2019 Integrated Annual Report
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GRI CONTENT INDEX

General Disclosures

ORGANIZATIONAL PROFILE
DISCLOSURE Number Description Response UNGC PRINCIPLEs
102-1 Name of the organization The Clorox Company CEO Letter reinforces Clorox’s commitment to the UN Global Compact Ten Principles.
102-2 Activities, brands, products and services 2019 Scorecard
2020 Strategy Overview and Progress
IGNITE Strategy Overview
FY 2019 Form 10-K: Item 1: Overview of Business, pages 1-4
 
102-3 Location of headquarters 2019 Scorecard  
102-4 Location of operations 2019 Scorecard  
102-5 Ownership and legal form FY 2019 Form 10-K cover page (The Clorox Company; State or other jurisdiction of incorporation of organization: Delaware)  
102-6 Markets served 2019 Scorecard
FY 2019 Form 10-K, page 3
 
102-7 Scale of the organization 2019 Scorecard  
102-8 Information on employees and other workers Strategy 1
2019 Scorecard
Clorox Website: Our People
 
102-9 Supply chain Clorox’s supply chain reflects the company as a formulator (not a chemical company) with a broad portfolio of products for consumers and professionals. Raw material inputs are varied.
Clorox Website: Corporate Responsibility: Supply Chain
UNGC Ten Principles — The Clorox Company Business Partner Code of Conduct includes our expectations of suppliers on business ethics, human rights, labor, and environmental compliance and sustainability.
102-10 Significant changes to the organization and its supply chain Clorox made the the following changes to its organization, which also impacted its supply chain: Aug. 2017 divestiture of the Aplicare business, including manufacturing; April 2018 acquisition of the Nutranext business, which added a manufacturing facility in Sunrise, FL.  
102-11 Precautionary Principle or approach Clorox Website: Brands: What We’re Made Of Principle 7
102-12 External initiatives CDP, GRI, SASB, UNGC — See CEO Letter
About This Report
Third Party ESG Frameworks
Clorox Website: AIM Progress Industry Collaboration
UNGC Ten Principles
102-13 Membership of associations Clorox Website: Stakeholder Engagement UNGC Principles 7-9 (See Responsible Sourcing Information)
Strategy
DISCLOSURE Number Description Response UNGC PRINCIPLEs
102-14 Statement from senior decision-maker CEO Letter  
102-15 Key impacts, risks and opportunities 2020 Strategy Overview and Progress
IGNITE Strategy Overview
10-K: Item 1.A. Risk Factors, pages 5-19
 
Ethics and Integrity
DISCLOSURE Number Description Response UNGC PRINCIPLEs
102-16 Values, principles, standards and norms of behavior Clorox Website: Mission and Values Principle 10
102-17 Mechanisms for advice and concerns about ethics Clorox Website: Clorox Code of Conduct and Clorox Business Partner Code of Conduct Principle 10
Governance
DISCLOSURE Number Description Response UNGC PRINCIPLEs
102-18 Governance structure Corporate Governance
Clorox Website: Corporate Governance
Clorox Website: Governance Guidelines
UNGC Ten Principles
102-19 Delegating authority Corporate Governance
Clorox Website: Corporate Governance
Clorox Website: Eco Governance Guidelines
Principles 7-9
102-20 Executive-level responsibility for economic, environmental and social topics Corporate Governance  
102-21 Consulting stakeholders on economic, environmental and social topics Corporate Governance
Clorox Website: Board of Directors
 
102-22 Composition of the highest governance body and its committees Corporate Governance
Clorox Website: Corporate Governance
 
102-23 Chair of the highest governance body Corporate Governance
Clorox Website: Corporate Governance
 
102-24 Nominating and selecting the highest governance body Clorox Website: Corporate Governance Committee Charters  
102-25 Conflicts of interest Clorox Website: Corporate Governance Committee Charters Principle 10
102-26 Role of highest governance body in setting purpose, values and strategy Clorox Website: Governance Guidelines UNGC Ten Principles
102-27 Collective knowledge of highest governance body Clorox Website: Clorox Board of Directors UNGC Ten Principles
102-28 Evaluating the highest governance body’s performance Clorox Website: Corporate Governance Committee Charters UNGC Ten Principles
102-29 Identifying and managing economic, environmental and social impacts Clorox Website: Governance Guidelines UNGC Ten Principles
102-30 Effectiveness of risk management processes Clorox Website: Governance Guidelines UNGC Ten Principles
102-31 Review of economic, environmental and social topics The Clorox board of directors meets at least quarterly to review key issues/opportunities impacting the company. UNGC Ten Principles
102-32 Highest governance body’s role in sustainability reporting Clorox’s CEO, CFO and General Counsel approve our integrated report.  
102-33 Communicating critical concerns Clorox Website: Communicating with Clorox Board of Directors  
102-34 Nature and total number of critical concerns Clorox Board of Directors regularly review and address a variety of key issues/opportunities through quarterly updates, strategy meetings and separate committee meetings. The company does not disclose the total number of concerns.   
102-35 Remuneration policies Clorox Website: SEC Filings 2018 Clorox Proxy — See Compensation Discussion and Analysis, pages 30-57  
102-36 Process for determining remuneration Clorox Website: SEC Filings 2018 Clorox Proxy — See Compensation Discussion and Analysis, pages 30-57  
102-37 Stakeholders’ involvement in remuneration Clorox Website: SEC Filings 2018 Clorox Proxy — See Compensation Discussion and Analysis, pages 30-57  
102-38 Annual total compensation ratio Clorox does not disclose, although the company does point to CEO median pay ratio.  
102-39 Percentage increase in annual total compensation ratio Clorox does not disclose.  
Stakeholder Engagement
DISCLOSURE Number Description Response UNGC PRINCIPLEs
102-40 List of stakeholder groups Corporate Governance
2020 Strategy, Our Relationships
Clorox Website: Stakeholder Engagement
 
102-41 Collective bargaining agreements U.S. 1.32%, International: 8.22%, Total Company: 9.55% Principle 3
102-42 Identifying and selecting stakeholders Clorox Website: Stakeholder Engagement  
102-43 Approach to stakeholder engagement Clorox Website: Stakeholder Engagement  
102-44 Key topics and concerns raised About This Report — Corporate Responsibility Priorities
Clorox Website: Stakeholder Engagement
 
Reporting Practice
DISCLOSURE Number Description Response UNGC PRINCIPLEs
102-46 Defining report content and topic Boundaries About This Report  
102-47 List of material topics About This Report — Corporate Responsibility Priorities
Clorox Website: Stakeholder Engagement
UNGC Principles 1-10
102-48 Restatements of information FY 2019 Form 10-K: Five-Year Financial Summary, page 66  
102-49 Changes in reporting About This Report  
102-50 Reporting period About This Report  
102-51 Date of most recent report About This Report  
102-52 Reporting cycle About This Report  
102-53 Contact point for questions regarding the report corporate.communications@clorox.com  
102-54 Claims of reporting in accordance with the GRI Standards About This Report  
102-55 GRI content index About This Report  
102-56 External assurance About This Report
Report of Independent Registered Accounting Firm
 
GRI 200: Economic
GRI 201: Economic Performance
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary CEO Letter
2020 Strategy
2019 Scorecard
About This Report — Corporate Responsibility Priorities
 
103-2 The management approach and its components CEO Letter
2020 Strategy
2019 Scorecard
FY 2019 Form 10-K, Part I, Item 1 — Overview of Business, Pages 1-4; Part II, Item 7 — Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 23
 
103-3 Evaluation of the management approach CEO Letter
2020 Strategy
2019 Scorecard
FY 2019 Form 10-K, Part II, Item 7 — Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 23
 
201-1 Direct economic value generated and distributed 2019 Scorecard Principles 7-9
201-2 Financial implications and other risks and opportunities due to climate change Clorox Website: Commitments and Progress — Message From the CEO
FY 2019 Form 10-K, Risk Factors, pages 5-19
 
201-3 Defined benefit plan obligations and other retirement plans Clorox Website: Working at Clorox — Benefits & Perks  
GRI 205: Anti-corruption
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Clorox and Business Partner Codes of Conduct Principle 10
103-2 The management approach and its components Clorox Website: Clorox and Business Partner Codes of Conduct Principle 10
103-3 Evaluation of the management approach Clorox Website: Clorox and Business Partner Codes of Conduct Principle 10
205-2 Communication and training about anti-corruption policies and procedures 100% of the company’s leaders and employees must go through anti-corruption training. 100% of the company’s suppliers must adhere to the Business Partner Code of Conduct, which addresses ethical business practices.
Clorox Website: Clorox and Business Partner Codes of Conduct
Principle 10
GRI 300: Environmental
GRI 303: Water
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Water
Clorox Website: Sustainability in Our Facilities — Water
Principles 7-9
103-2 The management approach and its components Water
Clorox Website: Sustainability in Our Facilities — Water
Principles 7-9
103-3 Evaluation of the management approach Water
Clorox Website: Sustainability in Our Facilities — Water
Principles 7-9
303-1 Water withdrawal by source Clorox Website: Sustainability in Our Facilities — Water  
GRI 306: Effluents and Waste
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Waste
Clorox Website: Footprint Reduction Summary — Waste
IGNITE Strategy Overview
 
103-2 The management approach and its components Waste
Clorox Website: Footprint Reduction Summary — Waste
Clorox Website: Commitments and Progress — Message From the CEO
IGNITE Strategy Overview
 
103-3 Evaluation of the management approach Waste
Clorox Website: Footprint Reduction Summary — Waste
Clorox Website: Commitments and Progress — Message From the CEO
 
306-2 Waste by type and disposal method Waste
2019 Scorecard
Clorox Website: Footprint Reduction Summary — Waste
We report solid waste disposal, not hazardous waste disposal. The waste disposal method has been determined based on information provided by the waste disposal contractor. Each site reports its annual reuse, recycling and disposal tonnages using information obtained from its recycling or waste disposal contractor to our corporate office where it is reviewed and compiled.
Materials (tons)
Reuse 35,952
Recycle 23,679
Compost 2,056
Energy Recovery 690
Incineration
Deep Well
Landfill 9,859
On-Site Storage
Other
 
GRI 307: Environmental Compliance
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary FY 2019 Form 10-K, Risk Factors, pages 5-19  
103-2 The management approach and its components Clorox Website: Environmental Sustainability  
103-3 Evaluation of the management approach Clorox Website: Environmental Sustainability  
307-1 Non-compliance with environmental laws and regulations Clorox Website: Clorox and Business Partner Codes of Conduct  
GRI 308: Supplier Environmental Assessment
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Supply Chain — Responsible Sourcing Principles 7-9
103-2 The management approach and its components Clorox Website: Supply Chain — Responsible Sourcing
Clorox Website: Clorox Business Partner Codes of Conduct
Principles 7-9
103-3 Evaluation of the management approach Clorox Website: Supply Chain — Responsible Sourcing
Clorox Website: Clorox Business Partner Codes of Conduct
Principles 7-9
308-1 New suppliers that were screened using environmental criteria Clorox does not track percentage of new suppliers screened using environmental data. The vast majority of new suppliers are informed/expected to adhere to our environmental commitments/practices in our business partner code of conduct. Clorox has a scorecard tracking the environmental practices of our top 100 suppliers (by spend).  
308-2 Negative environmental impacts in the supply chain and actions taken The company assesses the sustainability performance of its top 100 suppliers, which represents the majority of our supplier spend. 100% of suppliers, including new suppliers, must adhere to the company’s business partner code of conduct, which addresses sustainability expectations.
Clorox Website: Supply Chain — Supplier
Environmental Footprint Score Card
 
GRI 400: Social
GRI 401: Employment
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Engage Our People
Clorox Website: Our People
Clorox Website: Careers
 
103-2 The management approach and its components Engage Our People
Clorox Website: Our People
Clorox Website: Clorox Code of Conduct
 
103-3 Evaluation of the management approach Engage Our People
Clorox Website: Our People
 
401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees Clorox Website: Working at Clorox — Benefits & Perks  
GRI 403: Occupational Health and Safety
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Engage Our People — Workplace Safety
2019 Scorecard
Clorox Website: Workplace Safety
 
103-2 The management approach and its components Engage Our People — Workplace Safety
2019 Scorecard
Clorox Website: Workplace Safety
 
103-3 Evaluation of the management approach Engage Our People — Workplace Safety
2019 Scorecard
Clorox Website: Workplace Safety
 
403-2 Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities 2019 Scorecard
Clorox Website: Workplace Safety
We track the RIR & LTIR (lost time incident rate) for Clorox employees plus supervised workers. LTIR is reported internally on a monthly basis. We follow OSHA 1904 Rules for defining injuries as reportable and labor hours to track. The rate calculation is that used by the Bureau of Labor Statistics (BLS) and OSHA for comparison across industries.
 
GRI 404: Training and Education
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Our People
Clorox Website: Clorox Code of Conduct
 
103-2 The management approach and its components Clorox Website: Our People
Clorox Website: Clorox Code of Conduct
 
103-3 Evaluation of the management approach Clorox Website: Our People
Clorox Website: Clorox Code of Conduct
 
404-2 Programs for upgrading employee skills and transition assistance programs CEO Letter
Engage Our People
The company’s MyLearning program offers extensive internal and external courses to support professional development and capability- and leadership-building needs.
 
GRI 405: Diversity and Equal Opportunity
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Engage Our People — Diversity
2019 Scorecard
Clorox Website: Inclusion & Diversity
Principle 6
103-2 The management approach and its components Engage Our People — Diversity
2019 Scorecard
Clorox Website: Inclusion & Diversity
 
103-3 Evaluation of the management approach Engage Our People — Diversity
2019 Scorecard
Clorox Website: Inclusion & Diversity
 
405-1 Diversity of governance bodies and employees 2019 Scorecard
Clorox Website: Inclusion & Diversity
 
GRI 406: Non-discrimination
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Inclusion & Diversity
Clorox Website: Codes of Conduct
 
103-2 The management approach and its components Clorox Website: Inclusion & Diversity
Clorox Website: Codes of Conduct
 
103-3 Evaluation of the management approach Clorox Website: Inclusion & Diversity
Clorox Website: Codes of Conduct
 
406-1 Incidents of discrimination and corrective actions taken Clorox Website: Codes of Conduct  
GRI 408: Child Labor
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Codes of Conduct Principles 1-5
103-2 The management approach and its components Clorox Website: Codes of Conduct Principles 1-6
103-3 Evaluation of the management approach Clorox Website: Codes of Conduct Principles 1-7
408-1 Operations and suppliers at significant risk for incidents of child labor Suppliers must comply with Clorox’s policy on employment of young people where the minimum age of employment shall not be less than the greater of (a) the age of completion of compulsory schooling or (b) 15 years of age (or 14, where the local law of the country permits). Additionally, workers under age 18 should not perform any hazardous work. Principles 1-8
GRI 409: Forced or Compulsory Labor
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Codes of Conduct  
103-2 The management approach and its components Clorox Website: Codes of Conduct  
103-3 Evaluation of the management approach Clorox Website: Codes of Conduct  
409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labor Clorox Website: Codes of Conduct
Adherence to our Business Partner Code of Conduct — which articulates our expectations regarding human rights and labor, health and safety, the environment, and business conduct and ethics — is required of our suppliers, with certification taking place on a regular basis. This code precludes the use of forced, bonded, or indentured labor or prison labor. As an additional safeguard, the company’s Global Strategic Sourcing organization implemented a monitoring program in FY 2017 using web-crawl technology to monitor all global direct material suppliers for any activities or incidents that would pose risk to the Clorox supply chain. Through an alert system, buyers are notified of any significant findings for appropriate action and/or follow-up. GSS also began annual risk assessments of global suppliers in FY 2018 based on location, scale, industry and audit history to determine those suppliers at highest risk for social compliance issues, including forced labor and human trafficking. The risk assessment allows us to determine which suppliers should be selected for third-party audits to verify compliance with all principles and standards of the Clorox Business Partner Code of Conduct.
 
GRI 412: Human Rights Assessment
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Codes of Conduct  
103-2 The management approach and its components Clorox Website: Codes of Conduct  
103-3 Evaluation of the management approach Clorox Website: Codes of Conduct  
412-1 Operations that have been subject to human rights reviews or impact assessments None of our operations have been subject to human rights reviews/assessments.  
GRI 413: Local Communities
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Strategy 3
2019 Scorecard
Clorox Website: Social Impact
 
103-2 The management approach and its components Strategy 3
2019 Scorecard
About This Report — Corporate Responsibility Priorities
Clorox Website: Social Impact
 
103-3 Evaluation of the management approach Strategy 3: Safeguard Families Through Initiatives That Promote Health, Education and Safety-Community Support
2019 Scorecard
About This Report — Corporate Responsibility Priorities
Clorox Website: Social Impact
 
413-1 Operations with local community engagement, impact assessments and development programs Strategy 3: Safeguard Families Through Initiatives That Promote Health, Education and Safety-Community Support
Clorox Website: Social Impact
 
GRI 414: Supplier Social Assessment
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Sustainability in Our Supply Chain Clorox Website: Business Partner Code of Conduct Principles 1-6
103-2 The management approach and its components Clorox Website: Sustainability in Our Supply Chain Clorox Website: Business Partner Code of Conduct Principles 1-6
103-3 Evaluation of the management approach Clorox Website: Sustainability in Our Supply Chain Clorox Website: Business Partner Code of Conduct Principles 1-6
414-1 New suppliers that were screened using social criteria 100% of all suppliers, including new suppliers, must adhere to our Business Partner Code of Conduct, which addresses labor practices. We do not track percentage of new suppliers screened using labor practices criteria. The vast majority of new suppliers are informed and expected to adhere to our human rights and labor commitments through contract language requiring adherence to our Business Partner Code of Conduct. In the absence of a contract, there are other mechanisms to ensure compliance with labor practices criteria for significant purchases.  
GRI 416: Customer Health and Safety
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: What We’re Made Of Clorox Website: Social Impact Principles 7-9
103-2 The management approach and its components Clorox Website: What We’re Made Of Clorox Website: Social Impact Principles 7-9
103-3 Evaluation of the management approach Clorox Website: What We’re Made Of Clorox Website: Social Impact Principles 7-9
416-1 Assessment of the health and safety impacts of product and service categories Clorox Website: What We’re Made Of
The company assesses 100% of its products for human and environmental safety.
Principles 7-9
GRI 417: Marketing and Labeling
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Marketing Our Products Responsibly
We remain committed to providing information about our brands and products in a responsible and truthful manner, adhering to all laws and guidelines of the Federal Trade Commission and other relevant governing bodies. That means communicating the benefits, performance and attributes of our products accurately and directly, with claims that are substantiated. It’s also our policy to create and purchase advertising so we reach our target audiences with maximum efficiency, using advertisements and media that are consistent with the character and values of our company, while upholding relevant local laws and consumer privacy guidelines like the General Data Protection Regulation (GDPR). All company products have the required labeling for safety and usage. Clorox was also the first major CPG company to voluntarily disclose the product ingredients used in our cleaning and disinfecting products in the U.S. and Canada: www.IngredientsInside.com.
Clorox Website: All About Innovation
 
103-2 The management approach and its components Clorox Website: Marketing our Products Responsibly
Clorox Website: Ingredients Inside
 
103-3 Evaluation of the management approach Clorox Website: Marketing our Products Responsibly
Clorox Website: Ingredients Inside
 
417-1 Requirements for product and service information and labeling 100% of our products adhere to the appropriate regulations related to safety, caution and usage labeling.
Clorox Website: What We’re Made Of
 
417-3 Incidents of non-compliance concerning marketing communications We did not have any incidents of noncompliance with regulations or voluntary codes with respect to marketing communications.  
GRI 418: Customer Privacy
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Privacy Policy  
103-2 The management approach and its components Clorox Website: Privacy Policy  
103-3 Evaluation of the management approach Clorox Website: Privacy Policy  
418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data The company has not identified any material complaints related to this matter. Principles 7-9
GRI 419: Socioeconomic Compliance
DISCLOSURE Number Description Response UNGC PRINCIPLEs
103-1 Explanation of the material topic and its Boundary Clorox Website: Clorox Codes of Conduct  
103-2 The management approach and its components Clorox Website: Clorox Codes of Conduct  
103-3 Evaluation of the management approach Clorox Website: Clorox Codes of Conduct  
419-1 Non-compliance with laws and regulations in the social and economic area Clorox has been in material compliance with all social and economic regulations.