Verification

Nutrien’s Supplier Code of Conduct (“Supplier Code”) communicates Nutrien’s requirements for suppliers of goods and services to Nutrien, whether directly or indirectly. It includes requirements related to human rights and labor in our supply chains, including prohibitions on illegal, forced, compulsory and child labor and human trafficking, along with requirements regarding health and safety, working conditions, wages, hours of work and others. The Supplier Code is available on our website at nutrien.com.

Nutrien undertakes risk assessment and due diligence activities to identify, assess and manage the risks of slavery in our supply chains, including indentured servitude, human trafficking, forced labor, forced marriage, debt bondage, child labor and deceptive recruiting for labor or services, as detailed in our Modern Slavery Report (“MSR”) available on our website at nutrien.com. These activities are conducted by Nutrien personnel, using internal processes and information from third-party risk data providers and publicly available sources where appropriate, and are not conducted by third-party verifiers.

Audits

Nutrien does not currently conduct a standalone supplier audit program specifically dedicated to evaluating supplier compliance with company standards for trafficking and slavery. Nutrien may review supplier compliance with the Supplier Code and applicable contractual requirements on a risk-based basis through its supplier due diligence, procurement and integrity processes. To the extent such reviews are conducted, they are not routinely independent, unannounced audits specifically for trafficking and slavery compliance.

Certification

Nutrien does not require every direct supplier to provide a separate standalone certification specifically stating that materials incorporated into Nutrien products comply with slavery and human trafficking laws in the countries where they do business. However, within certain Nutrien operating segments, our standard form supplier contract terms and conditions for the purchase of goods and services includes terms requiring our suppliers and their employees and subcontractors to conduct their operations pursuant to the contract in alignment with our Supplier Code, and we aim to maintain these provisions in final contracts and to include similar provisions in non-standard form contracts with our suppliers.

Where suppliers refuse to follow the principles of the Supplier Code or show signs that they are not committed to improving their practices to comply with its principles, Nutrien will review its relationship with the supplier. Where contractual commitments and applicable laws permit, this review may include termination of our relationship with the non-compliant supplier.

Internal Accountability

Nutrien’s Integrity Program (“Integrity Program”) provides the knowledge and tools for all employees to achieve business results the right way – with integrity. We have a dedicated Integrity Program page on our global intranet to ensure all employees have access to information and resources that allow employees to find the current policies that apply to their activities based on their role and location in the company.

Nutrien has a number of controls and processes in place to assess and address the risk of slavery in our supply chains and operations. Responsibility and accountability for risk management are embedded in all levels of our organization, and we strive to integrate risk management into key decision-making processes and strategies. By considering risk throughout our business, we seek to effectively manage the risks that could have an impact on our ability to deliver on our strategy. Additionally, our Code of Conduct (the "Code") describes our values and principles of business conduct, including our own high standards and fundamental respect for the rule of law, including human rights, and outlines our commitment to compliance with all applicable laws in any jurisdiction where we do business. For additional information, the Code is available on our website at nutrien.com.

Violations of our Code, related policies, or the law may result in disciplinary action, up to and including termination of employment. If the violation breaks the law, it could lead to civil or criminal legal proceedings. Violations involving slavery and human trafficking by employees are addressed through the Code of Conduct and related accountability, investigation, and disciplinary processes. Violations involving slavery and human trafficking by contractors are addressed through the standards and procedures set out in our Supplier Code and applicable contractual requirements. Failure by a contractor to meet these standards may result in a review of the relationship and termination of our relationship with the contractor, as described under Certification section above.

Nutrien also maintains reporting and investigation procedures to support accountability. Our confidential Integrity Helpline complements other methods of speaking up that enable employees and stakeholders to report any violations or suspected violations of the Code and other associated Nutrien policies, or any behavior that does not comply with applicable laws. The Integrity Helpline is available 24 hours a day, 365 days per year, and is administered by a third party. It is available to employees and external stakeholders, with the web address and telephone numbers posted on a number of platforms, including publicly available on Nutrien’s external website. The Code also clearly sets out our no-retaliation policy, which is designed to enable employees to raise good faith issues in a safe environment without fear of retaliation.

Training

All employees, directors and officers must complete mandatory Code training annually. We update and rotate our annual training topics from year to year as part of our risk-based training strategy. We also provide refresher training periodically to address new or changing legal and compliance risks.

Nutrien does not currently provide a separate mandatory training program specifically focused on human trafficking and slavery for employees and managers with direct responsibility for supply chain management.