The Company has a long-standing policy against making contributions to any political party or candidate, which is set forth in both the Code of Conduct and the Business Practices Guidelines. These documents prohibit contributions to any political party or candidate, whether Federal, state or local.

A recent stockholder proposal by Boston Common Asset Management raised the possibility that Company dues to trade associations in the United States might be used for contributions to political parties or candidates without the Company’s knowledge. To address this concern, the Company will annually provide the U.S. trade associations to which it belongs with the relevant language from its Code and Guidelines and emphasize that this absolutely prohibits use of Company dues or contributions for any expenditures in connection with participation or intervention in any political campaign on behalf of or in opposition to any candidate for public office (i.e. the type made non-deductible under Section 162(e)(1)(B) of the Internal Revenue Code).

In addition, Colgate will request annual reports from U.S. trade associations to which it pays dues or other payments in excess of $15,000 annually. The requested report will cover any political expenditures by the trade association that are not deductible pursuant to Section 162(e)(1) of the Internal Revenue Code, with a breakdown of any political expenditures by sub-section (A)-(D) of Section 162(e)(1). Colgate will report annually on this effort and its results to the Company’s Audit Committee, composed solely of independent directors, and will publish a summary of the report on its website.