Colgate-Palmolive 264515272 PDF

Colgate-Palmolive
Business Practices Guidelines

TABLE OF CONTENTS
Introduction
1. Colgate-Palmolive Guidelines on Our Role in Societies Around the World . . . . . . . . . . . . . . 1.1 - 1.5
2. Sarbanes-Oxley and Related Compliance Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1 - 2.7
3. Reporting Issues and Business Practices Investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1 - 3.2
4. Colgate-Palmolive Guidelines on Conflicts of Interest and Related Issues . . . . . . . . . . . . . 4.1 - 4.5
5. Colgate-Palmolive International Competition Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . 5.1 - 5.15
6. Colgate-Palmolive Guidelines on Company Documents . . . . . . . . . . . . . . . . . . . . . . . . . . 6.1 - 6.3
7. Colgate-Palmolive Guidelines on The U.S. Foreign Corrupt Practices Act . . . . . . . . . . . . . 7.1 - 7.3
8. Colgate-Palmolive International Business Activities Guidelines . . . . . . . . . . . . . . . . . . . . . . 8.1 - 8.4
9. Colgate-Palmolive Guidelines on Business Relationships with

U.S. Government Entities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9.1 - 9.5
10. Colgate-Palmolive Guidelines

on Government Investigations and Civil Litigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10.1 - 10.2
11. Colgate-Palmolive Guidelines on Preserving Company Proprietary

Information and Respecting the Proprietary Information of Others . . . . . . . . . . . . . . . . 11.1 - 11.9
12. Colgate-Palmolive Guidelines on Securities Trading and

Conﬁdentiality of Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12.1 - 12.6
13. Colgate-Palmolive Environmental, Occupational Health & Safety

Policy Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13.1 - 13.5
14. Colgate-Palmolive Product Safety Research Policy Statement . . . . . . . . . . . . . . . . . . . . 14.1 - 14.6
15. Colgate-Palmolive Advertising Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15.1 - 15.3
16. Colgate-Palmolive Advertising Placement Policy Statement . . . . . . . . . . . . . . . . . . . . . 16.1 - 16.3
17. Colgate-Palmolive Product Integrity Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17.1 - 17.3
18. Disciplinary Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18.1

Colgate-Palmolive
Business Practices Guidelines
INTRODUCTION
Colgate-Palmolive published its first Code of Conduct in 1987. Since then,

the Company has updated the Code when significant legislative, regulatory,
or Company policies or practices have dictated doing so. Today, our Code of
Conduct is throughout the Colgate world in 27 languages. To augment the Code,
we also publish the Business Practices Guidelines.
Chapter 1 of the Business Practices Guidelines establishes the framework for

Colgate’s adherence to our Code of Conduct while Chapters 2-17 focus on key
topics selected from the Code. Our Business Practices Guidelines are intended to
amplify the values and principles described in our Code of Conduct and instruct
how and when to apply those values and principles in particular situations. The
Code and the Guidelines are independently important for what they are intended
to provide — the Code for its emphasis on Colgate’s values and the Guidelines
for their specific guidance on compliance with policies, laws and regulations. But
they work in partnership and are not intended to be a substitute for one another;
so you should acquaint yourself with both of them to help you continue to
conduct yourself in accordance with the highest ethical standards.
While using the Guidelines, should you have any questions, feel free to contact
Global Business Practices or your representative within the Legal Department.
INTRODUCTION
Chapter 1
Colgate-Palmolive Guidelines
on Our Role in Societies Around
the World
OUR RELATIONSHIP WITH EACH OTHER
Our dealings with each other should be based on mutual trust and dedication
to one another and our Company. We are responsible to ourselves and the
Company to treat each other with respect and dignity.
Successful working relationships are built on trust.

At Colgate, we take pride in the strong personal commitment of our people and
the excellence in achievement that results from that commitment. But this level
of cooperation can be achieved only in a climate of trust and mutual respect. All
of your dealings with your peers, your subordinates or your supervisors should be
conducted as a partnership, where each individual’s behavior is governed by an
overriding commitment to Colgate’s success.
Your relationship with those you work with should be as a member of a winning
team. People working in harmony and focused on a set of mutual objectives are
the driving momentum behind our business. For this dynamic team relationship
to work, each individual must fulfill his or her responsibilities — and feel assured
that others will also. This means providing the necessary support to others, at
every level, to get the job done. No individual or business unit can let its own
priorities supersede those of the Company.
Your relationship with those you work with or supervise should set an example
of decency, fairness and integrity in dealing with others. As a leader, you are
responsible for clearly defining standards of performance and creating an
environment that is conducive to teamwork.
Communicate openly and honestly.

Encourage creative and innovative thinking, and if you are a supervisor, treat
subordinates as individuals, providing them the freedom necessary to do their
jobs. Provide suggestions for performance improvement.
Your relationship with your supervisor should be one of mutual respect and trust.
You and your supervisor are a team with the shared purpose of achieving the
goals set for your unit by the Company. You are as responsible as your supervisor
O U R R O L E I N S O C I E T I E S 1.1
for ensuring that the communication between you is open and honest. Take the
initiative as often as you can. Be innovative in solving problems. Your cooperation
and creativity are essential to achieving the goals of your unit and the Company.
People are our greatest resource.

Colgate’s commitment to caring for people is manifested in the workplace
through a variety of programs designed to promote and reward individual and
team achievement. You are encouraged to advance as far as you can and to make
a meaningful contribution to the success of the Company. In the end, it is the
efforts of our talented and skilled people all over the world that make the success
of our business possible. Specifically, in matters of employment it is our policy:
• To select, place and pay all Colgate people on the basis of qualifications for
the work to be performed and without discrimination on the basis of race,
religion, national origin, ethnic origin, color, gender, age, citizenship, sexual
orientation, veteran status, marital status or a disability unrelated to the
requirements of the position.
• Not to use child labor. Child labor is defined as any person younger than the
minimum age allowed by law in the jurisdiction in question; however, in no
event will we knowingly employ anyone younger than sixteen (16) years of age.
• To achieve excellence by attracting and retaining people of all backgrounds
in our workforce.
• To provide training, education and promotional opportunities that permit
development and career advancement for Colgate people.
• To conduct performance appraisals with the goal of giving candid and
accurate feedback. To encourage two-way comments and discussion and to
afford review of appraisals by higher levels of management.
• To pay for performance and to recognize and reward contributions made by
individuals and teams that exceed their normal job duties through programs
such as the Chairman’s You Can Make a Difference Program.
• To prohibit sexual or any other kind of harassment of Colgate people by any
person in the workplace or while conducting Company business.
• To avoid favoritism or the appearance of favoritism in the workplace in
accordance with the policies and procedures adopted by the Company.
• To respect an individual’s privacy and dignity and to acquire and retain
only that personal information that is required for effective operation of
the Company or required by law. To keep such information protected and
confidential in accordance with applicable U.S. laws and laws in other countries
regarding the protection of an individual’s personal information.
1.2 OUR ROLE IN SOCIETIES

• To strive to eliminate potential hazards from the workplace and provide a safe
and healthy work environment for Colgate people and to strive to comply with
all applicable occupational safety and health laws and standards.
• To help ensure a safe, healthy and productive work environment, for
our people and others, by prohibiting the sale or use of illegal drugs on
Company time or property; to prohibit conducting company business while
under the influence of alcohol; to prohibit the use or possession of weapons
and firearms on Company premises, including in vehicles or on other
private property that may be visited while conducting Colgate business, in
accordance with Company procedures; and to report any such case of drugs
or alcohol abuse, or weapons possession to management immediately.
OUR RELATIONSHIP WITH SOCIETY
The Company strives to be a contributing member of the global community. We

are a citizen of each locality where we operate and, like individual citizens, have a
civic responsibility to support the health, education and welfare of the community.
Colgate participates in local giving and volunteerism.

Throughout the world, it is our goal to take part in projects to further the
development and welfare of the local community. Such projects include
participating in charitable drives and assuming responsibility for aiding the poor,
injured and homeless at the time of national disaster.
Our primary focus is on young people, particularly the education of young

people. Colgate believes that investments made in children today will benefit us
all tomorrow. That is why the Company sponsors reading programs, mentoring
initiatives, athletic competitions and other youth activities around the world.
These efforts foster in youth a spirit of competition and achievement.
The Company has subsidiaries or branches in over 100 countries. It is our policy
to work cooperatively with local and national governments. From time to time,
issues may arise that affect our operations. After careful consideration, the
Company will offer opinions and recommendations to governments on particular
issues to support our business goals and needs.
Colgate opposes exploitive, inhumane labor practices.
Colgate opposes the illegal use of child labor, the exploitation of children, and all
other forms of unacceptable treatment of workers. Moreover, it is Colgate’s policy
not to work with any supplier or contractor known to operate with unacceptable
worker treatment such as the exploitation of children, physical punishment,
female abuse, involuntary servitude or other forms of abuse. No abuse of child or
other labor is acceptable to the Company, and if any violation of our principles
becomes known to the Company, it is grounds for immediately terminating the
business relationship.
Colgate is committed to universal human rights.

Colgate is committed to respect for human rights worldwide. To that end,
Colgate practices and seeks to work with business partners who promote the
following standards:
• equal opportunity for employees at all levels regardless of color, race, gender,
age, ethnicity, national origin, sexual orientation, marital status, veteran
status, disability or religious beliefs;
• a safe and healthy workplace protecting human health and
the environment;
• paying employees a wage that enables them to meet at least their basic needs, and
providing employees the opportunity to improve their skills and capabilities;
• respecting employees’ lawful freedom of association; and
• working with governments and communities in which we do business
to improve the educational, cultural, economic and social well-being in
those communities.
Colgate is committed to protecting life and property.

Colgate has a commitment to protect the life and property of its people as well as
the members of the communities in which we operate. The Company maintains
a Crisis Management Plan. Any time that issues arise in the Colgate world that
involve crises relating to the environment, our products, or the life, health or
safety of Colgate people or others, you should contact your unit or division head,
who, in turn, should contact the members of the Crisis Management Team. If
you would like to know more about the Crisis Management Plan, you may
contact Global Security.
1.4 OUR ROLE IN SOCIETIES

QUESTIONS ABOUT GUIDELINES/REPORTS OF VIOLATIONS
• If you have a question about these Guidelines or their applicability to

specific situations, you should contact your unit’s legal counsel, the
Corporate Legal Department or the Global Business Practices Function.
• Suspected violations of these Guidelines must be reported to your unit’s legal
counsel, the Corporate Legal Department or the Global Business Practices
Function.
• The Company has instituted a telephone line for the Global Business
Practices Function to receive questions, comments and complaints about
matters such as the topic of these Guidelines. In the U.S., you may call
1‑800‑778-6080; otherwise you may call 212-310-2330 collect.
• You may also contact the Global Business Practices Function in writing at
300 Park Avenue, 15th Floor, New York, New York 10022-7499; by fax at
212‑310‑3745; or by e-mail at business_practices@colpal.com.
• If you choose, you may submit information to the Global Business Practices
Function on an anonymous basis. The Company will endeavor to keep the
information you submit confidential, but may need to disclose some or all
of that information in order to conduct an effective investigation and take
appropriate action.
Chapter 2
Sarbanes-Oxley and Related
Compliance Matters
OVERVIEW
Colgate’s corporate governance policies and programs, of which the Code of

Conduct is a key component, serve as an important safeguard of shareholder
value. In recent years many “checks and balances” have been enacted including
by the U.S. Congress with the Sarbanes-Oxley Act of 2002 (“Sarbanes-Oxley”),
by the U.S. Securities and Exchange Commission (the “SEC”) in implementing
Sarbanes-Oxley and in other rule-making by the New York Stock Exchange (the
“NYSE”). While these changes promote ethical corporate behavior, in many cases
they have been standard practice at Colgate for many years. Colgate shareholders
and employees are well served by an independent board that is made up of a
substantial majority of independent directors, independent committees that
oversee audit, compensation and governance matters, and charters and guidelines
that clearly define director roles and responsibilities and Colgate’s corporate
governance principles.
All Colgate people play a role in ensuring the highest standards in all facets
of our business, including compliance and corporate governance. Summarized
below are some of Colgate’s key compliance and corporate governance policies of
which managers around the world should be aware.
For a more detailed description of Colgate’s corporate governance program, please

see the “Governance” section of the “For Investors” page on www.colgate.com.
SUBSIDIARY/DIVISION QUARTERLY AND ANNUAL CERTIFICATIONS

TO CEO/CFO
As part of the U.S. Congress’s efforts to restore public confidence in the capital
markets and in corporations under Sarbanes-Oxley, CEOs and CFOs are required
to certify their company’s annual and quarterly reports filed with the SEC.
In order to support Colgate’s CEO/CFO certifications, subsidiary and division
management must certify the quarterly and annual financial statements that they
provide to Corporate Finance. In addition to certifying their financial statements,
subsidiary and division management must certify that:
• the subsidiary or division’s internal control over financial reporting is operating
effectively and is designed to provide reasonable assurance regarding the
reliability of financial reporting and the preparation of financial statements;
S ar b anes- O xley 2.1

• there are no significant deficiencies or material weaknesses in the design or
operation of internal control over financial reporting;
• there were no significant changes in internal control over financial reporting
during the most recent fiscal quarter;
• they are not aware of any fraud involving management, employees who
have a significant role in Colgate’s internal control over financial reporting
or other employees (if the fraud is material to the financial statements); and
• they are not aware of any changes that should be made to their most recent
Code of Conduct certification.
INTERNAL CONTROL OVER FINANCIAL REPORTING
Another Sarbanes-Oxley measure to restore confidence in the markets is the

requirement that U.S. companies document and test their internal controls over
financial reporting to ensure that they are effective, and make publicly available a
report of management regarding their effectiveness. Accordingly, Colgate’s annual
report filed with the SEC includes a report in which management:
• acknowledges its responsibility for establishing and maintaining adequate
internal control over financial reporting;
• indicates that it has evaluated the effectiveness of Colgate’s internal control
over financial reporting and, based on such evaluation, concludes whether
the internal control over financial reporting is effective;
• discloses any material weakness that has been identified during the
evaluation; and
• states that the independent auditors have issued a report on management’s
assessment of Colgate’s internal control over financial reporting.
Colgate must also disclose on a quarterly basis whether there has been any
change in its internal control over financial reporting during the most recent
quarter that has materially affected, or is reasonably likely to materially affect,
the Company’s internal control over financial reporting.
To support management’s report regarding the effectiveness of Colgate’s internal

controls, Colgate has instituted a global, company-wide program (the “SOX
Program”) under which the design and operation of its internal controls are
assessed, reviewed and tested on an ongoing basis. Many Colgate people around
the world are involved on an annual basis in the company-wide effort of
documenting and testing our internal controls at both the subsidiary and
corporate level.
2.2 S a r b a nes - O xley

CURRENT REPORTING REQUIREMENTS — SITUATION ALERTS
Under the rules and regulations of the SEC and the NYSE, there are certain
“material” events that Colgate must publicly disclose within four (4) business
days. The Situation Alert procedure is an important tool in ensuring that Colgate
complies with this requirement, as well as its other disclosure obligations.
Corporate and Division management have received guidance regarding the

material events that must be reported within four (4) business days. Also, Financial
Directors worldwide have received guidance from the Chief Financial Officer and
Corporate Controller specifying financial and accounting events that must be
reported immediately using the Situation Alert procedure. Subsidiary management
should ensure that they report any event required to be reported within the time
frame and in the manner specified in the Situation Alert and related guidance.
For more detailed information regarding the Situation Alert process, please feel
free to contact the Corporate Controller’s Group, the Global Business Practices
Function or the Corporate Legal Department.
AUDIT COMMITTEE PRE-APPROVAL OF SERVICES TO BE

PERFORMED BY INDEPENDENT AUDITORS
The Audit Committee must pre-approve all services to be provided by the

independent auditors, including statutory auditors of Colgate subsidiaries. The
Audit Committee Pre-Approval Policy is intended to help ensure the independence
of the Company’s external auditors and compliance with applicable rules and
regulations. The policy designates the following as “permitted services”: audit
services, audit-related services and tax services, in each case, as further described in
the policy. The policy provides that at the time the Audit Committee engages the
independent auditors to audit the financial statements for a particular year, it may
pre-approve the provision of specified audit-related services and tax services,
subject to certain maximum fees. Any other services, or any audit-related or tax
services that would exceed the maximum fees, must be approved in advance by the
Audit Committee on an engagement-by-engagement basis.
The following services are “Prohibited Non-Audit Services” and may not be
performed by the external auditors under the policy and applicable rules
and regulations:
• bookkeeping or other services related to the accounting records or financial
statements of the audit client;

• financial information systems design and implementation;
• appraisal or valuation services, fairness opinions or contribution-in-kind
reports;
• actuarial services;
• internal audit outsourcing services;
• management functions;
• human resources;
• broker-dealer, investment adviser or investment banking services;
• legal services;
• expert services unrelated to the audit;
• marketing, planning or opining in favor of the tax treatment of certain
“confidential tax transactions” or “aggressive tax position transactions”;
• any tax service, including expatriate tax services, to a person in a “financial
reporting oversight role” in a significant business unit (or an immediate
family member of such person); and
• any service for which a contingent or “value added” fee is charged.
The provision of any services unrelated to the audit should be pre-cleared with
the Corporate Controller’s Group. Under no circumstances should any of the
“Prohibited Non-Audit Services” listed above be provided, contracted for or
agreed to. For a more detailed description of prohibited non-audit services and
the pre-approval policy, please see Section E-11 of the Colgate Financial Policy.
PROHIBITION ON IMPROPER INFLUENCE OF AN AUDIT
Colgate employees, and anyone acting under their direction, are prohibited from
coercing, manipulating, misleading or fraudulently influencing the independent
auditor of Colgate’s financial statements when the employee or other person
knows or should know that such action, if successful, could render Colgate’s
financial statements materially misleading. “Improper influence” could include
the following types of conduct:
• offering or paying bribes or other financial incentives, including offering
future employment or contracts for non-audit services;
• providing an auditor with inaccurate or misleading information;

• threatening to cancel or canceling existing non-audit or audit engagements
if the auditor objects to Colgate’s accounting;
• seeking to have a partner removed from the audit engagement because the
partner objects to Colgate’s accounting;
• blackmailing; and
• making physical threats.
PROHIBITION ON LOANS TO DIRECTORS OR OFFICERS
Colgate is strictly prohibited from, directly or indirectly, including through any

subsidiary, extending or maintaining credit, arranging for the extension of credit
or renewing an extension of credit, in the form of a personal loan to any of its
directors or officers.
AUDIT COMMITTEE COMPLAINT PROCEDURES
Colgate people may direct concerns or questions relating to accounting,

internal accounting controls, financial policy, risk management or auditing
matters directly to the Audit Committee by sending an e-mail to their attention
at directors@colpal.com or by writing to Audit Committee, c/o Office of the
General Counsel, Colgate-Palmolive Company, 300 Park Avenue, 11th Floor, New
York, New York 10022-7499. These questions and concerns will be handled in
accordance with procedures established by the Audit Committee. Under these
procedures, the Company’s Global Business Practices Function, in conjunction
with the Company’s Internal Audit and Corporate Legal Departments, addresses
these concerns in accordance with the directions of the chairman of the Audit
Committee. The chairman of the Audit Committee approves recommendations
regarding the handling of each matter, oversees any investigations and approves
the disposition of each matter. In the Audit Committee chairman’s discretion, he
or she may engage outside counsel and other independent advisers.
Concerns relating to accounting, internal accounting controls, financial policy,

risk management or auditing matters may also be reported to the Global Business
Practices Function through its telephone, facsimile and e-mail hotline as follows:
24-hour Hotline: (800) 778-6080 (toll free from the United States, Canada
and Puerto Rico) or (212) 310-2330 (collect from all other locations); facsimile
number: (212) 310-3745; and e-mail: business_practices@colpal.com.
Colgate policy prohibits the Company from retaliating against any individual
who provides information to the directors. Concerns may be submitted to the
directors on an anonymous basis through their postal address or through the

24‑hour hotline numbers maintained by the Global Business Practices Function.
If requested, Colgate will endeavor to keep information submitted confidential,
subject to the need to conduct an effective investigation and take
appropriate action.
RELATED PARTY TRANSACTIONS
Under SEC rules, the Company is required to disclose any transaction or series
of similar transactions (including debt or any guarantee of debt) valued at over
$120,000 in which any Colgate entity is a participant and that involves:
• any director or executive officer of Colgate;
• any nominee for election as a director;
• any owner of 5% or more of Colgate stock; or
• any immediate family member or anyone sharing the household (other than
a tenant or domestic employee) of any of the foregoing.
Any such transactions should be pre-cleared with the Corporate Legal Department.
DISCLOSURE COMMITTEE
To assist Colgate in complying with its SEC reporting requirements, a “Disclosure

Committee” has been formed. This committee, led by the Corporate Controller
and including personnel from the Corporate Controller’s group and the
Corporate Legal Department, meets regularly to review and discuss the
Company’s public disclosure and carries out quarterly due diligence procedures in
support of the CEO/CFO certifications.

Corporate Legal Department or the Global Business Practices Function. You
should abstain from the activity in question until you have been informed
that the activity is not prohibited.
• Suspected violations of these Guidelines must be reported to your unit’s
legal counsel, the Corporate Legal Department or the Global Business
Practices Function.

1‑800-778-6080; otherwise you may call 212-310-2330 collect.
appropriate action.

Chapter 3
Reporting Issues and Business
Practices Investigations
When any event within your organization occurs that might in any way be
considered of critical importance to the business, a breach of security, a threat
to the health or safety of a Colgate person, a potential crime or violation of
Colgate’s Code of Conduct or Business Practices Guidelines, or potentially
embarrassing to the Company, it must be reported immediately.
Global Business Practices investigates all potential violations of these Guidelines,

as well as our Code of Conduct including:
• Any potential criminal conduct
• Improper financial or accounting practices
• Theft, bribes, or kickbacks
• Harassment, including sexual
• Discrimination
• Unauthorized disclosure of Company trade secrets or proprietary
information
• Improper sales practices
• Fraud (i.e., financial)
• Conflicts of interest
• Company political contributions
• Insider trading
• Any action that could potentially compromise the safety or integrity
of Colgate products
• Any action that could prove detrimental to the name and reputation
of the Company
If you know of or suspect a violation of the law, the Code of Conduct or Business
Practices Guidelines, you have a responsibility to report that information
immediately. You can report the information directly to your manager,
your unit’s legal counsel, through the Situation Alert process, or through the
24‑hour Global Business Practices Hotline at 1-800-778-6080 (United States)
or 212‑310‑2330 (collect from all other locations). The Hotline provides an
alternative means of communication for people to bring information about
inappropriate conduct to the Company’s attention.
R E P O RT I N G I S S U E S & I N V E S T I GAT I O N S 3.1

All reported violations will be promptly investigated and will be treated
confidentially to the extent possible. It is imperative that reporting persons not
conduct their own investigations. Investigations may involve complex legal
issues. Acting on your own may compromise the integrity of an investigation
and adversely affect both Colgate and you.
Submissions may be made on an anonymous basis. The Company will endeavor

to keep the information submitted confidential, but may need to disclose some
or all of that information in order to conduct an effective investigation and take
appropriate action.
Global Business Practices

Colgate-Palmolive Company
300 Park Avenue, 15th Floor
New York, NY 10022-7499
(212) 310-2330
(800) 778-6080
(212) 310-3745 (Fax)
business_practices@colpal.com
3.2 R E P O RT I N G I S S U E S & I N V E S T I GAT I O N S

Chapter 4
on Conflicts Of Interest and
Related Issues
CONFLICTS OF INTEREST
Your private life is very much your own. Still, a conflict of interest may arise if
you engage in any activities or advance any personal interests at the expense of
Colgate’s interests. It is up to you to avoid situations in which your loyalty may
become divided or be called into question. Each individual’s situation is different,
and in evaluating your own, you will have to consider many factors. As a general
rule, if you have any question as to whether any activity on your part might create
a conflict of interest or an appearance of a conflict, you should inform and seek
guidance from your manager or your unit’s legal counsel.
The most common types of conflicts are addressed here to help you make
informed decisions.
PROHIBITION AGAINST WORKING FOR A COMPETITOR
• An obvious conflict of interest is providing assistance to an organization

that markets products or services in competition with Colgate’s current or
potential products or service offerings. You may not, without Colgate’s
consent, work for such an organization as an employee, a consultant or as a
member of its board of directors. Such activities are prohibited because they
divide your loyalty between Colgate and that organization.
• Obtain approval from the Chairman and CEO, and Corporate General
Counsel before agreeing to serve on a board of directors or similar body for
an outside company or government agency.
• Serving on the board of directors for a non-profit organization can be

approved by your Division or Corporate function head.
COMPETING AGAINST COLGATE
• You may not market products or services in competition with Colgate’s

current or potential product offerings.
C O N F L I C T S O F I N T E R E S T 4.1
• It is your responsibility to consult with your manager or your unit’s legal
counsel to determine whether your planned activity will compete with any
of Colgate’s actual or potential product lines. This should be done before
you pursue any activity that might create a conflict of interest with Colgate.
SUPPLYING COLGATE
• Generally, you may not be a supplier or vendor to Colgate, represent or

work for a supplier or vendor to Colgate, or be a member of a supplier’s
or vendor’s board of directors while you are an employee of Colgate.
Exceptions to this policy may be granted by your Division head, in
consultation with the Corporate Legal Department, where the dollar amount
involved is not material. If you have any question as to whether this type of
conflict exists, please consult your manager or your unit’s legal counsel.
• You may not accept money or benefits of any kind for any advice or services
you may provide to a supplier or vendor in connection with its business
with Colgate.
• You may not work on any products or services offered by a supplier or
vendor without specific authorization by your Division head.
Investments
• Do not make any investments that might affect your business decisions.
Company policy contains prohibitions against employees owning stock
or having a proprietary interest in a company competing with or doing
business with Colgate.
• If you made this kind of investment before joining Colgate, report the facts
to your unit’s legal counsel.
• This prohibition does not apply to owning small amounts of the stock of a
publicly traded company.
USE OF COLGATE’S TIME AND ASSETS
• You may not perform or solicit outside work while on Colgate premises or
while working on Colgate time.
• You are not permitted to use Colgate equipment, telephones, materials,
resources or proprietary information for any outside work without specific
authorization by Colgate management.
4.2 CONFLICTS OF INTEREST

SOMEONE CLOSE TO YOU WORKING IN THE INDUSTRY
• With many two-career families and the expansion of the industry, you
may find yourself in a situation where your spouse, another member of
your immediate family, or someone else you are close to is a competitor,
customer or supplier of Colgate or is employed by one. Such situations are
not forbidden, but call for extra sensitivity to security, confidentiality and
conflicts of interest.
• There are several factors to consider in assessing such a situation. Among
them are: the relationship between Colgate and the other company; the
nature of your responsibilities as a Colgate employee and those of the person
close to you; and the access each of you has to your respective employer’s
confidential information.
• You should also be aware that the situation, however harmless it may appear
to you, could arouse suspicions among your associates that might affect your
working relationships. The very appearance of a conflict of interest can
create problems, regardless of the propriety of your behavior.
• To remove any such doubts or suspicions, you should review your specific
situation with your manager or your unit’s legal counsel to assess the nature
and extent of any concerns and how they can be resolved. Frequently, any
risk to Colgate’s interests is sufficiently remote that your manager need only
remind you to guard against inadvertently disclosing Colgate confidential
information.
• Notify your manager and obtain approval from your Division head and
Division General Counsel before doing business on Colgate’s behalf with any
company in which you or a close family member may in any way benefit
from your actions.
IMPROPER PAYMENTS, GIFTS AND ENTERTAINMENT
• It is not acceptable to give or receive gifts to influence any business decision.

If you intend to give a gift that is more than nominal in value, then you
must contact your Division General Counsel for approval before doing so. If
it would be embarrassing to the Company for you not to accept a particular
gift that may exceed a nominal value, then your acceptance of the gift
should be reported to the Division General Counsel. Counsel will assist in
determining whether or not you may retain the gift or place it in Colgate’s
archives.
• Gifts offered to or exchanged by employees of different companies vary
widely. They range from widely distributed advertising novelties of minimal
or nominal value, which you may give or accept, to bribes, which you
unquestionably may not give or accept. As a general rule, if you have any
question concerning whether the giving or receipt of a payment, gift or
entertainment is proper, you should report the matter to your manager and
seek guidance from your unit’s legal counsel.
Receiving
• No employee or immediate family member of any employee shall,
directly or indirectly, solicit, accept or retain a personal benefit from any
vendor, supplier or customer of the Company or from any individual or
organization doing business or seeking to do business with the Company.
A personal benefit means any type of gift, gratuity, use of facilities, favor,
entertainment, service, loan, fee or compensation or anything of monetary
value. Exception to this prohibition is made if the personal benefit falls
into one of the following categories and has no likelihood of improperly
influencing or appearing to improperly influence the employee:
• Normal business courtesies such as occasional business meals or
entertainment that are reasonable in amount;
• Paid trips or guest accommodations in connection with proper
company business and with the prior written approval of your
manager; and
• Promotional items, awards, mementos or other gifts of nominal or
modest value.
Acceptable courtesies or gifts must in all cases be lawful, unsolicited and

infrequently provided, in accordance with customary and acceptable business
practices and, as stated above, must not influence or appear to influence your
business decisions.
You may never accept a gift of cash or cash equivalents or securities.
Giving
• You may not give any gift to an executive, official or employee of any
supplier, vendor, customer, government agency or any other organization
if doing so could reasonably be construed as having any connection with
Colgate’s business relationship, except for normal business courtesies, gifts
or promotional items of nominal or modest value. Acceptable courtesies or
gifts must be lawful, unsolicited and infrequently given, in accordance with
customary and acceptable business practices and must not result in Colgate’s
obtaining an improper advantage or appearing to do so.
4.4 CONFLICTS OF INTEREST

• Colgate employees must scrupulously observe government laws and regula-
tions relating to gifts and entertainment for government employees. In the
U.S., you may not pay in whole or part for business meals, entertainment,
travel or other business courtesies for government employees. Please refer
to the “Colgate-Palmolive Guidelines on Business Relationships with U.S.
Government Entities” (Chapter 9) for further information on dealings with
U.S. Government employees.
• You may never provide a gift of cash or cash equivalents or securities.
• Colgate operating units or divisions may implement their own gift and
entertainment guidelines that are more restrictive than those described
above. Accordingly, you should consult with your manager or your unit’s
legal counsel to ensure you are in compliance with your particular unit’s or
division’s guidelines.

Function.
1-800-778-6080; otherwise you may call 212-310-2330 collect.
• You may also contact the Global Business Practices Function in writing
at 300 Park Avenue, 15th Floor, New York, New York 10022-7499; by fax at
212-310-3745; or by e-mail at business_practices@colpal.com.
appropriate action.
Chapter 5
Colgate-Palmolive International
Competition Guidelines
OVERVIEW
It is Colgate’s policy that all employees comply fully with the competition laws
of every country, state and locality where Colgate does business. The purpose
of competition laws is to protect the competitive process to benefit consumers.
Competition laws ensure that companies compete to get business by offering
lower prices, innovative products and better service and not by interfering
with the market forces of supply and demand. Competition laws also protect
companies from predatory or unfair acts by dominant companies so that the
competitive playing field is open and fair to all. Colgate supports the goals
of the competition laws. We believe that our Company performs best in a
competitive marketplace.
Virtually every country has enacted competition laws. These Guidelines

summarize the principle requirements under most competition laws, but the law
may be more or less restrictive in a particular country. It is your responsibility to
understand the laws where you are doing business and seek guidance from your
unit’s legal counsel or Corporate Legal Department as needed.
All competition laws prohibit agreements or understandings among competitors

(often referred to as “cartels”) that affect prices. Violations of these laws have
very serious consequences. Employees can receive prison sentences up to ten
(10) years and fines up to $10 million. Numerous countries also prohibit (and
severely punish) agreements on price between suppliers and resellers. Colgate
may be liable for millions of dollars in fines, penalties and civil damages if
employees violate the competition laws. Price-fixing charges also harm Colgate’s
reputation with its customers and consumers, and government investigations can
severely disrupt our business. In short, no imagined business gain is worth the
risk of violating the competition laws.
In addition, to uncover collusive schemes, many countries have adopted

amnesty programs. These programs reward the firm that discloses a cartel to the
government and cooperates in the investigation. Firms that are first to notify the
authorities can avoid penalties and jail time. The practical implication of these
programs is that there is no chance of a collusive scheme going undetected by
government authorities. Colgate must know about any suspected illegal activity
as soon as possible. Employees should report any suspected violation to their
international co m petition 5.1

unit’s legal counsel, the Corporate Legal Department or the Global Business
Practices Function.
Colgate has developed these Guidelines to assist you in understanding your

obligations under the competition laws. You should read the Guidelines
carefully. These Guidelines cannot cover every possible situation you may face or
every potential violation, but they should allow you to recognize risky situations.
You are expected to seek guidance from your unit’s legal counsel or the Corporate
Legal Department whenever you have any doubt or questions and always before
taking any action when you have a concern. Any employee who commits or
knowingly permits a violation of these Guidelines may be subject to disciplinary
action, including termination.
Basic Prohibitions: Competitor Contacts
Competition laws throughout the world prohibit agreements among existing

or potential competitors that harm competition. The key to compliance is
independence. Colgate must act independently in its business activities — setting
prices, discounts, promotions, and terms of purchase and sale; selecting
customers, distributors and suppliers; and choosing the products to produce and
how much to sell. It is important to remember that an illegal agreement does
not have to be in writing. It may be a verbal agreement or inferred from a course
of business conduct or comments in documents. An agreement also does not
have to be successful to be illegal.
Example: Representatives of two competitors are in a discussion about a

possible joint venture when someone says, “These falling prices are killing
us. I don’t know about anyone else, but we are going to hold the line.”
Within a month, both competitors raise prices. That conversation and the
subsequent pricing behavior could be used as evidence of an agreement to
fix prices, even if the firms were not successful in establishing a higher price.
Competition law violations are often based on circumstantial evidence. Therefore,

employees must avoid all communications with competitors unless they are
necessary for some legitimate business purpose, and every Colgate employee
must draft clear, accurate business documents. Rules for competitor contacts and
drafting documents are discussed in detail below.
It is Colgate’s policy that employees will not engage in any of these activities.
5.2 intern ation a l co m petition

a. No Exchange of Pricing, Marketing or Other Sensitive
Business Information with Competitors
Do not exchange sensitive business information with competitors, directly

or through a third person. Sharing sensitive business information with our
competitors can, by itself, be a violation of the competition laws or be used as
evidence of an illegal agreement. Sensitive business information includes new
product initiatives or innovations and past, current or future information about
selling prices and other terms of sale, marketing and promotional plans, profit
margins, sales or production volumes, supply or production costs or other
information from which a competitor could determine Colgate’s prices. Not only
are these exchanges unwise from a business perspective, they may be illegal and
could be used to infer illegal coordination.
If you receive a request for pricing or other sensitive business information

(described above) from a competitor — even if the competitor wants to buy
product — you should contact your unit’s legal counsel or the Corporate Legal
Department immediately.
It is permissible to collect and analyze competitive intelligence. (Please refer to

“Colgate-Palmolive Guidelines on Preserving Company Proprietary Information
and Respecting the Proprietary Information of Others” (Chapter 11) for our
policy about collecting competitive intelligence.) It is a necessary and legitimate
business activity, and you may consider competitive prices in determining
Colgate’s prices. You must, however, obtain such pricing information from
sources other than competitors and document the source of all competitive
information that you obtain.
Example: A customer sends you a copy of a competitor’s price list seeking

to get a better price from Colgate. The price list is not marked confidential
and you believe it has been distributed to others. You may consider the
competitor’s pricing in deciding how to respond to the customer. You must,
however, write on the competitor’s price list (or any other competitively
sensitive document you receive) the date you received it, how you received
it (i.e., who forwarded it to you) and the reason it was forwarded. Writing
this information on the document rather than a separate note is preferred
because notes are often misplaced or lost, leaving only your memory to
explain the circumstance in which you acquired a competitor’s sensitive
business information.
All Colgate employees must follow these rules:

• Never disclose information about Colgate to a competitor directly or use a
third party to deliver the information to a competitor.

• Never obtain information from a competitor directly or, if you know a
competitor is using a third party to deliver information, from that person.
• Never pay third parties for competitive intelligence unless cleared by your
unit’s legal counsel or the Corporate Legal Department.
• Document the legal source of a competitor’s sensitive business information.
• Report any request from a competitor for sensitive business information to
your unit’s legal counsel or the Corporate Legal Department.
b. No Price-Fixing Arrangements
“Price fixing” is one of the most frequently prosecuted and harshly penalized
antitrust violations. The prohibition against price fixing applies broadly to any
understanding or agreement that has the effect of raising, lowering or stabilizing
prices among competitors, including agreements on the following:
• Prices or discounts
• Margins
• Credit terms
• Promotional programs
• Other terms and conditions of sale
A violation need not involve an agreement on a specific price or a price range.

The agreement simply has to cover one or more components that affect prices
in order to be illegal. Moreover, it does not matter whether the agreement was
successful in fixing prices to be considered illegal. Agreements with competitors
on which day to implement a price increase or the justification offered to
customers for the price increase is also illegal.

• Never provide documents to competitors or ask for documents from
competitors about prices, discounts, promotion strategies, price lists,
marketing plans, profit margins or any document from which a competitor
can infer prices.
• Never discuss prices, discounts, promotions, pricing strategies, timing of
price increases, marketing plans or profit margins with competitors or ask
competitors for this information.
• Never discuss a customer’s resale price or the industry’s retail prices with
a competitor.

• Never discuss with a competitor the terms on which Colgate or the
competitor is dealing with customers or how it plans to deal with its
customers — collectively or individually — in the future.
• Never comply with a competitor’s request to reveal the price that Colgate
is charging its customers or a particular customer or ask a competitor for
this information.
• Never discuss or enter into an agreement with a competitor, whether
written or oral, to set the price or any other term of sale for products or
services offered by Colgate.
• Report suspected illegal activity to your manager, your unit’s legal counsel,
the Corporate Legal Department or the Global Business Practices Function.
If you become aware of any price-fixing activity within Colgate, it is your
obligation to report this information. Supervisors who are aware of price
fixing can be held criminally liable for the violation even if they did not
authorize it or participate in the scheme.
c. No “Invitations to Collude”
Even an attempt to fix prices may be aggressively prosecuted or, at a minimum,

investigated by antitrust agencies.
Example: The Chairman of American Airlines made a colorful statement to

the Chairman of Braniff Airlines suggesting that both of them raise prices.
The Chairman of Braniff rejected the offer to collude and tape-recorded
the conversation. He gave the tape to the Department of Justice’s Antitrust
Division, which prosecuted American Airlines.

• Never make a statement when competitors are present that could be
interpreted to invite or encourage competitors to take certain actions. For
example, “these low prices are killing us” or “something has to be done with
the rampant discounting in this industry.”
• Reject all offers to collude. If a competitor makes a statement similar to
the ones above, say loudly, “It is Colgate’s policy not to discuss prices with
our competitors,” and end the discussion or leave the meeting. Report the
incident to your unit’s legal counsel or the Corporate Legal Department.

d. No Market Allocations
“Market allocation agreements” refer to agreements or understandings among

competitors to divide markets in some way, e.g., by allocating customers, products
or territories or agreeing on market share targets. Market allocations — like price
fixing — are serious antitrust violations with severe penalties. Decisions as to if,
where, when, to whom and in what quantities Colgate will sell its products must
be based entirely on independent assessments of market conditions, and not
through discussions with competitors.
Example: Because of a concern that supply and demand might be out of

balance in a particular market area, one competitor discusses with another
competitor how much they intend to supply to that market area. A judge,
jury or regulator could conclude that both companies were guilty of agreeing
to allocate market shares between them.

• Never discuss sales, sales quotas, preferred markets or favored lines of
business or business partner arrangements with competitors.
• Never provide documents about customers, products or services or plans for
products or services to a competitor or ask a competitor for these documents.
• Never discuss or agree with a competitor to divide territories, markets
or customers or to otherwise restrict the variety of products and services
available to consumers.
• Never agree with a competitor to refrain from 1) marketing certain products
or services, 2) engaging in certain lines of business or 3) transacting business
with certain distributors or other business partners.
• Never discuss or agree with a competitor as to what Colgate’s or a
competitor’s market share is or will be in any geographic area.
• Never agree to a request by two or more distributors to allocate territories.
If you receive such a request, tell them it is Colgate’s policy to reject joint
requests and report the matter to your unit’s legal counsel or the Corporate
Legal Department. Take notes of the event, including your statements
and actions.
• Report any suspected illegal activity to your manager, your unit’s
Practices Function.

e. No Group Boycotts
“Boycotts” refer to understandings or agreements among companies to refrain

from dealing with another person or to pressure another person not to deal with
another party. When competitors boycott another company, it is no excuse
that there is a business reason for their joint refusal to deal. Each competitor
must decide its own course of action independently. For example, the fact that
a buyer is particularly difficult and insists on unreasonable terms would give
each supplier, acting independently, a right to refuse to sell to that buyer. It is
illegal, however, for a group of competitors to take collective action to boycott
that buyer. In addition, companies who are not competitors may also violate
the competition laws, if the purpose or effect of the boycott is to raise or
stabilize prices.
Example: The New York Attorney General’s Office found that Federated
Department Stores and May’s Department Stores pressured Waterford
Wedgeford and Lenox to pull their china and crystal from Bed Bath &
Beyond stores. Federated and May’s wanted to eliminate competition from
this discount chain. The Attorney General settled this group boycott case
after the four companies paid a collective $2.9 million in fines.
There are some rare instances — generally in connection with a joint venture or

competitor collaboration — when it is legal to exclude a competitor or deal only
with a particular supplier. For example, depending on the structure of the market,
it may be legal for a group of competitors to purchase from one or a few suppliers
to get a better price or to collaborate on a research and development project. It is
critical, however, to consult with your unit’s legal counsel or the Corporate Legal
Department before starting any collaboration with a competitor. Whether such a
collaboration is permissible under the competition laws requires some analysis.

• Never agree with a competitor to refuse to deal with anyone, unless it is
part of a legitimate joint venture approved by your unit’s legal counsel or
the Corporate Legal Department.
• Never agree with a competitor to prevent another competitor from using
some resource or facility.
• Never agree with a competitor on the terms under which you will deal with
anyone.
• Never agree with your competitors to exclude a company from an
association or standards setting group — make your own decision after
consulting with your unit’s legal counsel or the Corporate Legal Department.

• Report suspected illegal activity to your unit’s legal counsel, the Corporate
Legal Department, the Global Business Practices Function or your supervisor.
f. No Communications with Competitors Unless There Is a

Legitimate Business Reason
Most criminal and civil competition law violations begin with contacts between
competitors. As noted, courts can infer antitrust violations when competitors
communicate with each other and their subsequent behavior suggests that they
are cooperating instead of competing.
There are some situations, however, where contact with a competitor is permissible
and legal, e.g., in connection with acquisitions or joint ventures, at trade
association meetings, to coordinate joint petitioning activity before federal, state,
or local governments, or to purchase or sell products. In addition, a retailer may
convene a meeting of its suppliers to discuss common concerns. Remember there
is no protection from a competition law violation because a retailer invited you to
the meeting. No matter how the contact occurs, you must follow these rules.
Contact your unit’s legal counsel or the Corporate Legal Department before you
do the following:
1) Attend a meeting where you expect to have substantial contact with a
competitor;
2) Purchase product from a competitor or respond to a request from a
competitor to supply product;
3) Join a new trade association or standard setting organization; and
4) Join a lobbying effort with competitors.
All Colgate employees must follow these rules when meeting with or speaking to
a competitor:
• Do make sure an agenda is prepared and your unit’s legal counsel or the
Corporate Legal Department has approved it in advance of the meeting.
When at the meeting, make sure the agenda is followed, minutes are taken
and the minutes are accurate. If it is not possible to insist that an agenda be
prepared in advance, e.g., a large customer’s meeting, follow the remaining
rules and take notes at the meeting.
• Do not discuss (or make jokes about) any of the prohibited topics listed in
Sections a. through f. above.

• Conduct all contacts with competitors as if every word exchanged
were public. Remember, there is no such thing as an “off-the-record”
conversation with a competitor.
• Do immediately and emphatically disavow any invitation to discuss
a prohibited topic with a competitor. You must leave the meeting or end
the telephone conversation. Your refusal to discuss the subject — or even
listen or be present for the discussion — should be sufficiently dramatic
that the competitor will remember that Colgate employees do not discuss
such matters. Report any such incident to your unit’s legal counsel or the
Corporate Legal Department.
• Do make sure that every written communication with a competitor has
a clear, lawful purpose and is carefully drafted; ambiguous language must
be avoided. If you receive a document from a competitor covering an
illegal topic, consult with your unit’s legal counsel or the Corporate Legal
Department before responding.
• Do make sure that if Colgate is a supplier or a customer of the competitor,
any information about prices or supply is limited to the specific transaction
at issue and the communication contains only the information necessary to
complete the transaction.
Relations with Customers and Distributors
The competition laws impose certain limitations on relationships with customers

and distributors. In a number of countries, any attempt to deprive customers or
distributors of their freedom to determine prices, terms and conditions of sale,
or to place undue limitations on their right to operate independently violates
the competition laws. The competition laws in this area may be more or less
restrictive in a particular country, and you must be familiar with the laws where
you do business. It is Colgate’s policy, however, that no employee will engage in
the following conduct.
a. No Vertical Price Fixing (Resale Pricing Agreements) or

Other Undue Limitations on Customers’ and Distributors’
Independence
Any agreement or understanding with a dealer, distributor, trader or other reseller

to control minimum resale prices is likely to be unlawful. In the United States
and some other countries, it is permissible to set maximum resale prices. Consult
your unit’s legal counsel or the Corporate Legal Department before implementing
a maximum resale pricing program.

While Colgate may suggest minimum resale prices, it may not use threats or
coercion to force the reseller to adhere to certain prices. Colgate also cannot
coordinate or facilitate the joint adherence to minimum resale prices by its
customers or distributors. The setting of resale prices must always remain in our
distributors’ and customers’ sole discretion. Resale price fixing (also referred to as
“RPM” or resale price maintenance agreements) may be proved by circumstantial
evidence and a written agreement does not have to be involved.
Example: The Competition Council of France fined 13 perfume brands and

three vendors €46 million for agreeing to keep perfume prices high. The
Council found that L’Oreal SA and others set high prices for their perfumes
and then pressured vendors and threatened reprisals — including delivery
delays — against the vendors that refused to sell at those prices.

• Never agree (verbally or in writing) with a customer or distributor that
it will charge a particular price, not price below a certain price or not
offer discounts.
• Never require, demand, threaten or pressure a distributor or customer to
promise to charge a particular price, price below a certain price or not offer
discounts. It is acceptable, however, to provide incentives for a customer
not to charge above a certain price.
• Never agree to a request by two or more distributors to allocate territories.
If you receive such a request, tell them it is Colgate’s policy to reject joint
requests and report the matter to your unit’s legal counsel or the Corporate
Legal Department. Take notes of the event, including your statements
and actions.
• Never meet or talk to two customers or distributors at once if the subject of
the meeting is price discounting or other commercial practices of customers
or distributors.
• Never agree to a request or demand to intervene with respect to the pricing
practices or commercial behavior of a customer or distributor. If a request
is made at a customer or distributor meeting, state that it is Colgate’s policy
not to discuss pricing practices or commercial behavior of one customer/
distributor with other customers/distributors, terminate the meeting,
take notes of the event, and report the event, including your statement
and actions, promptly to your unit’s legal counsel or the Corporate
Legal Department.

b. No Unfair Termination of Customers or Distributors
Colgate may refuse to sell to or buy from any person if it makes the decision
independently and unilaterally. It is Colgate’s policy that all customer and
distributor terminations be made fairly and unilaterally. Under no circumstance
should any Colgate employee make a decision to terminate a customer or
distributor based on discussions, arrangements, or agreements with another
customer or potential customer or with any competitor.
• Consult with your unit’s legal counsel or the Corporate Legal Department
before terminating a distributor. If you have the authority to terminate a
distributor, make sure that you document the reasons why the distributor is
being terminated.
c. No Unlawful Discrimination on Promotions or Prices in the

United States
The U.S. Robinson Patman Act prohibits price discrimination — selling the same
product to competing customers at different prices — where the effect is to injure
competition. Price includes discounts, rebates and other terms of sale that affect
the amount paid by the customer.
Different prices may be charged to two or more competing customers, under the
following exceptions:
• Meeting Competition. Most price reductions will be based on this
exception. This defense allows a supplier to lower its price where a
competitor has offered an equally low or a lower price to the customer.
Accurate records documenting the decision to lower prices based on
competition are important to maintain, but competitors should not be
contacted to verify prices. The standard is a good faith determination that a
competitor offered a lower price, not virtual certainty.
• Cost Justification. A price difference between competing customers
is legal where the lower price is justified by a savings in cost to Colgate.
Discounts based solely on volume may not be justified unless true cost
savings result. Courts subject defendants to a high burden of proof for the
cost savings. An analysis may have to be done before the lower price is
offered.
• Functional Discounts. Different prices may be offered to customers
who provide different services to Colgate, e.g., if the customer provides
transportation. The discount amount should be related to the cost savings
to Colgate or the cost actually incurred by the buyer.

• Functionally Available to All Customers. Discounts may be offered
to customers if they are available, known and offered to all customers on a
proportional basis.
• Government/Not-for-Profit Institutions. It is not illegal to charge these
entities a lower price.
• Significant Changes in the Market. It is not illegal to charge a lower
price if there is a major market change, e.g., products about to expire or
discontinuation of a line of products.
Allowances offered by Colgate to customers in exchange for promotions or

advertisements run by the customer, or other marketing assistance given to
customers, generally must be made available on proportionally equal terms to all
other competing customers. Promotional and advertising allowances should be
designed so that substantially all of Colgate’s customers could take advantage of
the offer. Non-proportional allowances can be justified on a meeting competition
basis, subject to the requirements discussed above.
Price discrimination is a complex area of the law. You should consult with your
unit’s legal counsel or the Corporate Legal Department if you have any questions
about the legality of any pricing activity.
d. No Restrictions on Trade Between EU Member States
Any restriction in an agreement with a distributor/reseller that impedes either

the import or export of products from one Member State of the European Union
to another violates EU competition law and is subject to heavy fines. Similarly,
it is unlawful for a supplier to charge a customer more for a product if the
customer intends to export it, to disallow rebates or discounts for products that
are exported, or to apply dual price lists — one for the national market and one
for exports.
Example: ��
Automobiles Peugeot SA and its Dutch subsidiary implemented
a strategy designed to prevent dealers in the Netherlands from selling
cars to consumers in other Member States (where Peugeot prices were
higher). Peugeot SA’s payments to its Dutch dealers were based on the final
destination of the vehicle, and it denied performance bonuses if dealers
sold cars to consumers residing outside the Netherlands. Peugeot SA also
exercised, through its Dutch subsidiary, direct pressure on those dealers
who were identified as having developed a significant export activity
(e.g., threatening to reduce the number of cars supplied to them). The EU
Commission imposed a fine of €49.5 million on Peugeot SA and Peugeot
Nederland N.V.

• Never agree to any terms of trade with a distributor or reseller that includes
a ban or any disincentive on exporting/importing products between
Member States.
• Never sanction, threaten or exercise pressure against a distributor or reseller
who is exporting or importing products between Member States or invite the
distributor to stop such a practice.
• Never promise to make representations of any kind to a distributor or
reseller who exports or imports products between Member States if requested
by other distributors or resellers.
• Report any such request to your unit’s legal counsel or the Corporate Legal
Department.
Dominance
The competition laws also scrutinize the actions of “dominant” firms more
closely. Their conduct with respect to customers, suppliers, and distributors and
other competitors may be subject to additional limitations. The legal definition
of “dominance” varies by country. If you believe that Colgate has a dominant
position where you do business for any product, contact your unit’s legal counsel
or the Corporate Legal Department for additional guidance.
Company Documents
It is Colgate’s policy that every document — including instant messages, e-mails

and expense reports — created by its employees are clear, accurate and complete,
with no statements that mislead the reader or mischaracterize a situation. Please
read Chapter 6 in the Business Practices Guidelines for a complete discussion of
Colgate’s policy on drafting company documents and its mandatory document
retention policy.
Competition cases often involve issues of intent or motive. Plaintiffs and

enforcement authorities may take statements out of context or attach the most
damaging meaning to an ambiguous phrase. In addition, a company’s own
perceptions of competition and product markets — even if inaccurate — may
be used as admissions in litigation. Therefore, it is very important for all
Colgate employees to follow the rules in Chapter 6 and the ones below when
drafting documents.

• Do not overstate the significance of Colgate’s competitive position,
production or marketing strategy, e.g., “dominant position,” “this will
cripple the competition,” or Colgate is the “price leader.”
• Do not overstate Colgate’s share of any product market. Accurately describe
the markets in which Colgate competes. If you believe that other products
compete with Colgate’s products, do not refer to a “market” that does not
include those other products.
• Do not speculate on the ability of Colgate to raise prices after it makes an
acquisition or that it will have “market leverage” after it implements a new
business plan.
• Do not speculate about the difficulties a company would face in attempting
to enter the industry or expand output or on the inability of a company to
compete in a product category or geographic area.
• Do not speculate or comment on the legality or potential illegality of any
particular business conduct.
• Do not use language that gives the false impression that industry
coordination is occurring, e.g., “industry agreement,” “industry price” or
“industry policy.”
• Do record the business reason for engaging in a business practice and the
synergies, cost savings and other pro-competitive benefits that Colgate will
obtain from an acquisition or as a result of a business decision.
• Do note when a competitor is also a supplier or customer. Because Colgate’s
policy forbids discussions with competitors on prices, supply and other
sensitive business topics, there should be no mention of such discussions in
our documents unless it is in reference to a supply or purchase agreement.
QUESTIONS About Guidelines/REPORTING VIOLATIONS
• If you have a question about these Guidelines or their applicability to a

specific situation, contact your unit’s legal counsel, the Corporate Legal
Department or the Global Business Practices Function. When in doubt,
do not act until you ask and receive confirmation that the conduct is
permissible.

Practices Function.
• Colgate has instituted a telephone line for the Global Business Practices
Function to receive questions, comments and complaints relating to these
Guidelines.

In the U.S., you may call 1-800-778-6080 or 212-310-2330 collect.
You may also contact the Global Business Practices Function in writing
212-310-3745; or by e‑mail at business_practices@colpal.com.
Function on an anonymous basis, Colgate will endeavor to keep the
appropriate action. Colgate will not retaliate against employees who report
suspected violations in good faith.

Chapter 6
Colgate-Palmolive Guidelines on
Company Documents
It is Colgate’s policy that every document — including e-mails and expense
reports — created by its employees are clear, accurate and complete. Colgate’s
goal is to have objective, true business documents with no statements that
mislead the reader or mischaracterize a situation. Carelessly drafted and
ambiguous documents can unnecessarily expose Colgate to civil or even criminal
liability. Government prosecutors, plaintiffs and judges generally view Colgate’s
documents — which are created contemporaneously with events — as being
more reliable than later testimony by employees. It is critical that every Colgate
document be drafted with the understanding that it could end up in court or
before a prosecutor. Do not say anything in a document that you would not be
willing to testify to in court.
REMEMBER: Everything written is a “document” and every document

is discoverable. There is no such thing as a “personal” document in the
workplace. Calendar or diary entries, instant messages, notes in PDAs and
text messages in cell phones are all subject to discovery requests. Marking a
document “Confidential” or “Personal and Confidential” does not shield it
from discovery.
REMEMBER: Deleted e-mails and electronic documents can

be recovered. You should assume that any e-mail you write will
exist — somewhere — years from now. People are often less formal when
writing e-mail, but prosecutors and plaintiffs consider emails just as
important as formal presentations to the Board.
Every written communication should have a clear, lawful purpose, that is

consistent with Colgate-Palmolive’s Code of Conduct. The purpose should be
apparent on the face of the document and ambiguous language must be avoided.
In addition, documents that contain careless and inappropriate language may
make conduct that is perfectly legal look suspicious. “Sarcastic,” “ironic” or
broadly “colorful” comments may seem funny and may be understood by others
within Colgate at the time, but invariably can be misinterpreted — after the
fact — by a government agency or court. If you receive a document or e-mail
that contains a statement that is misleading or wrong, correct it by responding
to the e-mail or by writing notes on the document’s margin. If the document
mistakenly implies that a Colgate employee engaged in conduct that violates
the Code of Conduct, contact your unit’s legal counsel or the Corporate Legal
Department for additional guidance.
C OM PANY D O C UME N T S 6.1

Example: An employee fills out an expense report and writes under
purpose of trip: “Meet with competitors.” The employee actually was
attending a trade association meeting to discuss health and safety issues.
Years later, a plaintiff or a government enforcement agency could use that
document to support a conspiracy. The employee may no longer be with
the company to explain the true purpose of the meeting.
Colgate has a document retention program with mandatory compliance for

every employee. File management costs are high and document requests
are burdensome when large amounts of paper and electronic files are stored
unnecessarily. If you have questions about this policy or need a copy of the
document retention plan, contact your unit’s legal counsel or the Corporate
Legal Department.
All Colgate employees must follow these rules when drafting documents:
• Do not use words suggestive of illegal or surreptitious behavior, such as
“please destroy after reading.”
• Do not speculate or comment about the legality or potential illegality of
any particular business conduct or the consequences if it were found to
be illegal.
• Do not exaggerate, joke or use sarcasm.
• Do not put anything in an e-mail or other document that you would not
want read to a judge or jury. Do draft e-mails as if they were formal reports,
not conversations with friends.
• Do fully and accurately complete any report required by Colgate’s
procedures.
• Do comply with Colgate’s document retention policies.
• Do think before you write and assume that everything you write will
be made public. If you are not sure of the facts or are having difficulty
explaining the complexities of a situation, consider whether the
communication should be conveyed in a face-to-face meeting or by
telephone.
• Do contact your unit’s legal department or the Corporate Legal Department
when in doubt.
6.2 C O M PA N Y D O C UM E N T S
QUESTIONS About Guidelines/REPORTS OF VIOLATIONS
• If you have a question about these Guidelines or their applicability to a

specific situation, contact your unit’s legal counsel, the Corporate Legal
Department or the Global Business Practices Function. You should
abstain from the activity in question until you have been advised that it
is permissible.

Practices Function.
• The Company has instituted a telephone line for the Global Business Practices
Function to receive questions, comments and complaints relating to these
Guidelines. In the U.S., you may call 1-800-778-6080 or 212-310-2330 collect.
appropriate action.
C OM PANY D O C UME N T S 6.3

Chapter 7
on The U.S. Foreign Corrupt
Practices Act
It is Colgate’s policy to comply fully with all provisions of the U.S. Foreign
Corrupt Practices Act (the “Act”).
ANTIBRIBERY PROVISIONS
• The Act makes it a criminal offense to give or offer to give money

or anything of value to a foreign official, foreign political party, or
party official or candidate for foreign political office for the purpose
of influencing any act or decision of that person or entity; obtaining,
retaining, or directing business to any person, whether or not that person is
the one paying or offering the bribe; or securing any improper advantage.
• Indirect payments made through agents are also strictly prohibited, as is the
use of personal funds for such prohibited purposes.
• The Act also prohibits the offering of money or anything of value to any
person (foreign or domestic), knowing that all or a portion of such money
or thing of value will be used directly or indirectly for purposes proscribed
by the Act.
• While the law allows certain types of payments to foreign officials,
including payments to “facilitate” routine government actions, determining
what is a permitted “facilitating” payment involves difficult legal
judgments. To ensure that such transactions are proper and not prohibited, you
must consult with your unit’s legal counsel prior to making any payment or gift
believed to be “facilitating” or otherwise exempt from the law.
• Determining who is covered by the antibribery provisions is complicated;
therefore, you should consult with your unit’s legal counsel to determine
the applicability of these provisions to particular situations. However,
as a general guideline, the antibribery provisions of the Act apply to the
following organizations and individuals, among others:
– U.S. corporations and business entities and their officers, directors,
employees and agents and any stockholder acting on behalf of the
corporation or business entity;
– U.S. citizens and permanent residents residing anywhere in the
world; and
F O R E I G N C O R R U P T P RA C T I C E S A C T 7.1
– foreign companies, including foreign subsidiaries of U.S. companies, and
non-U.S. nationals who commit some act in furtherance of proscribed
conduct while within the territory of the United States.
RECORDKEEPING PROVISIONS
• The Act also requires public corporations to:

– Maintain books and records that accurately and fairly reflect all
corporate transactions, and
– Maintain a system of internal accounting controls that provide
reasonable assurance that transactions are executed as authorized; that
the books and records are maintained in such a manner that financial
statements can be prepared in accordance with generally accepted
accounting principles; and that all corporate assets are properly
controlled and accounted for.
• The recordkeeping provisions of the Act apply to issuers of U.S. securities
and to their foreign subsidiaries if the parent company holds more than
50% of the voting power of the subsidiary. Where the parent company
holds 50% or less of the voting power of the foreign subsidiary, the Act
requires the parent to attempt in good faith to use its influence, to the
extent reasonable, to cause the subsidiary to comply with the recordkeeping
provisions of the Act.
• It is Company policy to maintain accurate books and records and to

maintain a system of internal accounting controls sufficient to ensure
compliance with the recordkeeping provisions of the Act.

You should abstain from the activity in question until you have been
informed that the activity is not prohibited.
Practices Function.
7.2 F O R E I G N C O R R U P T P RA C T I C E S A C T
appropriate action.
F O R E I G N C O R R U P T P RA C T I C E S A C T 7.3
Chapter 8
Colgate-Palmolive International
Business Activities Guidelines
It is Colgate’s policy to conduct its business in accordance with all U.S. and
foreign laws and regulations applicable to the conduct of business outside the
United States. Certain of these U.S. laws and regulations that apply to business
activities outside the U.S. are summarized below.
In the conduct of both its domestic and overseas operations, the Company
fully complies with all applicable U.S. laws governing imports, exports and the
conduct of business with non-U.S. entities. These laws contain limitations on
the types of products that may be imported into the U.S. and the manner of
importation. They also prohibit exports to, and most other transactions with,
certain countries as well as cooperation with or participation in foreign boycotts
of countries that are not boycotted by the U.S. Colgate people must conduct
Company activites so as to fully comply with the laws of the countries in which
they operate; however, there may be a time when there is a conflict between
the laws of one country and those of the U.S. or Company policy. Should this
instance occur, you should consult your Division Counsel.
U.S. ANTIBOYCOTT LAWS
U.S. antiboycott laws and regulations are designed to prevent businesses from
cooperating with unsanctioned foreign boycotts of countries friendly to the U.S.,
such as the boycott of Israel by certain Arab countries.
Prohibitions
• In general, U.S. antiboycott laws and regulations prohibit cooperation with
certain unsanctioned foreign boycotts, whether by way of:
(i) refusal to do business with another person;
(ii) discriminatory employment practices;
(iii) furnishing information on the race, religion, sex or national origin of
any U.S. person;
I N T E R NAT I O NAL B U S I N E S S A C T I V I T I E S 8.1

(iv) furnishing information concerning any person’s affiliations or business
relationships with a boycotted country or with any person believed to
be restricted from doing business in the boycotting countries; or
(v) utilization of letters of credit and/or shipping documents containing
boycott provisions.
Mandated Compliance Measures

• Oral or written boycott-related requests must be reported by the Company
to the Commerce Department on a quarterly basis. The Corporate Legal
Department is responsible for making this filing.
• Form 5713 must be filed annually with the Internal Revenue Service,
reporting boycott operations or cooperation by the Company as well as
boycott requests received by the Company. The Corporate Tax Department
is responsible for filing Form 5713.
• You should be especially alert to the possibility of boycott-related requests
from any of the following countries:
Bahrain Saudi Arabia Yemen

Libya Lebanon Syria
Oman Iraq United Arab Emirates
Qatar Jordan Kuwait
These are the countries that are listed by the Internal Revenue Service as
boycotting countries. This list, however, is not an exhaustive list of countries in
which or from which the Company may receive reportable boycott requests.
• No matter where a request has originated, if you receive a request that you suspect
may be related to the boycott of Israel or any other country friendly to the United
States, you must contact the Corporate Legal Department before giving any
response to or taking any action on that request.
U.S. EMBARGOES AND EXPORT CONTROLS
The U.S. imposes certain trade restrictions under the International Emergency
Economic Powers Act, the Trading With the Enemy Act, and the related Executive
Orders and U.S. Treasury Department and U.S. Commerce Department regulations.
8.2 I N T E R N AT I O NA L B U S I N E S S A C T I V I T I E S
Prohibitions
• As of the date of these Guidelines, trade restrictions are in effect with respect
to North Korea, Burma, Cuba, Iraq, Libya, Iran, Sudan, Yugoslavia (Serbia),
portions of Angola and areas of Afghanistan that are controlled by the
Taliban. This list of embargoed countries changes frequently and, therefore,
you should be alert for any notices that the Corporate Legal Department
may send you of changes to this list.
• The prohibitions and restrictions imposed under these regulations may
cover foreign-based subsidiaries of U.S. companies as well as foreign-based
U.S. citizens and permanent residents and may affect exports, imports,
investments, travel, currency transactions, assets and accounts.
• Generally speaking, what may not be done directly may also not be done or
arranged through third parties.
• Severe civil and criminal sanctions may be imposed for violations of these
restrictions.
• Any business dealings involving any embargoed countries must be reviewed
in advance with the Corporate Legal Department.
U.S. CUSTOMS LAWS
• The Tariff Act of 1930 and other laws enforced at the border by the U.S.
Customs Service provide that certain articles are prohibited importations
into the U.S. These prohibited importations include, but are not limited to:
(i) Articles that are not clearly marked with their country of origin;
(ii) Articles that bear false designations of origin or false descriptions or
representations;
(iii) Certain food products, drugs, cosmetics, medical devices, poisons (e.g.,
pesticides and herbicides) and hazardous substances not conforming to
requirements set by the relevant regulatory agency, including the Food
and Drug Administration, the Environmental Protection Agency, the
Consumer Product Safety Commission, the Department of Health and
Human Services and the Department of Agriculture; and
(iv) Certain plants, animals, and plant or animal products.
Knowing or willful violation of any of these prohibitions (except (i)) could
result in criminal and civil sanctions while any violation could result in
seizure and possible forfeiture of the goods.
I N T E R NAT I O NAL B U S I N E S S A C T I V I T I E S 8.3

U.S. FOREIGN CORRUPT PRACTICES ACT
• Please refer to the “Colgate-Palmolive Guidelines on the U.S. Foreign

Corrupt Practices Act” (Chapter 7) for information about this law.
U.S. ANTITRUST LAWS
• The U.S. antitrust laws apply to business operations and conduct outside
the U.S. that have a direct, substantial and foreseeable effect on trade
or commerce with or in the U.S. Please refer to the “Colgate-Palmolive
International Competition Guidelines” (Chapter 5) for information about
these laws.

Function.
appropriate action.
8.4 I N T E R N AT I O N A L B U S I N E S S A C T I V I T I E S
Chapter 9
on Business Relationships with
U.S. Government Entities
It is Colgate’s policy that all Colgate employees must comply with all applicable
laws, rules and regulations in doing business with U.S. government entities
(whether federal, state or local). Guidelines based on U.S. law for employees
and other agents who are doing or plan to do business with U.S. federal, state or
local government entities are set forth below. If you are located outside the U.S.,
you should contact your unit’s legal counsel for guidelines as to dealing with
government entities in your country.
DEALINGS WITH U.S. GOVERNMENT OFFICIALS
Political Activity and Contributions

• The Company does not use its funds or assets to make political
contributions to any political party or candidate at the federal, state or
local level in the United States.
• No employee or agent may use Company facilities, such as office space,
computers, telephones, copiers, fax machines or postage, or Company
employee services in connection with political fund-raising or other
campaign activity.
• Colgate employees and agents may make political contributions using their
personal funds and may engage in volunteer political activity so long as
such activity does not occur while on Colgate premises or while working on
Colgate time.
• No Colgate employee or agent (including outside lobbyists) may be
reimbursed or compensated by the Company in any way, directly or
indirectly, for any personal political contribution made by that person.
• Questions regarding political activity and contributions or their applicability
to specific situations should be directed to your unit’s legal counsel, the
R E LAT I O N S H I P S W I T H G O V E R NM E N T S 9.1
Customer Service and Contract Compliance
• Colgate is committed to providing high quality products and service to
government customers.
• Colgate requires strict compliance with all terms of its contracts and
applicable laws and regulations.
• Questions regarding contract interpretation or compliance should be
directed to the Military Sales Group Manager or Special Sales Group
Manager, your unit’s legal counsel or the Global Business Practices Function.
Prohibited Expenditures
• Colgate employees and agents are prohibited from offering, giving, soliciting
or receiving any form of bribe, rebate, gratuity, honoraria or kickback to or
from a federal, state or local government employee or agent.
• You may not pay in whole or in part for any business courtesies, such as
meals, entertainment, travel, lodging or anything else of value, for a federal,
state, local or foreign government employee, unless you pre-clear such
business courtesies with your unit’s legal counsel.
• Gifts to such government employees on behalf of Colgate must be pre-
cleared, regardless of whether company or personal funds are used to
purchase them.
• It is a violation of the law and Colgate’s policy to provide a thing of value to
a government official on behalf of Colgate, even if it is not given with the
intent or ability to influence that official.
Lobbying Government Entities

• To ensure that the Company and its employees are complying with
applicable lobby registration and reporting laws, you must notify your
unit’s legal counsel if you are communicating with a federal, state or local
government employee on behalf of the Company in order to: (1) influence
legislation, (2) influence a formal rulemaking or ratemaking by an executive
branch agency, or (3) influence any official action of such agency (including
attempts to solicit business from the agency).
9.2 R E LAT I O N S H I P S W I T H G O V E R NM E N T S
Anti-Kickback Statute
• Federal law and Colgate’s policy prohibit you from soliciting or accepting
anything of value, including any money, fee or other compensation, for
the purpose of improperly obtaining or rewarding favorable treatment in
connection with a government contract or subcontract. The prohibition of
such payments or “kickbacks” applies in connection with the Company’s
selection of distributors and brokers or other subcontractors.
• Colgate is required to report to the government promptly and in writing
whenever it has reasonable grounds to believe that a kickback related to a
federal government contract has occurred. You must immediately report any
reasonable suspicion that a kickback may have occurred in accordance with the
reporting procedures set forth at the end of these Guidelines.
False Statements
• Colgate’s policy and the law prohibit making or causing to be made a false
statement or a false claim for payment, orally or in writing, to a government
official or willfully concealing or causing to be concealed a material fact
from a government official.
• You can violate the law and this policy even if you do not personally have
direct contact with a government official or do not personally submit a
claim or writing to the government. For example, you are prohibited from
providing intentionally false information to any other employee or third
party who later provides such information to the government.
• This policy applies to all certifications and statements provided to the
government, including certifications to qualify as a supplier to the Defense
Commissary Agency and other entities, Procurement Integrity Law
certifications and all billing statements.
Obtaining Confidential Data

• The Company must use only legitimate methods to obtain a contract to sell
its products to the government. You are prohibited from seeking or
receiving information that the Company is not authorized to possess,
including confidential or proprietary data, source selection information,
pricing information of other competitors for government contracts, and
other non-public government documents relating to government purchasing.
Hiring Former and Current Government Employees
• Strict laws govern the recruitment and hiring of former and current
federal, state or local government employees, particularly those involved
in procurement matters, by companies that conduct business with
the government.
• The written approval of your unit’s legal counsel or the Corporate Legal
Department must be obtained prior to any contact with current or former
federal, state or local government employees about employment or use as an
agent, consultant or representative.
• Should the employment issue be raised by government employees or
members of their immediate families, you should seek immediate guidance
from your unit’s legal counsel or the Corporate Legal Department.
• Former federal, state or local government employees who become Colgate
employees or consultants must strictly follow all conflict of interest laws,
regulations and policies applicable to their former government employment.
RELATIONSHIPS WITH DISTRIBUTORS AND BROKERS
• The Company engages distributors and brokers to represent it and facilitate

its business with government entities. All such agreements are required to
be in writing.
• The Company shall pay fees, commissions or other compensation to
distributors and brokers only in accordance with its written agreements.

specific situations, you should contact the Military Sales Group Manager or
Special Sales Group Manager, your unit’s legal counsel, the Corporate Legal
Department or the Global Business Practices Function. You should abstain
from the activity in question until you have received the necessary guidance.
• Suspected violations of these Guidelines must be reported to one of the
individuals/departments listed above.
• The Company has instituted a telephone line for the Global Business Practices
Function to receive questions, comments and complaints about matters such
as the topic of these Guidelines. In the U.S., you may call 1-800-778-6080;
otherwise you may call 212-310-2330 collect.
9.4 R E LAT I O N S H I P S W I T H G O V E R NM E N T S
appropriate action.
Chapter 10
On Government Investigations
and Civil Litigation
CONTACTS WITH INVESTIGATORY AGENCIES
If you are contacted by any U.S. or overseas government investigatory agency

concerning any activities relating to Colgate, including any Company subsidiary
or affiliate, prior to responding to such agency, you should immediately
report the incident in detail to your unit’s legal counsel, the Corporate Legal
Department or the Global Business Practices Function.
A copy of all subpoenas, legal documents or other correspondence received from

government authorities must be immediately forwarded to the Corporate Legal
Department (Attn: Litigation Counsel) in New York. All papers should be faxed
to 212-310-3745.
These Guidelines cover contacts with government investigatory authorities

whether on the national or local level (or in the U.S., on the federal, state or local
level). In the U.S., federal investigatory agencies include, but are not limited to,
the U.S. Department of Justice, the Federal Bureau of Investigation, the Federal
Trade Commission, the Environmental Protection Agency and the Securities and
Exchange Commission.
Colgate will not retaliate against any employee who reports information
concerning potential violations of law or these guidelines to, or who participates
in any investigation or proceeding by, any government investigatory agency.
These Guidelines do not cover routine or regular contacts with government

agencies, e.g., regular audits by tax or environmental authorities.
CONTACTS WITH CIVIL LITIGANTS
If you are contacted by any person concerning matters involving current or

threatened litigation against the Company, its subsidiaries or affiliates, you should
not respond to such person(s). You should immediately report the incident to
your unit’s legal counsel or the Corporate Legal Department. Other than speaking
with Colgate legal counsel, avoid discussing matters of pending or current
G O V E R NME N T I N V E S T I GAT I O N S / C I V I L L I T I GAT I O N 10.1

litigation with anyone. This prohibition includes discussing such matters with
your co-workers.
A copy of all subpoenas, legal documents or other correspondence received from

persons representing private litigants must be immediately forwarded to the
Corporate Legal Department (Attn: Litigation Counsel) in New York. All papers
should be faxed to 212-310-3745.
QUESTIONS ABOUT GUIDELINES/Reports of Violations
• If you have any questions concerning these Guidelines or their applicability

to specific situations, you should contact your unit’s legal counsel, the
Practices Group to receive questions, comments and complaints about
appropriate action.
10.2 G O V E R NM E N T I N V E S T I GAT I O N S / C I V I L L I T I GAT I O N

Chapter 11
Colgate-Palmolive Guidelines on
Preserving Company Proprietary
Information and Respecting the
Proprietary Information of Others
OVERVIEW
These Guidelines address the need to protect Colgate-Palmolive Company

proprietary information and to respect the confidentiality rights of competitors
and other third parties concerning their proprietary information. These
policies apply to all employees of Colgate-Palmolive Company and its
subsidiaries, worldwide.
PROTECTING COLGATE-PALMOLIVE
PROPRIETARY INFORMATION
Colgate spends a great deal of time and money developing and marketing new
products, improving existing products and devising new and efficient processes
for making these products. Our competitors could benefit if they had access to
this information. Therefore, it is the responsibility of all Colgate employees to
maintain the confidentiality of all proprietary information belonging to Colgate. It
is just as important to maintain the confidentiality of all proprietary information
that Colgate has obtained from third parties under obligations of confidentiality.
This policy, therefore, applies to all of Colgate’s non-public information, including
Colgate’s trade secrets, formulas, designs, devices and all other internal information
whether generated by or for Colgate or disclosed to Colgate by others.
Your Obligation of Confidentiality

Your obligations with respect to Colgate proprietary information are:
• Not to disclose this information to persons outside Colgate unless you are
authorized to do so.
• Not to use this information for your own benefit or the benefit of persons
outside Colgate.
• Not to disclose this information to other Colgate employees except on a
“need to know” or “need to use” basis.
P R O P R I E TARY I N F O RMAT I O N 11.1

Definition of Proprietary Information
Colgate proprietary information is broadly defined as non-public information in
Colgate’s possession. Such information gives Colgate the opportunity to obtain
an advantage over its competitors who do not have the information. As long
as secrecy is maintained, the law generally protects Colgate from the use of the
information by others in breach of an agreement, confidence or duty, or as a
result of discovery by improper means.
The law only protects Colgate information that is, in fact, kept secret. To protect
Colgate’s legal rights, it is imperative that the confidentiality of proprietary
information be maintained.
Examples of Proprietary Information

The following are examples of the types of information that may, under certain
circumstances, qualify as Colgate proprietary information:
Financial/Business
• Corporate strategic plans; budgets; internal profit and loss

data; raw material costs; identity of suppliers; customer lists;
customer information.
Corporate Organization
• Potential merger, acquisition and divestiture candidates; facility

openings or closings; employee staffing levels.
Sales/Marketing
• New product developments and proposed launches; discontinuance of

existing products; sales policies; product testing data; consumer testing
data; market research; proposed promotion and advertising campaigns.
Technical Information
• Manufacturing plant designs/redesigns; production machines and

methods; machinery supplies; R&D reports; Colgate product formulas;
packaging and package designs; internally developed software;
patentable inventions prior to patent grant.
11.2 P R O P R I E TA RY I N F O RMAT I O N
Copyright
• Colgate licenses the use of much of its computer software from a variety
of outside companies. In most instances, this computer software is
protected by copyright. Colgate does not own this software or its
related documentation and unless authorized by the software developer,
does not have the right to reproduce it. Employees caught making,
acquiring or using unauthorized copies of computer software may be
subject to disciplinary action, up to and including termination, and
possible civil and/or criminal penalties. Additionally, employees may
not make unauthorized copies of other copyrighted materials, including
publications and videotapes. While making a working copy for your
own use is acceptable, making multiple copies without permission may
violate U.S. copyright laws.
Patents
• A patent is a federal right that permits the inventor of a new, useful

and nonobvious machine, product, process or composition of matter to
exclude others from making, using or selling the invention during the
term of the patent.
• Under applicable law, inventions and other intellectual property
created by employees within the scope of their employment or in fields
related to the Company’s business are the property of the Company
and are to be assigned by employees to the Company. The Company
has the sole right to decide whether to seek patent or other protection
for any such invention.
• Employees must disclose to the Corporate Patent Department any and
all inventions or intellectual property created by them to determine
whether they are the property of the Company. No invention
belonging to the Company is to be used, disclosed or marketed without
the prior approval of the Corporate Patent Department.
This list, while not complete, suggests the wide variety of information that
needs to be safeguarded. If you are uncertain as to whether any information
is proprietary, or the extent to which certain information should be
disclosed — even to outside consultants working for Colgate or to Colgate
joint venture partners — err on the side of caution and do not disclose such
information without first contacting your unit’s legal counsel, the Corporate
Legal Department or the Corporate Patent Department for guidance.

Steps to Be Taken to Preserve Confidentiality
Take every practicable step to preserve the confidentiality of proprietary
information. For example:
• Don’t discuss business or office matters or read confidential documents
in public places, e.g., elevators, hallways, restaurants, trains, airplanes,
taxicabs, etc.
• Don’t take part in any survey, data collection or benchmarking
session — especially over the telephone — without first having received
management approval.
• Don’t discuss Colgate proprietary information with family members,
relatives or social acquaintances.
• Don’t copy confidential Company documents for your own personal use or
provide confidential Company documents to third parties in the absence
of either a written confidentiality agreement or the express consent of your
unit’s legal counsel. This includes any confidential Company documents
relating to customers, competitors or suppliers of the Company.
• If you need to transport confidential materials outside the office, ensure that
such proprietary information is properly handled and safeguarded.
• Don’t leave documents in unattended conference rooms; don’t leave
documents, flipcharts or other materials behind, erase blackboards when the
meeting is over. If a meeting or conference takes place outside a Colgate
facility, be extra vigilant about picking up all materials.
• Label particularly sensitive documents as “Confidential — Colgate-Palmolive
Proprietary Information,” so all users will be made aware of their sensitivity.
• Shred sensitive documents that are no longer needed or no longer
required to be maintained by the Company’s Record Retention Program,
instead of throwing them into the trash — particularly in view of our
efforts to recycle.
• Cover confidential documents on your desk before you leave your office;
don’t leave papers lying where visitors can see them.
• Do not give your computer “log-on” or password information to anyone and
do not leave your computer terminal “logged-on” or otherwise unattended
for any extended period of time.
• Computer disks containing confidential information should be treated with
the same degree of care as confidential papers.
• Beware of the carrying quality of conversations conducted on speaker
telephone in offices, and the potential for eavesdropping on conversations
conducted on cellphones or airplane telephones, marine radios, etc.
11.4 P R O P R I E TA RY I N F O R MAT I O N
• In appropriate cases, code names should be used in confidential documents
or documents relating to non-public matters. Other information within
such documents that might be used to deduce the identity of the parties,
such as addresses or financial information, should also be omitted from
drafts or replaced by coded information.
• Confidential information should be password protected and kept in a secure
location or under your direct supervision at all times.
This list is only suggestive. It is the responsibility of each person to take

whatever practicable steps are appropriate to preserve the confidentiality
of information.
Confidentiality Agreements
Confidentiality agreements are commonly used when the Company needs
to disclose confidential information to venders, consultants, joint venture
participants or others. A confidentiality agreement puts the person receiving
Colgate confidential information on notice that he/she must maintain the
secrecy of such information, or face legal consequences. If, in doing business
with persons not employed by Colgate, you foresee that you may need to disclose
Colgate confidential information, you should call your unit’s legal counsel or the
Corporate Legal or Patent Departments and discuss the utility of entering into a
confidentiality agreement.
Leaving Colgate
Employees’ obligation to protect Company proprietary information do not end
when they leave the Company. All former Colgate employees are legally required
to protect such proprietary information until such time that the information
becomes publicly available or the Company decides it no longer needs to
be protected.
RESPECTING THE PROPRIETARY INFORMATION OF OTHERS
It is Company policy to respect the proprietary information of others, including

our customers, vendors, suppliers and competitors. Failure to respect the
proprietary information of others violates the Code of Conduct and could place
the Company at significant legal and financial risk.
U.S. Economic Espionage Act of 1996

The U.S. Economic Espionage Act of 1996 (“EEA”) makes it a crime to wrongfully
obtain, possess, or convey proprietary information or trade secrets of another for the

economic benefits of anyone other than the owner thereof. The law broadly defines
trade secrets to include information of any actual or potential value, as long as the
owner of the information has taken reasonable measures to keep it secret.
The law covers both persons who wrongfully obtain proprietary information and
those who receive it knowing it to be wrongfully obtained. It is also illegal to plan
or conspire with others to wrongfully obtain such information.
The EEA is applicable to U.S. organizations both inside and outside the U.S., and
thus applies to Colgate and its employees worldwide.
Penalties for violating the EEA include imprisonment for up to 10 years for
individuals, and steep fines of up to $5 million for corporations for each act in
violation of the statute. Any profits or gains resulting directly or indirectly from
an EEA violation are subject to forfeiture by the U.S. Government.
Competitive Information
Business information and knowledge about our competition is very important
for Colgate to compete effectively in all of the markets where we do business.
The proper gathering of competitive information is very important to ensuring
our success as a business and is generally encouraged. On the other hand,
the improper gathering of competitive information could subject you and the
Company to criminal liability under the EEA and civil liability from competitors
as well. Accordingly, Colgate employees must not:
(1) engage in illegal or improper means to acquire competitive

information; or
(2) gather, solicit, receive, or use information derived from a competitor
that is proprietary or not in the public domain.
Guidelines for Handling Competitive Information

In particular, the following guidelines should be carefully followed when
gathering, soliciting, receiving, using or discussing competitive information:
• Methods of gathering competitive information must in all cases be open
and honest. Competitive information must never be obtained through
deceptive, illegal, unethical or improper means. Strictly prohibited activities
include industrial espionage, theft, hiring competitors’ employees to obtain
confidential information, or urging competitors’ personnel or customers to
disclose confidential information.
• If there is any indication that the information obtained remains
confidential, is not in the public domain or was not lawfully received by
the party in possession, then Colgate employees should refuse to receive
it. Competitive information received anonymously or unsolicited in the
mail or that is marked confidential is especially suspect. If you receive such
information, you should contact your unit’s legal counsel immediately. Do
not disseminate such information without first clearing it with legal counsel.
• Information that is published or is otherwise in the public domain is not
considered to be confidential or proprietary. For example, a competitor’s
sales presentation that is provided to a trade customer without an agreement
or other request to maintain confidentiality is no longer confidential or
proprietary. In this situation, it is perfectly lawful for the trade customer to
disclose this information to Colgate and for Colgate to receive it. Similarly,
information disclosed at industry or trade association meetings would not be
proprietary and could be legitimately utilized by Colgate.
• Colgate employees should not induce, whether through social or
professional relationships, present or former employees of competitors
to disclose any confidential or proprietary information. If any such
information is freely offered, Colgate employees must refuse to receive it.
• Employees of competitors must not be recruited or hired in order to obtain
confidential information relating to their former employer. Care must
be taken to properly advise new employees not to disclose or use any
confidential or proprietary information relating to their former employer.
New employees must not be placed in a position where disclosure of
proprietary information from their prior employment is unavoidable
or inevitable.
• The improper gathering of competitive information, no matter how
insignificant, could subject both you and the Company to criminal liability
under the EEA. If you have any doubts or questions concerning whether it
is lawful or proper to possess certain competitive information, you should
contact your unit’s legal counsel. Do not disseminate any questionable
competitive information without first clearing it with legal counsel.
Third Party Proprietary Information

All Colgate employees must protect the proprietary information of customers,
suppliers, consultants, joint venture participants or any other third party with the
same degree of care exercised in protecting Colgate proprietary information. In
no event should any Colgate employee disclose another company’s information
that is in some manner identified as secret or proprietary without the express
written permission of that company.

Information disclosed to Colgate by third parties under a confidentiality agreement
may, in some cases, require even greater protection than our own. When
disclosure to Colgate is made pursuant to a confidentiality agreement, you should
familiarize yourself with the terms of the confidentiality agreement before utilizing
the information.
All confidentiality agreements to be entered into by Colgate at the request of

a third party must be reviewed and approved by legal counsel. In this regard,
you should contact your unit’s legal counsel or the Corporate Legal or Patent
Departments for guidance.
We Respect Consumer Privacy

We respect and honor the privacy rights of our consumers. It is Colgate’s policy
to collect personal information from consumers only for legitimate business
purposes and to take all reasonable steps to safeguard such information.
In their interactions with Colgate, through requests for product information or

participation in Company-sponsored competitions, for example, consumers may
provide certain personal information, such as names, street addresses and e-mail
addresses, to the Company. We use such information only for the reasons it was
supplied to us, unless a consumer consents to other uses, and as necessary for our
recordkeeping purposes.
It is our policy not to share personal information about consumers with third
parties unless required to help us provide services to our consumers, and then
only if such third parties agree to protect the privacy and security of such
personal information. We also adhere to local legal requirements regarding
the protection of personal information. Further, family privacy is of utmost
importance to Colgate, and the Company complies with U.S. laws and the laws
of other countries relating to the collection and use of personal information
from children.
Unsolicited New Ideas and Suggestions Received

from Third Parties
Colgate employees often receive new ideas and suggestions from persons outside
the Company concerning marketing, advertising, trademarks, technology, as well
as other areas related to Colgate’s business. The Company has strict guidelines
regarding the submission and review of new ideas and suggestions. Accordingly,
to protect Colgate as well as those who submit their ideas to us, you should
immediately forward all such communications to your local Consumer Affairs
Department. Do not act on any such information on your own.
QUESTIONS ABOUT GUIDELINES/REPORT OF VIOLATIONS

Corporate Legal Department, the Corporate Patent Department or the
Global Business Practices Function. You should abstain from the activity in
question until you have received the necessary guidance.
• Violations of these Guidelines must be reported to your unit’s legal counsel,
the Corporate Legal Department, the Corporate Patent Department or the
Global Business Practices Function.
matters addressed in these Guidelines. In the U.S., you may call 1-800-778-
6080; otherwise you may call 212-310-2330 collect.
appropriate action.

Chapter 12
on Securities Trading and
Conﬁdentiality of Information
SECURITIES TRADING GUIDELINES

It is Colgate’s policy that all Colgate employees and agents must comply with all
laws, rules and regulations relating to the trading of Colgate securities and the
securities of other companies that may be affected by Colgate’s business activity.
Insider Status
• The securities laws of the U.S. impose important restrictions on securities
transactions by employees and others who are considered “insiders”
of companies.
• An “insider” is any person who, as a result of his or her relationship with
Colgate, learns of material, non-public information about Colgate or, in
some cases, about other companies. Thus, “insider” status can extend to
persons who are not employed by Colgate but who are retained by the
Company for a particular project or on a continuing basis.
Prohibited Buying, Selling or “Tipping”

• Colgate employees must not buy or sell stocks, bonds or other securities
(including puts, calls and options) if they possess material, non-public
information relating to the issuer of the stocks, bonds or other securities
(“Insider Information”).
• Insiders must not disclose Insider Information to another person — a
“tippee” — who uses it for trading purposes. This applies regardless of
whether the “tippee” is related to the insider or is an entity, such as a trust,
or corporation.
• That the employee believed he/she had a duty to trade or to disclose
information (for example, as a trustee) or that he/she did not intend to
defraud anyone is not a valid excuse for a violation of these securities rules.
S E C U R I T I E S T RA D I N G / C O N F I D E N T IAL I T Y 12.1
When Is Information Material?
• “Material information” includes any information that, if publicly disclosed
(a) might affect the market for a company’s securities or (b) a reasonable
investor would consider important in making an investment decision.
• Information about Colgate or other firms that may be considered material
includes proposed acquisitions or sales; changes in management or control
of the company; interim earning figures; marketing plans; new product
introductions; a significant litigation, claim or contingent liability; a
proposed joint venture agreement or termination; a proposed dividend rate
or policy change; and a possible repurchase of securities. This list is merely
illustrative and is not intended to be exhaustive.
When Is Information Non-Public?

• Information is considered to be “non-public” until it has been adequately
disclosed to the public.
• A person with material, non-public information may trade only when he
or she is certain that official announcements of the material information
have been sufficiently publicized that the public has had the opportunity to
evaluate the information.
• Examples of effective disclosure include public filings with securities
regulatory authorities, issuance of press releases and perhaps meetings with
members of the press and the public.
• An insider may not attempt to “beat the market” by trading simultaneously
with, or shortly after, the official release of material information.
• Insider trading is not made permissible merely because material information
is reflected by rumors or other unofficial statements in the marketplace.
Timing and Pre-Clearance of Transactions in Colgate Securities

• If Insider Information exists at the time an insider trades, and subsequent
disclosure of information affects the securities’ price, there is a risk that
government or private proceedings will be brought and the insider will have
to prove that he or she was not aware of the information. This may be
difficult to prove.
• A delay of two business days following disclosure is often considered a
sufficient period for routine information to be absorbed by the market.
12.2 S E C U R I T I E S T RA D I N G / C O N F I D E N T IA L I TY
• Corporate officers and directors may only trade in Colgate securities during
“window periods.” “Window periods” commence on the third business
day and end on the twelfth business day following a release of quarterly or
annual earnings information. Additionally, corporate officers and directors
may only trade during a “window period” if they do not otherwise have
Insider Information as discussed above. Corporate officers and directors
should consult with the Corporate Legal Department before engaging in any
transaction (including the exercise of stock options) involving the purchase
or sale of Colgate securities.
• An employee who has access to Insider Information should: (i) not trade
Colgate securities shortly in advance of the Company’s release of important
information, such as quarterly or annual earnings that may be affected by
such Insider Information; (ii) if possible, time trades in Company securities
to occur during the “window periods” from the third through the twelfth
business days after such releases; and (iii) consult with the Corporate Legal
Department before trading in Colgate securities whenever he or she has any
questions concerning the applicable legal restrictions.
• Any other questions regarding these restrictions should be referred to the
Sanctions for Insider Trading

• In addition to Company disciplinary measures, employees violating the
U.S. securities laws may be subject to severe civil and criminal sanctions,
including heavy fines and jail sentences, and disgorgement of the profits
gained or losses avoided by the insider trading.
• The Company may be criminally or civilly liable as a controlling person of
an insider trading violator if the Company failed to take steps to prevent the
action before it occurred. In such cases, Colgate could be forced to pay fines
and restitution totaling millions of dollars.
REPORTING REQUIREMENTS OF DIRECTORS AND OFFICERS
The U.S. securities laws have special provisions relating to the trading of securities
by directors and corporate officers of the Company and the reporting of their
securities trading activities and securities ownership. For further information,
directors and officers should consult the Company’s Memorandum to Directors
and Officers on Securities Trading and Reporting, which is available from the
PRESERVING THE CONFIDENTIALITY OF INFORMATION
All Colgate personnel must maintain the confidentiality of non-public

information belonging or relating to Colgate or relating to others and obtained
through a relationship with Colgate. This policy applies to all of Colgate’s
material, non-public information, including Colgate’s (and others’) trade secrets,
proprietary information and other internal information.
Steps to Be Taken to Preserve Confidentiality

Take every practicable step to preserve the confidentiality of information.
For example:
• Don’t discuss business or office matters or read confidential documents
in public places, e.g., elevators, hallways, restaurants, airplanes, trains
or taxicabs.
• Don’t discuss Colgate confidential information with family members,
relatives or social acquaintances.
• Don’t discard documents where they can be retrieved by others. Shred
sensitive documents.
• Don’t carry documents in elevators, hallways, etc. in an exposed manner.
• Beware of the carrying quality of conversations conducted on speaker
telephones in offices, and the potential for eavesdropping on conversations
conducted on car or airplane telephones, on marine radios, etc.
• Don’t leave documents in unattended conference rooms; don’t leave
documents, flipcharts or other materials behind when a meeting or
conference is over; erase blackboards and dryboards when a meeting or
conference is over. If a meeting or conference takes place outside Colgate,
be particularly careful about retrieving all Colgate materials.
• Cover confidential documents on your desk before you leave your office;
don’t leave papers lying where visitors can see them.
• Don’t give out the whereabouts of personnel not in the office or reveal the
presence of specific visitors to the office except when authorized. The mere fact
of a meeting or the destination of a trip may reveal something confidential.
• Under no circumstances are employees to copy confidential documents for

their own personal use or provide confidential company documents to third
parties, without either a written confidentiality agreement or the express
consent of their unit’s legal counsel. This includes any confidential company
documents relating to customers, competitors or suppliers of the company.
• In appropriate cases, code names should be used in confidential documents
or documents relating to non-public matters. Other information within
such documents that might be used to deduce the identity of the parties,
such as addresses or financial information, should also be omitted from
drafts or replaced by coded information.
• Do not give your computer “log-on” or password information to anyone and

do not leave your computer terminal “logged-on” or otherwise unattended
for any extended period of time.
• Computer disks containing confidential information should be treated with

the same degree of care as other confidential documents.
• Don’t take part in any survey, data collection or benchmarking

session — especially over the telephone — without first having received
management approval.
• If you need to transport confidential materials outside the office, ensure that
such confidential information is properly handled and safeguarded.
• Label particularly sensitive documents as “Confidential — Colgate-Palmolive

Proprietary Information,” so all users will be made aware of their sensitivity.
• Confidential information should be password protected or kept in a secure
location or under your direct supervision at all times.
This list is only suggestive. It is the responsibility of each person to take

whatever practicable steps are appropriate to preserve the confidentiality of
information.
RESPONDING TO INQUIRIES FROM THE PRESS AND OTHERS
• If someone from outside the Company, such as the media, press, financial
community or the public, asks you for financial or business information
about Colgate, either directly or through another person, do not attempt to
answer them.
• You should obtain the name of the person making the inquiry and
immediately notify the Vice President–Corporate Communications and
the Vice President–Investor Relations. Requests for information or other
contacts from the Securities and Exchange Commission, the New York Stock
Exchange or other regulators must be referred to your unit’s legal counsel or
the Corporate Legal Department.
• The Company does not make selective disclosure of material non-public
information to securities market professionals, stockholders or other third
parties who may trade on that information.
PERSONS COVERED BY GUIDELINES
These Guidelines cover all Colgate employees, officers, directors and agents as
well as spouses, family members and others who live with them, and any other
people who might reasonably be deemed to have a direct or indirect relationship
to Colgate such that application of the Guidelines would be required to protect
Colgate or comply with applicable law.
• If you have a question as to whether information regarding the Company

or other firms with which the Company does business or is negotiating or
competing is material or has been adequately disclosed to the public, you
must contact your unit’s legal counsel, the Corporate Legal Department or
the Global Business Practices Function. You should abstain from trading
in the affected securities or disclosing the information until you have been
informed by one of the above people that the information is not material or
has been publicly disclosed and digested.
• Other questions about these Guidelines or reports of suspected violations
also should be directed to your unit’s legal counsel, the Corporate Legal
Department or the Global Business Practices Function.
matters addressed in these Guidelines. In the U.S., you may call 1-800-778-
6080; otherwise you may call 212-310-2330 collect.
• If you choose, you may submit information to the Business Practices
appropriate action.
Chapter 13
Colgate-Palmolive
Environmental, Occupational
Health & Safety Policy Statement*
At Colgate, we are committed to conducting ourselves in a responsible manner
to protect people and the environment in every area of the world in which
we operate.
The following Environmental, Health & Safety principles guide all of our
decisions on products, packaging, facilities and business decisions. Colgate
people are expected to incorporate environmental, health and safety
considerations into their daily activities. Training is provided to further
their understanding of these considerations.
1. OUR PRODUCTS
We will provide the public with safe and effective products and will strive to
produce products that have the lowest practical impact upon the environment.
High Product Standards

• We will comply with applicable government rules and regulations in the
formulation, manufacture, labeling and marketing of our products and
exceed them when Company standards are higher. These standards are not
intended to replace applicable regulatory requirements.
Continuous Evaluation
• We will continuously evaluate the impacts of our products and processes
upon the environment.
Risk Minimization
• We will consider and minimize environmental risks as part of our product
formulation and development procedures.
*This policy is also available in pamphlet form for distribution to the public upon request.
E O H & S 13.1
Consumer Communication
• We will communicate with consumers regarding the environmental impact
of our products, including their potential abuse or mishandling.
Resource Efficient Formulations

• We will strive to develop products that meet or exceed consumers’
expectations based on resource efficient and environmentally sensitive
technologies.
2. OUR PACKAGING
To reduce the impact of our product packaging on the environment, Colgate-

Palmolive, as a worldwide consumer products company, will work to improve the
environmental compatibility of all our packaging materials. At the same time, we
will continue to ensure the safety and efficacy of our products and packaging. In
taking these steps, Colgate endorses the worldwide hierarchy of solid waste
management: source reduction, recycling (including reuse), incineration,
and landfilling.
Ongoing Examination & Impact Quantification

• We will examine and, where appropriate, quantify the environmental
impacts of the volume and toxicity of our packaging.
Heavy Metals Elimination

• We will eliminate from our packaging those heavy metals in printing inks
and colorants that may leave hazardous residues when incinerated or
disposed of in landfills.
Source Reduction & Waste Management

• We will strive to reduce the volume and weight of our packaging and use the
minimum amount of packaging required to label our products and protect
their contents.
Recycling
• We will utilize recycled and recyclable materials in our packaging, including
paperboard and plastics, whenever practicable.
13.2 EOH&S
Coding
• We will code our plastic packaging with recycling symbols,
where appropriate.
Public Awareness
• We will support efforts to educate consumers to become part of the recycling
solution through changes in use and disposal habits.
Research
• We will contribute to research in the area of solid waste management.
3. OUR FACILITIES
Colgate is committed to the health and safety of all employees, and the
communities in which we operate as well as the protection of the environment.
We will establish and maintain programs for the operation and design of our
facilities to meet or exceed applicable environmental laws and regulations.
Periodic Reviews
• We will conduct periodic reviews of the potential impact of our operations
on the environment and on the health and safety of our people.
Ongoing Evaluation & Improvement

• We will evaluate the potential impact on the environment as well as
on the health and safety of our people, in the design, construction and
improvement of facilities and processes.
Hazardous Waste Minimization

• We will work to minimize the generation of and strive to eliminate the
discharge of hazardous materials into the air, water and land.
Employee & Community Safety

• We will seek to minimize environmental, health and safety risks to our
people and the communities in which we operate by employing safe
technologies, operating procedures and emergency plans, including the
training of employees.
E O H & S 13.3
Community Awareness
• We will communicate with local communities on the environmental safety
of our operations.
Safe Disposal
• We will dispose of all hazardous wastes through safe and responsible methods.
Safe Energy
• We will strive to utilize environmentally safe and sustainable energy sources
to meet our needs.
Raw Materials & Waste Reduction

• We will strive to improve our processes to use fewer raw materials and
produce less waste.
Employee Participation & Training

• We encourage all Colgate people to identify potentially hazardous
environmental, health and safety conditions. Training will focus on giving
all people the skills and knowledge to work safely and promote sound
environmental practices.
4. OUR BUSINESS DECISIONS
Protecting and enhancing the company’s reputation is vitally important.

Accordingly, Colgate considers environment, health and safety to be key business
issues. We consider these issues in all business decisions, including acquisitions,
divestitures, discontinuance of operations, leasing and entry into joint ventures.
We will also act in a responsible manner with respect to the environmental
protection of the lands under our management and ownership.
Environmental, Health & Safety Issues and Liabilities Review

• We will review potential environmental, health and safety issues and
liabilities prior to any acquisition, divestiture, discontinuance of operations,
leasing or entry into joint ventures.
Property Evaluation
• We will evaluate owned and operated property to identify significant
environmental, health and safety issues.
13.4 EOH&S
Voluntary Identification & Cleanup
• We will participate in the voluntary identification and cleanup of
environmentally contaminated locations involving the Company, as may
be appropriate.
Address of Past Practices

• We will act responsibly to address identified risks to public health or
the environment, and will cooperate with regulatory agencies and other
interested groups in achieving acceptable solutions.
Preserve and Create Value

• We will communicate to Colgate people that sound environmental,
health and safety practices will preserve and create value for our
Company worldwide.
• If you have a question about these Guidelines or their applicability

to specific situations, you should contact you unit’s legal counsel, the
Practices Function.
appropriate action.
E O H & S 13.5
Chapter 14
Colgate-Palmolive Product Safety
Research Policy Statement*
Colgate-Palmolive’s Approach to Assuring Product

Safety for Our Consumers Around the World
At Colgate-Palmolive, the safety of our consumers is our first and greatest

concern. We manufacture and sell a wide range of consumer products for oral
care, personal care, household surface care and fabric care that are sold in over
200 countries around the world. We believe that the safety of these products is
an ethical obligation. Our Company is committed to ensuring that consumers
can trust Colgate products for their safety, quality and superior performance and
that the Colgate people who make these products are never put at risk.
HOW DOES COLGATE ENSURE THAT ITS PRODUCTS

ARE SAFE?
All of the products that we manufacture and sell are subjected to rigorous safety
evaluations long before they ever reach the store shelf. From the time that a
product first begins its development cycle, all of its ingredients, their interactions
and their effects for both intended use and accidental misuse are assessed to
assure that the product is safe. After determining if ingredients are safe for use
in a Colgate product, our scientists then examine everything about the product,
including its efficacy and any potential adverse effects of usage. With this
knowledge, the scientists also develop the appropriate instructions for use found
on the label of a finished product.
Colgate Standards and Government Standards

Before testing even begins, Colgate’s scientists have a responsibility to find all the
information they can about the ingredients they are considering for inclusion in
a product. They also ensure that the ingredients meet our Company’s internally
established safety standards. Once these hurdles have been cleared, our
scientists review all regulatory requirements to be sure that the product they are
formulating meets government compliance guidelines.
*This policy is also available in pamphlet form for distribution to the public upon request.
P R O D U C T SAF E TY R E S EA R C H 14.1
The products we sell and the safety testing we conduct are highly regulated by
laws and government agencies in nearly all countries around the world. Many
of our products are developed for regional or global distribution. If standards in
a particular country fall below those of Colgate-Palmolive, we adhere to our own
stricter guidelines. Alternatively, where standards are different, or more evaluation
is requested by a governing body, Colgate undertakes the necessary tests to
ensure compliance.
Our goal is to meet these safety requirements whenever possible through the use
of existing data or tests that don’t put humans or animals at risk.
Today at Colgate, animal testing is the exception to the rule in our product
safety efforts, with more than 99% of all internal requests for product safety
substantiation being met using non-animal alternatives and available databases.
Unfortunately, however, there are conditions under which we must conduct

animal testing. There are government regulations in the U.S. and in many
countries that, as a condition of sale, specifically require animal testing be
conducted to establish proof that a product is safe and to determine labeling
instructions. Additionally, there are circumstances where safety demonstrations
are necessary but scientifically recognized alternatives to animal testing do not
yet exist. Our goal is to continually search for alternatives.
OUR USE OF ALTERNATIVE TESTING METHODS
Computer Databases
Extensive historical data is often available to Colgate’s researchers when they
begin to evaluate the safety of ingredients for inclusion in a new product. Our
scientists have access to governmental data and independent agency, company,
industry and organizational information from studies already conducted utilizing
both animal and non-animal tests. As a result, in many instances we can avoid
re-testing because data already exists to prove efficacy and safety.
In-Vitro Evaluation
In-vitro testing involves the use of cell culture or tissue culture test systems.
At Colgate, we have developed a variety of these non-animal and non-human
alternatives for evaluating new products. For instance, Colgate scientists have
developed an artificial mouth that simulates the dynamics of the human mouth.
This has contributed to a significant reduction in our testing with animals in
laboratory settings. Additionally, we employ cell-culture models that can predict
the effects of ingredients in humans without the need to test on animals.
14.2 P R O D U C T SA F E TY R E S E AR C H
Human Clinicals
Human testing is critically important to product safety research for Colgate’s
new products. These studies help Colgate scientists gain the knowledge needed
to protect human health and safety and to learn, for example, exactly how a
toothpaste performs in the mouth or how a soap behaves on the skin. These
tests are strictly regulated by government and industry standards to assure the
safety of participants.
OUR POLICIES LIMITING ANIMAL TESTING
Very often some promising new ingredients and materials that offer important
health or other benefits are identified that have not been evaluated to determine
their safety or efficacy. While some non-animal testing methods have proven
successful in predicting safety, they are still not completely sufficient to assure
all aspects of product safety and thus replace all testing on living organisms.
Also, many governments continue to require information from animal tests
before a product can be introduced. At Colgate, however, animal testing is only
conducted after all other options have been exhausted. Prior to conducting tests
with animals, reasonable assurances must also be provided that new scientific
knowledge will be gained to benefit the health and welfare of either humans
or animals. When animal tests are performed, they are always planned to
involve only the minimum number of animals required to obtain scientifically
meaningful results or to comply with regulatory mandates.
All of our animal testing is conducted at outside laboratories, but under Colgate
supervision. No animal testing is done in-house. Contract laboratory testing is
governed by a strict set of Colgate-developed guidelines, which meet or exceed
legislated standards.
We insist that testing procedures and practices be governed by the highest

consideration for humanitarian ideals coupled with technical professionalism.
With regard to the handling and care of animals, no procedure is undertaken
which could be expected to inflict undue pain or distress. Anesthesia is used
where appropriate to insure animal comfort.
Colgate does not, and will not in the future, use either the standard Draize eye
irritation test or the Classic LD 50 test, except in those instances where explicitly
required by a regulatory authority. Even in these cases, our policy is to challenge
this requirement and seek access to the regulatory officials to present alternative
means for assessing the safety of the product.
OUR MORATORIUM ON ALL ANIMAL TESTING OF ADULT
PERSONAL CARE PRODUCTS
After careful study by our safety experts, early in 1999, Colgate declared a voluntary
moratorium on all animal testing of our Personal Care products designed for adults
and the ingredients used in those products. Advances in-vitro testing alternatives
coupled with the safety data available for the ingredients regularly used in these
products make it possible to institute this moratorium while still ensuring the
safety of our consumers and employees. This decision affects the following product
categories: underarm deodorants; hair shampoo; hair conditioners and styling aids;
men’s and women’s fragrances; after-shave lotions; men’s and women’s talcs; shaving
cream; bar soaps; liquid soaps and shower gels. Products that are classified as drugs
or pharmaceuticals, subject to specific regulatory requirements or intended for oral
application or use, are excluded from this moratorium.
We feel that this moratorium is a positive step forward. However, we will

maintain the option of using animals for this category when we cannot find
other appropriate means to insure the safety of our consumers and our people.
OUR COMMITMENT TO RESEARCH AND ACCEPTANCE OF

ALTERNATIVES
Since 1982, Colgate has undertaken a broad program dedicated to advancing

the development of scientifically acceptable and properly validated alternatives
that will remove the need and governmental requirements to carry out any
research with animals. Working with industry associations, governments and
other companies, we continually strive to promote, advocate and participate
in activities that encourage independent validation and acceptance of these
new methods by regulatory agencies. Toward that end, Colgate is working
actively with a wide variety of organizations who share our goal of completely
eliminating animal testing.
Colgate funds research and teaching fellowships devoted specifically to the search
for alternatives and the training of scientists in the use of alternative methods.
Colgate executives and scientists actively participate in a number of collaborative
international initiatives to uncover new scientific advances and to achieve
regulatory acceptance of proven alternatives. We believe that our practice of
sharing the results of our alternatives research work with other companies and
government agencies is an important contribution towards helping others
achieve similar success in reducing animal use.
14.4 P R O D U C T SA F E TY R E S EA R C H
OUR COMMITMENT TO CHALLENGE UNNECESSARY GOVERNMENT
REQUIREMENTS
Colgate’s global presence affords us a unique opportunity to help foster

acceptance of non-animal alternatives by regulatory agencies around the world.
Many overseas health and safety agencies persist in requiring unnecessary or
inappropriate animal tests. Frequently, these requirements persist because local
regulators lack awareness of alternatives or up-to-date information about their
validation. In some cases, regulators can be persuaded to accept existing safety
data prepared for other authorities, rather than require the new animal tests.
Whenever possible, we will work with other companies and organizations towards
the elimination of these testing requirements. Colgate recognizes that we will
not always persuade regulators to accept alternative safety assurances. However,
as part of our commitment to the elimination of animal testing, our policy is to
bring such scientifically valid alternatives to the attention of regulators and urge
their acceptance.
OUR COMMITMENT TO UTILIZING SCREENING MECHANISMS
Although alternative-to-animal test methods have not yet been developed to the
stage where they can completely replace animal testing, there are situations in
which Colgate and others use these tests to screen new materials for safety and
efficacy that contributes to significant reductions in animal use. Also, when a
number of product or ingredient options are being considered, the alternative
screening tests can be used to select the safest and most effective options so that
if animal testing is required, it does not need to be conducted on all the options,
but only on the most promising ones. In some cases, however, screening tests
can give a high enough level of comfort to allow us to go directly to human
safety clinical studies without conducting any animal tests.
OUR POLICY OF OPENNESS
We are committed to responding openly to the issues and questions related to

product safety research and animal laboratory testing, to sharing this information
with all parties — individuals, organizations, other companies and government
agencies — interested in contributing to further reductions in the use of animals
and particularly with those who share our goals in developing and implementing
effective alternative testing and validation methods.
COMPLIANCE WITH ANIMAL TESTING POLICY
All laboratory testing involving animals must be approved and coordinated

through the Corporate Product Safety Group in Global Technology. Requests or
questions in this regard should be directed to Product Safety Assurance, Global
Technology at (732) 878-7500.
QUESTIONS ABOUT GUIDELINES/REPORTS OF VIOLATIONs
• If you have a question about these Guidelines on their applicability to

Function.
Practices Function to receive questions, comments and complaints abut
appropriate action in order to conduct an effective investigation and take
appropriate action.
14.6 P R O D U C T SA F E TY R E S EA R C H
Chapter 15
Colgate-Palmolive
Advertising Guidelines
The Colgate-Palmolive Code of Conduct requires that an advertisement must be
honest and not misleading. This guideline details the responsibilities associated
with truthful and non-deceptive advertising.
ADVERTISING IS CONSTRUED BROADLY
• Advertising is to be construed broadly. It includes all communications about

our products including packaging, promotion, point of sale material and
product publicity. The totality of our advertising establishes the integrity
that we want our consumers to associate with Colgate and its products.
NET IMPRESSION BASIS
• All advertising is evaluated on a net impression basis. That is, not only
must what is said and what is illustrated be truthful, but the overall
“net” impression of the advertisement on the consumer must be truthful,
accurate and not misleading. Colgate advertising must also be in good taste
characterized by honesty and decency.
TYPES OF PRODUCT CLAIMS
• Product claims may be express in that they make an affirmative

representation about a product attribute. Claims may also be implied. An
implied claim communicates by suggestion in addition to what is said
or illustrated. Both types of claims must be fully substantiated prior to
dissemination.
CLAIMS SUBSTANTIATION
• All objectively verifiable claims for product performance or characteristics,

whether express, implied or drawn from the net impression of an
advertisement, must be supported by consumer research, clinical or
laboratory data, or another similar factual source. This support must be
adequate and available prior to the time the advertising is disseminated.
• In general, the adequacy of substantiation required is determined by the claim.
AD V E RT I S I N G 15.1
• Claims that are express (e.g., proven, established, medical study, laboratory
test) must be supported by the amount and type of substantiation the
advertisement actually communicates to the consumer.
• A claim that establishes a product’s efficacy must be supported by the
amount and quality of evidence sufficient to satisfy the relevant scientific
community of the claim’s truth. For some products, establishment claims
require two or more adequate and well controlled clinical investigations
demonstrating the claimed efficacy.
• Claims that do not specify their level of substantiation but nevertheless
are objectively verifiable must have a reasonable basis. What constitutes a
reasonable basis is determined by taking into account the product involved,
the type of claim, the consequences of a false claim and the amount of
substantiation experts in the field would think is reasonable.
PUFFERY
• There are statements in advertisements that are not capable of being

objectively measured or that consumers would not take seriously. Such
statements are not verifiable claims but instead are considered puffery. Puffery
is usually extreme exaggeration or hyperbole. Substantiation is not required
for such statements.
ENDORSEMENTS AND TESTIMONIALS
• Personal endorsements and testimonials are claims and when used in

Colgate advertising must be substantiated. Additionally, testimonials that
imply professional expertise or special competence in an area where a
spokesperson is not in fact an expert are improper. Signed documents must
be secured from endorsers attesting to their use of and experience with our
product. Specific experience endorsement claims are generally limited to
experiences that reflect results typically achieved by product users.
PRODUCT DEPICTION
• Product visualization and demonstrations in advertising must accurately

portray the quantity, quality and attributes of a Colgate product that a
consumer expects to receive. Photographs of products must be depicted as
normally marketed. Neither mock-ups nor camera manipulations may be
used to show product attributes or performance other than those normally
found in or delivered by the product.
15.2 A D V E RT I S I N G
TRADEMARK ISSUES
• It is Company policy that all advertising, sales promotional and packaging

materials not be copied — in whole or in part — from competitors’ materials.
Particular care should be taken in the use of trademarks, logos, package
designs and slogans. Further guidelines relating to trademark matters can be
found in the “Quick Answers to Trademarks and Copyright Questions and
Procedures” manual published by the Corporate Trademark Department.
• Management is responsible for the approval of Colgate advertising and

compliance with these Guidelines in partnership with their unit’s legal
counsel and the Corporate Legal Department.
Practices Function.
matters such as the topic of these Guidelines. In the U.S., you may call 1-
800-778-6080; otherwise you may call 212-310-2330 collect.
212-310-3745; or by e-mail at business_practices@colpal.com
appropriate action.
AD V E RT I S I N G 15.3
Chapter 16
Colgate-Palmolive
Advertising Placement
Policy Statement
Colgate-Palmolive provides products that offer consumers real and unique
values. The role of our advertising is to communicate those unique values in a
manner consistent with the highest ethical standards, because our advertising
creates more than a product image. It mirrors Colgate’s reputation for reliability,
dependability and trustworthiness.
Our advertising in its placement, as well as its content and format, is sensitive to
the public and its concerns, interests and sensibilities.
Specifically, Colgate-Palmolive does not advertise in a media context:

• That includes gratuitous or excessive violence — that is, violence that is not
necessary to the development of a program’s character or story line or an
article’s development. Colgate-Palmolive also disqualifies those programs
where some violence is an integral part of the story line, but which feature
unnecessary violent details, brutality or suffering.
• That it considers antisocial or in bad taste, or that could stimulate antisocial
behavior through viewer imitation.
• In which sexual behavior is grossly aberrant and/or offensive.
• That lends actual or implied support for those activities that may abuse the
physical or mental health of an individual.
• That insults, ridicules or denigrates people because of their age, gender,
sexual orientation, race, religion or ethnic origins or engages in other
inappropriate stereotyping.
Colgate-Palmolive charges its advertising agencies and their media buying

services with the responsibility of pre-screening any questionable media content
or context. If there is any doubt about media suitability for Colgate-Palmolive
advertising, it is referred to Colgate-Palmolive media management for review
and discussion.
As a corporation, Colgate-Palmolive is sensitive and responsive to consumers’

changing needs and values. Our advertising policy guidelines are periodically
AD V E RT I S I N G P LAC EM E N T 16.1
reviewed and revised to ensure their appropriateness in fulfilling both the needs
of the Company and those of our consumers.
MEDIA SELECTION CRITERIA
While Colgate values all media vehicles for disseminating our advertising
messages, not every media vehicle is appropriate for use. Selection criteria such as
demographics, brand relevancy, editorial content, strategic priority and cost are all
measures we closely evaluate in making our final advertising vehicle selections.
Our advertising is accurate.

One of the most important aspects of our business is advertising. Advertising
should be creative and competitive, but at the same time honest and not
misleading. Our advertising must also avoid any stereotyping of individuals based
on factors such as race, religion, national origin, ethnic origin, color, gender,
age, citizenship, sexual orientation, veteran status, marital status or disability.
Advertising creates more than a product image. It creates our reputation for
reliability, dependability and trustworthiness. In addition, we exercise care in
the selection of the media in which our advertising messages appear. We do not
permit our advertisements to appear on television programs or in other media that
make gratuitous or excessive use of violence or sex or are antisocial or in bad taste.
We observe standards of commercial fairness in devising, using and selecting

advertising and trademarks, so that our products succeed on the strength of their
own quality and our reputation, rather than by imitation or trading on the good
will of competitors.
Commercial fairness implies:

• Strict adherence to local legal requirements respecting trademark
infringement and unfair competition.
• Avoiding copying of well-known trademarks, slogans, advertising themes

and graphics used by multinational companies outside your locality.
16.2 A D V E RT I S I N G P LA C E M E N T

Practices Function.
appropriate action.
AD V E RT I S I N G P LAC EM E N T 16.3
Chapter 17
Colgate-Palmolive
Product Integrity Guidelines
Colgate products are intended to meet all legal requirements as well as our own
high standards for safety, reliability, quality and performance. This applies
to product composition, labeling and efficacy. Consumer health and safety
considerations are our primary concern.
ADULTERATION AND MISBRANDING
Adulteration
• Colgate products are not adulterated. Colgate is committed to producing
its products in compliance with good manufacturing practices in product
manufacture. It is Colgate’s policy to manufacture products with pure
ingredients and in an appropriate manufacturing environment. In addition,
all Colgate products meet our high standards for consumer safety, product
identity, strength, quality and purity in compliance with applicable laws.
All products are packaged in appropriate containers designed to protect the
product and the consumer.
Misbranding
• The labeling for Colgate products should not be false or misleading in any
respect. All required label information should be contained in product
packaging, including an understandable description of the product by
established name or otherwise, as well as adequate directions for use.
COMPLIANCE WITH LAWS AND REGULATIONS
Colgate products may fall within the jurisdiction of one or more regulatory
authorities within the countries where the Company does business. In all cases,
whether within or outside the U.S., it is Colgate’s policy to lawfully register
its products, lawfully manufacture its products and lawfully label its products
for distribution as well as consumption. Furthermore, Colgate shall meet all
applicable consumer and product safety standards.
Employees should consult with their unit’s legal counsel concerning the
requirements of the law in their country.
P R O D U C T I N T E G R I TY 17.1
In the U.S., the laws and regulations relating to adulteration and misbranding
are administered by the Food and Drug Administration. The other major U.S.
regulatory agencies and areas of regulation that affect our products in the U.S. are
summarized below:
Environmental Protection Agency/FIFRA

• As a general rule, a product that claims to kill germs on inanimate objects
requires registration with the Environmental Protection Agency under the
Federal Insecticide, Fungicide and Rodenticide Act (“FIFRA”). No sale of
such a product may be made until it is registered under FIFRA.
• Please refer to the “Colgate Palmolive Environmental, Occupational Health
& Safety Policy Statement” (Chapter 13) for information about other
environmental issues affecting Colgate.
Bureau of Alcohol, Tobacco and Firearms, Department of

Transportation, Consumer Products Safety Commission
• In the U.S., various Colgate products may fall within the jurisdiction of the
above referenced agencies. For example, a product containing alcohol may
be subject to the jurisdiction of the Bureau of Alcohol, Tobacco and Firearms
because of its alcohol ingredient or content. The same product may also be
subject to the Department of Transportation’s (“DOT”) Federal Hazardous
Substances Labeling Act since the DOT identifies some uses of alcohol as
yielding a hazardous product. Additionally, the Consumer Products Safety
Commission may have jurisdiction over some product attributes such as
tamper-evident packaging.
• Management is responsible for compliance with these Guidelines in

partnership with their unit’s legal counsel, the Corporate Legal Department
and the Global Product Safety Group.
should abstain from the activity in question until you have received the
necessary guidance.
Function.
17.2 P R O D U C T I N T E G R I TY
• The Company has instituted a telephone line for the Business Practices
Function to receive questions, comments and complaints about matters such
as the topic of these Guidelines. In the U.S., you may call 1-800-778-6080;
otherwise you may call 212-310-2330 collect.
appropriate action.
P R O D U C T I N T E G R I TY 17.3
Chapter 18
Disciplinary Actions
The Code of Conduct and the Business Practices Guidelines establish the policies
with which all Colgate people must comply. The Code of Conduct and the
Business Practices Guidelines are applicable to all Colgate people, including
officers, directors and agents of the Company and its subsidiaries. Vendors and
suppliers are also subject to these requirements as adherence to the Code is a
condition for conducting business with Colgate-Palmolive.
The Company’s policy is “zero tolerance” for any conduct that violates these
important business rules. Colgate people who violate the Code of Conduct or
Colgate Business Practices Guidelines are subject to disciplinary actions, up to
and including termination.
Similarly, suppliers or other business partners may be excluded from or lose

Colgate business due to their failure to comply with the Code of Conduct and
the Business Practices Guidelines.
D isciplina ry Actions 18.1

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Colgate-Palmolive

Business Practices Guidelines

2. Sarbanes-Oxley and Related Compliance Matters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1 - 2.7

3. Reporting Issues and Business Practices Investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1 - 3.2

4. Colgate-Palmolive Guidelines on Conflicts of Interest and Related Issues . . . . . . . . . . . . . 4.1 - 4.5

5. Colgate-Palmolive International Competition Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . 5.1 - 5.15

6. Colgate-Palmolive Guidelines on Company Documents . . . . . . . . . . . . . . . . . . . . . . . . . . 6.1 - 6.3

8. Colgate-Palmolive International Business Activities Guidelines . . . . . . . . . . . . . . . . . . . . . . 8.1 - 8.4

9. Colgate-Palmolive Guidelines on Business Relationships with

10. Colgate-Palmolive Guidelines

11. Colgate-Palmolive Guidelines on Preserving Company Proprietary

12. Colgate-Palmolive Guidelines on Securities Trading and

13. Colgate-Palmolive Environmental, Occupational Health & Safety

14. Colgate-Palmolive Product Safety Research Policy Statement . . . . . . . . . . . . . . . . . . . . 14.1 - 14.6

15. Colgate-Palmolive Advertising Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15.1 - 15.3

16. Colgate-Palmolive Advertising Placement Policy Statement . . . . . . . . . . . . . . . . . . . . . 16.1 - 16.3

17. Colgate-Palmolive Product Integrity Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17.1 - 17.3

18. Disciplinary Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18.1

Colgate-Palmolive published its first Code of Conduct in 1987. Since then,

Chapter 1 of the Business Practices Guidelines establishes the framework for

Successful working relationships are built on trust.

Communicate openly and honestly.

People are our greatest resource.

1.2 OUR ROLE IN SOCIETIES

OUR RELATIONSHIP WITH SOCIETY

The Company strives to be a contributing member of the global community. We

Colgate participates in local giving and volunteerism.

Our primary focus is on young people, particularly the education of young

Colgate is committed to universal human rights.

Colgate is committed to protecting life and property.

1.4 OUR ROLE IN SOCIETIES

• If you have a question about these Guidelines or their applicability to

Colgate’s corporate governance policies and programs, of which the Code of

For a more detailed description of Colgate’s corporate governance program, please

SUBSIDIARY/DIVISION QUARTERLY AND ANNUAL CERTIFICATIONS

S ar b anes- O xley 2.1

INTERNAL CONTROL OVER FINANCIAL REPORTING

Another Sarbanes-Oxley measure to restore confidence in the markets is the

To support management’s report regarding the effectiveness of Colgate’s internal

2.2 S a r b a nes - O xley

Corporate and Division management have received guidance regarding the

AUDIT COMMITTEE PRE-APPROVAL OF SERVICES TO BE

The Audit Committee must pre-approve all services to be provided by the

S ar b anes- O xley 2.3

PROHIBITION ON IMPROPER INFLUENCE OF AN AUDIT

2.4 S a r b a nes - O xley

PROHIBITION ON LOANS TO DIRECTORS OR OFFICERS

Colgate is strictly prohibited from, directly or indirectly, including through any

AUDIT COMMITTEE COMPLAINT PROCEDURES

Colgate people may direct concerns or questions relating to accounting,

Concerns relating to accounting, internal accounting controls, financial policy,

S ar b anes- O xley 2.5

RELATED PARTY TRANSACTIONS

To assist Colgate in complying with its SEC reporting requirements, a “Disclosure

QUESTIONS ABOUT GUIDELINES/REPORTS OF VIOLATIONS

• If you have a question about these Guidelines or their applicability to

2.6 S a r b a nes - O xley

S ar b anes- O xley 2.7

Global Business Practices investigates all potential violations of these Guidelines,

R E P O RT I N G I S S U E S & I N V E S T I GAT I O N S 3.1

Submissions may be made on an anonymous basis. The Company will endeavor

Global Business Practices

3.2 R E P O RT I N G I S S U E S & I N V E S T I GAT I O N S