What human-rights-related statistics has General Mills (GIS) disclosed?

For 2025, General Mills disclosed 673 audited sites and 109 significant incident analyses. As of February 2026, it reported incidents as 62% closed, 22% under a Corrective Action Plan, and 16% open, along with conducting an internal effectiveness assessment in 2024.

Investor group urges General Mills human rights review

Q: What does Proposal 7 at General Mills (GIS) request?

Proposal 7 requests a report assessing the effectiveness of General Mills’ existing human rights policies and due diligence processes, focusing on how well current controls address company-identified salient risks like forced labor and child labor, rather than asking for new policies or prescriptive actions.

Q: Why does the proponent consider human rights risks financially relevant for General Mills (GIS)?

The proponent notes that agricultural inputs are General Mills’ largest variable manufacturing cost and that the company itself acknowledges that suppliers’ practices can damage its reputation and that significant supply-chain problems can adversely impact its business, making human rights risk management financially relevant.

Filing Impact

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Form Type

PX14A6G

Rhea-AI Filing Summary

GENERAL MILLS INC (GIS) is the subject of an exempt solicitation by Friends Fiduciary Corporation supporting Proposal 7, which requests a report assessing the effectiveness of General Mills’ existing human rights policies and due diligence processes. The materials note that General Mills identifies forced labor and child labor as its most salient human rights issues and flags sugarcane as a higher-risk ingredient. Disclosed audit activity includes 673 audited sites, 109 significant incident analyses, and Corrective Action Plans in 2025, with 62% of incidents closed, 22% under a CAP, and 16% open as of February 2026, but the proponent argues these statistics do not show how effective controls are against salient risks or beyond Tier 1 suppliers. The solicitation compares General Mills’ disclosure with peers such as Nestlé, Unilever, and Mondelēz International, which are cited as providing more detailed coverage, outcomes, and remediation reporting, and contends that a focused effectiveness report would offer incremental, financially relevant, company-specific risk information at reasonable cost.

Filing Explained

This exempt solicitation advocates Proposal 7, which asks General Mills for a report assessing the effectiveness of its human-rights policies and due-diligence processes; it records a request rather than adoption or completion, so no immediate company-level policy or process change is disclosed.

Key Figures

Audited supplier sites in 2025: 673 sites Significant incident analyses in 2025: 109 incident analyses Incident status as of February 2026 – closed: 62% incidents closed +5 more

8 metrics

Audited supplier sites in 2025 673 sites Supplier audits conducted in 2025

Significant incident analyses in 2025 109 incident analyses Significant incidents reviewed in 2025

Incident status as of February 2026 – closed 62% incidents closed Portion of incidents reported closed

Incident status as of February 2026 – under CAP 22% incidents under a Corrective Action Plan Portion of incidents in active remediation

Incident status as of February 2026 – open 16% incidents open Portion of incidents still open

KnowTheChain Food and Beverage benchmark score – General Mills 19 Score out of 100 on forced labor benchmark

World Benchmarking Alliance human rights score – General Mills 68.8% Respect for human rights metric

Prioritized Tier 1 supplier sites audited – peer example 1,200+ sites Mondelez International prioritized Tier 1 sites audited in 2025

Key Terms

salient human rights issues, Tier 1 suppliers, Corrective Action Plan (CAP), KnowTheChain, +2 more

6 terms

salient human rights issues financial

"General Mills identifies forced labor and child labor as its most salient human"

Tier 1 suppliers financial

"achieving visibility beyond Tier 1 suppliers in regional commodity markets"

Tier 1 suppliers are companies that sell finished parts or systems directly to original manufacturers (the firms that sell the final product), acting like the lead contractors who deliver ready-to-install components. Investors care because these suppliers often have stable, large contracts, closer relationships and greater influence on product quality and delivery timing, so their performance can signal supply-chain health and affect the maker’s production and profitability.

Corrective Action Plan (CAP) financial

"673 audited sites, 109 significant incident analyses, and a Corrective Action Plan (CAP)"

KnowTheChain financial

"KnowTheChain Food and Beverage benchmark (of 100)"

World Benchmarking Alliance financial

"World Benchmarking Alliance: respect for human rights (of 100%)"

modern-slavery risk financial

"ingredient with a higher likelihood of modern-slavery risk"

FAQ

AI-generated questions and answers. How Rhea-AI works. Not financial advice.

What does Proposal 7 at General Mills (GIS) request?

Proposal 7 requests a report assessing the effectiveness of General Mills’ existing human rights policies and due diligence processes, focusing on how well current controls address company-identified salient risks like forced labor and child labor, rather than asking for new policies or prescriptive actions.

Why does the proponent consider human rights risks financially relevant for General Mills (GIS)?

The proponent notes that agricultural inputs are General Mills’ largest variable manufacturing cost and that the company itself acknowledges that suppliers’ practices can damage its reputation and that significant supply-chain problems can adversely impact its business, making human rights risk management financially relevant.

What concerns does the Proposal 7 proponent raise about current General Mills (GIS) disclosures?

The proponent states it is unclear whether significant incidents involve forced or child labor, how effectiveness is assessed beyond Tier 1 suppliers, whether remedy and recurrence prevention occur, and how the most serious risks are changing over time, despite existing aggregate audit data.

How is General Mills (GIS) compared to peers on human rights disclosure?

Citing benchmarks, the proponent notes General Mills scores 19 on the KnowTheChain Food and Beverage benchmark and 68.8% on the World Benchmarking Alliance human rights metric, compared with Nestlé (26, 96.9%), Unilever (47, 100%), and Mondelēz International (30, 71.9%), and highlights peers’ more detailed effectiveness and remediation reporting.

Why is sugarcane in India highlighted in the General Mills (GIS) exempt solicitation?

The materials reference U.S. Department of Labor and media reports of serious forced and child labor risks in Maharashtra’s sugarcane sector and note that General Mills has two Indian manufacturing operations in Maharashtra and a new plant, raising questions about how its due diligence manages these intersecting risks.

AI-generated analysis. How Rhea-AI works. Not financial advice.

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Available on EDGAR 09/01/2026 - 10:48 AM EDT Accepted by SEC EDGAR 09/01/2026 - 10:47 AM EDT

• NAME OF REGISTRANT: General Mills, Inc. • NAME OF PERSON RELYING ON EXEMPTION: Friends Fiduciary Corporation • ADDRESS OF PERSON RELYING ON EXEMPTION: 1700 Market Street, Suite 1535, Philadelphia, PA 19103

General Mills – Proposal 7: Assessing the Effectiveness of Human Rights Policies and Due Diligence August 28, 2026 (All references appear in the exempt solicitation ; sources cited on individual slides are new material not included there.) This is not a solicitation of authority to vote your proxy. Please DO NOT send us your proxy card as it will not be accepted.

Is General Mills Effectively Managing Salient Human Rights Risks? • Proposal 7 asks for a report assessing the effectiveness of existing policies and due - diligence processes. • General Mills identifies forced labor and child labor as its most salient human - rights issues. • The Company flags sugarcane as an ingredient with a higher likelihood of modern - slavery risk. • The report would provide meaningful incremental information on a financially relevant, company - specific risk. • The request leaves implementation to management, at reasonable cost and omitting proprietary information. 3 This is not a solicitation of authority to vote your proxy. Please DO NOT send us your proxy card as it will not be accepted.

Human Rights Risks in Agricultural Supply Chains are Financially Relevant for General Mills • Economically important sourcing: Agricultural inputs represent General Mills’ largest variable manufacturing cost. • Potential business consequences: General Mills recognizes suppliers' policies and practices can damage its reputation and that significant supply - chain problems can adversely impact its business. • Company - identified human - rights exposure: General Mills acknowledges structural challenges in achieving visibility beyond Tier 1 suppliers in regional commodity markets. • Potential value impact: Investors need to understand whether the relevant controls are effective. 4 This is not a solicitation of authority to vote your proxy. Please DO NOT send us your proxy card as it will not be accepted.

General Mills Reports Activity; But Investors Cannot See Effectiveness Against Salient Risks. What is visible: • 673 audited sites, 109 significant incident analyses, and a Corrective Action Plan (CAP) in 2025. • 62% incidents closed, 22% under a CAP, and 16% open as of February 2026. • Internal effectiveness assessment of its human - rights approach in 2024. What remains unclear: • Do significant incidents involve forced labor, child labor, or other salient risks? • How effectiveness is assessed where upstream visibility is limited, i.e. beyond Tier 1 suppliers? • Is remedy provided in response to violations? Does remediation prevent recurrence? • How are the most serious risks changing over time? Proposal 7 seeks insights from an effectiveness assessment that General Mills says it already performs. 5 This is not a solicitation of authority to vote your proxy. Please DO NOT send us your proxy card as it will not be accepted.

Sugarcane in India Illustrates Why the Effectiveness Disclosure Matters • The U.S. Department of Labor and media reporting document serious forced - and child - labor risks in Maharashtra's sugarcane sector in India. • India is a growth region: General Mills reported the country contributed to International segment sales in all four quarters of Fiscal 2026 according to earnings webcasts. • General Mills’ only two Indian manufacturing operations are in Maharashtra and a new plant will increase demand for local raw materials. • The proposal does not ask to solve systemic labor conditions in India. • How does General Mills determine whether its own due diligence and controls are effective where a known sector risk may intersect with its supply chain? Reference for earnings webcasts: First - quarter Fiscal 2026 Earnings Webcast, September 17, 2025 , Second - quarter Fiscal 2026 Earnings Webcast, December 17, 2025 , Third - quarter Fiscal 2026 Earnings Webcast, March 18, 2026 , Fourth - quarter Fiscal 2026 Earnings Webcast, July 1, 2026 6 This is not a solicitation of authority to vote your proxy. Please DO NOT send us your proxy card as it will not be accepted.

Effectiveness Disclosure Is Feasible and Non - Prescriptive: Peer Comparison Enhanced disclosure examples KnowTheChain review of engagement with affected supply chain workers on forced labor risks ( pg 43 of report ) KnowTheChain Food and Beverage benchmark (of 100) World Benchmarking Alliance: respect for human rights (of 100%) Company None identified No disclosure 19 68.8% General Mills Due - diligence coverage across key ingredients, significant human rights non - compliances and closures, supply - chain grievance outcomes, and child - labor due - diligence coverage for specific commodities. (https://www.nestle.com/sustainability/performance - reporting/non - financial - kpis) List of suppliers with country of origin for 14 key ingredients (including sugar ) Discloses efforts specific to recruitment 26 96.9% Nestlé Direct worker - survey findings, remediation of recruitment - fee issues, and measures to track the effectiveness and impact of its forced labor program. (https://www.unilever.com/files/unilever - modern - slavery - statement - march - 2026.pdf) Clearly disclosed 47 100% Unilever June 2026: ~99% of prioritized Tier 1 supplier sites completed third - party Sedex audits over the prior three years; 1,200+ prioritized Tier 1 sites audited in 2025; ~100% of Cocoa Life communities in West Africa covered by child - labor monitoring and remediation systems. (https://ir.mondelezinternational.com/news - releases/news - release - details/mondelez - international - scales - human - rights - due - diligence - across) Clearly disclosed 30 71.9% Mondelēz International 7 This is not a solicitation of authority to vote your proxy. Please DO NOT send us your proxy card as it will not be accepted.

Why Proposal 7 Warrants Support Agricultural sourcing is economically important to General Mills. Financial relevance Current disclosed aggregate audit statistics do not explain how General Mills determines whether due diligence is effective against its most salient risks. Incremental information General Mills identifies forced labor and child labor as salient human rights risks; sugarcane as higher - risk raw material. Company - specific exposure Recent disclosures are useful progress, but do not answer the specific effectiveness question. Existing response Other food and consumer companies provide more coverage - , outcome - , and remediation - related information. Peer feasibility The request is flexible, non - prescriptive, at reasonable cost, and excludes proprietary information. Scope and burden 8 This is not a solicitation of authority to vote your proxy. Please DO NOT send us your proxy card as it will not be accepted.

Source: View Original Filing on SEC EDGAR