal, well, lake, river and stormwater.
Workforce demographics/ diversity metrics7 See right for metric scope Percentage minority non-production employees in U.S.8 34% OSHA Regulation 1920.2(d) and Equal Employment Opportunity Commission (EEOC) — Instruction Booklet EEO-1 and EEO Terminology defines “Employee” as an individual who is employed in a business of his employer which affects commerce. The Equal Employment Opportunity Commission defines “Minority” as any race that is not white (Asian; Black; Latino; Native American; Native Hawaiian; or Two or More).

Management’s criteria as follows: “Manager” is defined as an “employee” at Grade 27 or above for U.S. employees and Grade 26 or above for international employees with regard to Clorox’s Human Resources (HR) compensation structure. “Production Employee” is defined as an employee at Grade 19 or below with regard to Clorox’s HR compensation structure (international and U.S.). “Non-Production Employee” is defined as an employee at Grade 20 or above with regard to Clorox’s HR compensation structure (international and U.S.). In certain circumstances, nonproduction employees may be classified below Grade 20 based on type of work performed.
Percentage minority non-production managers in U.S.8 30%
Percentage female non-production employees globally8 51%
Percentage female non-production managers globally8 44%
Percentage female Board of Directors 33%
Percentage minority Board of Directors 33%
Percentage female Executive Committee members 43%
U.S. product donations7,9 U.S. Only Value of products donated in U.S. dollars $13.4 million GRI 201-1a ii. Economic value distributed (community investments)

Management’s definition as follows: U.S. product donations refer to those donations used to aid in disaster relief or to support schools, food banks and other nonprofit organizations. Value is derived from current-year average truckload price of the product donated. Truckload prices are based on volume ordered and shipped.
Recordable incident rate10 Global Recordable incident rate (RIR) 0.58 Occupational Health and Safety Administration (OSHA) Regulation (Standards – 29 CFR) Part 1904 “Recording and Reporting Occupational Injuries and Illness”

Note 1: Nonfinancial information is subject to measurement uncertainties resulting from limitations inherent in the nature and the methods used for determining such data. The selection of different but acceptable measurement techniques can result in materially different measurements. The precision of different measurement techniques may also vary.

  1. All percentages are rounded to the nearest whole number in the Annual Report.
  2. For all locations where Clorox maintains operational control and for the calendar year ended December 31, 2019.
  3. Scope 1 emissions include direct energy used by Clorox in its operations, categorized by stationary combustion, mobile combustion, refrigerant use, direct VOC loss and direct wood pyrolysis. The last two sources relate mainly to Clorox’s Kingsford business unit, and wood pyrolysis is considered to be a mostly carbon neutral process; therefore, CO2 emissions from wood pyrolysis are not included in total tCO2e, but CO2 equivalent emissions from CH4 and N2O are included. Natural gas emissions, the largest Scope 1 emission source, are calculated using factors from the EPA (Environmental Protection Agency) Mandatory GHG Reporting for Stationary Fuel Sources, Title 40 Part 98 Table C-1 and C-2 (December 2016) and Global Warming Potential (GWP) rates from the Intergovernmental Panel on Climate Change’s (IPCC) Fourth Assessment Report. For Scope 1 emissions related to wood pyrolysis, Clorox is using the Wood & Wood Residuals emission factors under Title 40 Part 98 Table C-2.
  4. Clorox’s natural gas, electricity and municipal water consumption data for U.S. sites are tracked by Clorox’s third-party utility management company. Other sources of energy and water consumption in the U.S. are tracked manually on a site by site basis and reported to Clorox’s corporate team on an annual basis. For international sites, all energy and water consumption data is tracked manually and reported annually to Clorox’s corporate team.
  5. Scope 2 includes indirect emissions resulting from Clorox’s purchased electricity use and is calculated using the EPA’s 2018 eGRID emission factors (published in March 2020) for U.S. locations and the International Energy Agency’s (IEA) 2017 emission factors (published in 2019) for international locations, with the exception of Canada. For Canadian locations, Clorox uses 2017 emission factors from the 2019 Canada National Inventory Report (NIR) part 3. Clorox applies GWPs from the IPCC’s Fourth Assessment Report. For the Scope 2 market-based-method, Clorox contacted its largest utility suppliers, however, was unable to obtain reliable supplier specific emission factors. Clorox’s renewable energy certificates are not retired and other contractual instruments and residual mix factors are not available in the locations in which Clorox operates. Due to the lack of market-based data available, Clorox’s market-based emissions were calculated following the same process as the location-based-method emissions.
  6. Scope 3 includes finished goods transportation in the U.S. only and global employee business travel. Employee business travel includes emissions from commercial air flights and rental car use by Clorox’s employees. Commercial air flights are limited to business travel booked in the United States, United Kingdom, Hong Kong, Argentina, Chile, Mexico, Peru and Canada. Scope 3 emissions for business travel are calculated using ‘per vehicle-mile traveled’ and ‘per passenger-mile traveled’ emissions factors from the EPA’s Center for Corporate Climate Leadership guidance (published in 2020). Emissions from finished goods transportation are calculated using ‘per ton-mile’ emission factors, from the same guidance.
  7. For the fiscal year ended June 30, 2020.
  8. Based on headcount data of employees with reported gender and ethnicities. The total headcount data used for workforce/diversity metrics excludes Nutranext employees as they were acquired in FY18 and are not yet included in Clorox’s headcount system.
  9. U.S. product donations include donations made by U.S. businesses (Brita, Cat Litter, Charcoal, Food Products, Glad, Home Care, Laundry Care, Natural Personal Care and Renew Life).
  10. Recordable incident rate was determined as of July 10, 2020, for the fiscal year ended June 30, 2020. The recordable incident rate includes all reportable incidents that occurred at Clorox facilities globally. It does not include workers at offices with fewer than 30 employees, but it does include remote workers.