Our Guiding Principles Cargill Code of Conduct

Our Guiding Principles

Cargill Code of Conduct Table of contents “ The policy on which our business has always been conducted is… our word is just as good Introduction as our bond.” A Message from our Resources...... 5 John MacMillan, Sr., 1923 Chief Executive Officer ...... 2 Good Decisions Through Cargill’s Guiding Principles...... 3 Discussion...... 6

About the Cargill Code ...... 4

Applying Our Guiding Principles

We Obey The Law ...... 8 We Treat People with Dignity

Obeying Applicable Laws and Respect...... 22 Third Parties and Legal Conduct Safety and Health Strength Through Diversity We Conduct Our Business Alcohol and Drugs with Integrity...... 10 Harassment and Violence Employee Data Privacy Anti-Bribery Business Gifts and Entertainment We Protect Cargill’s Information, Fair Competition Third Party Intellectual Property Assets and Interests...... 26 Trade Sanctions Cargill Property and Resources Derivatives Transactions Cargill Intellectual Assets Insider Trading We Keep Accurate and Conflicts of Interest Honest Records...... 16 We Are Committed to Being a Creating and Managing Business Records Responsible Global Citizen...... 30 Financial Statements and Controls Human Rights Environmental Standards We Honor Our Business Food and Feed Safety Obligations...... 18 Political Activity Enriched Communities Trust in Business Relationships Government Contracting

Cargill’s guiding principles 1 A message from our Chief Executive Officer Guiding Principles

Dear colleagues:

I believe that the work we do every day is more than just a job – it’s a way for us to 1 We obey the law. make a meaningful contribution to society, form relationships with our colleagues and 2 We conduct our learn on a daily basis. It’s also a way for us business with integrity. to demonstrate that a company can grow and prosper while adhering to a strong set of 3 We keep accurate ethical beliefs. and honest records. We know our employees and owners care deeply about the way we conduct our business and it’s also become increasingly important to our customers and the communities where 4 We honor our we operate. That’s why we have set our sights on becoming the most ethical and trusted business obligations. source of sustainable products and services. Not only is it the right thing to do, but it’s also good business, serving to differentiate Cargill and prompt customers to choose us 5 We treat people with more often. dignity and respect. In a world that’s changing every day, we realize the importance of having a shared definition of what it means to be the most ethical and responsible provider. That’s why 6 We protect Cargill’s we have our Code of Conduct, which is a combination of our Guiding Principles and the information, assets compliance policies that support them. Be sure to review it and think about how it applies and interests. to your work within Cargill. If you’re unsure, talk to your manager or a colleague. Through discussion, we are able to see things from different perspectives and ultimately make 7 We are committed to more informed decisions. being a responsible Thank you for the care and thoughtfulness that you bring to help Cargill be the most global citizen. trusted partner. It’s a goal that we can only make happen together!

Sincerely,

David W. MacLennan President and CEO

2 A message from our President and CEO Cargill’s guiding principles 3 About the Cargill Code Resources

Why do we have Cargill’s Code of Conduct outlines our shared ethical standards What should Even companies with a long history of doing the right thing a Code? for conducting business throughout the world and serves as I do if I learn experience misconduct, and we are no exception. a guide when you have questions or face dilemmas where the about right choice is not clear. Reporting misconduct takes courage, but it’s the right thing or suspect to do. Cargill will not tolerate retaliation against anyone who, in The Code is grounded in our 7 Guiding Principles—the foundation misconduct? good faith, raises a concern or participates in an investigation. that supports all of Cargill’s corporate activity, along with our Employees who intentionally make false accusations or provide individual actions and decisions as Cargill employees. It also false information may face disciplinary action. summarizes key compliance policies, highlighting issues that can have significant legal and ethical consequences if handled We take all reports of potential misconduct seriously and handle improperly and providing guidelines for appropriate action. them promptly, fairly and as confidentially as possible.

Where should Start by talking to your manager. If you’re not comfortable doing so, Who must follow Our Code applies to all employees of Cargill and its affiliated or if your manager doesn’t properly address the situation, reach out companies worldwide. It also applies to the members of our I start? our Code? to any of the following people: board of directors when acting on behalf of Cargill. • Talk to your Human Resources Manager • Talk to your Business or Function Leader What does the As employees of Cargill, we are each accountable for following • Contact the Law Department • Contact the Global Ethics and Compliance Office (GECO) our Code and exercising good judgment consistent with it. We Code require at [email protected] are also responsible for reporting Code violations that we learn from me? about or experience. Employees who fail to comply with our You can also call or send a message to Cargill’s Ethics Open Line Code—including those who fail to report Code violations—may (subject to certain countries’ legal limitations). It’s available 24 hours face disciplinary action, up to and including termination. a day, 7 days a week for employees anywhere in the world.

What does Managers set the tone for their teams, and they are often the first place employees turn with questions. As a result, they are Ethics Open Line the Code expected to: require from • Set a strong example of ethical conduct. To call the Ethics Open Line: managers? • Provide training, education and resources to support • Inside the United States, dial 1-800-357-OPEN (6736). employees in complying with the Code and underlying policies. • Outside the United States, go to the Ethics Open Line website to find the • Encourage employees to speak up if they have questions specific phone number for your country. Or, dial your direct access code or concerns. for your country, followed by 1-800-357-OPEN (6736). • Watch for and appropriately address misconduct in their teams. To send a message to the Ethics Open Line:

Access www.cargillopenline.com from any computer with Internet access.

4 About the Cargill code Resources 5 Good decisions through discussion

The Code can provide practical guidance for many situations. But no single Would I be proud to tell document can anticipate every situation or outline every requirement. Most importantly, our Code is never a substitute for common sense and good a colleague I admire? judgment. If you don’t find the answer you need in the Code, stop and think about your proposed course of action. Discuss it with your manager or a colleague or contact the Ethics Open Line.

Does it show respect for Is it legal? our employees, shareholders, Ask... customers, and communities? Talk about it.

Is it consistent with our Guiding Principles and policies? If it appeared in the news, would it reflect well on Cargill?

“ Doing the right thing is clearly embedded Cargill’s culture. We all can support this culture through thoughtful decision- making and building a strong compliance foundation that equals our ethical spirit. Together, our ethics and compliance define us, and will be a key factor in our vision to become the most trusted partner in agriculture, food and nutrition.”

Anna Richo General Counsel and Chief Compliance Officer

6 Good decisions through discussion 7 Obeying Applicable Laws

Cargill conducts business globally and our employees are citizens of many countries. As a result, our business activities are subject to the laws of many different jurisdictions. Some laws extend beyond a specific country’s borders. For instance, Q&A certain U.S. laws concerning imports and exports, bribery and trade sanctions apply My business recently pur- 1 We obey the law. not only to our U.S. operations, but to our Q chased goods from a seller located in country “x.” The seller operations around the globe. We are each called and asked if we could pay for responsible for following all of the laws that the goods by wiring funds to a third apply to our businesses. At times, you may party’s bank account in country “z.” encounter a conflict between various laws I’ve never heard of the third party that apply to our business activities. If you and country “z” doesn’t seem like a logical location for the customer or encounter a conflict or have any concerns the transaction. Am I right to be con- about whether something is legal, contact cerned? the Law Department for guidance.

Yes. The seller’s request to pay an Third Parties A unrelated third party in a country other than the seller’s principal place of and Legal Conduct business is concerning since the seller may be using Cargill to assist it with Assisting a third party to engage in illegal breaking the law. For example, the seller activities can damage our reputation and may be using the unrelated third party result in serious legal consequences for and bank account in country “z” to avoid both you and Cargill, including charges tax requirements or launder money. You should tell the seller that our policy that we aided or conspired with the third is to pay sellers directly into their bank party. In addition to obeying the laws that account in the country of their principal apply directly to us, we cannot take ac- place of business. If the customer does tions which we know, or ought to know, not accept your answer, discuss the will assist a third party in violating the law. situation with your manager and seek guidance from your finance or business We are each responsible for recognizing Obeying the law is the foundation on which our reputation and leader. signs that indicate third parties are en- Guiding Principles are built. As a global organization privileged gaging in potentially illegal activities and to do business all over the world, we have the responsibility to using Cargill to assist them. If you have any concerns that a third party with whom comply with all of the laws that apply to our businesses. you are doing business might be using Cargill to assist it in violating the law, resolve your concerns before proceeding with the transaction.

8 We obey the law 9 Anti-Bribery

Cargill does not offer or accept bribes, kickbacks or other corrupt payments, regardless of local practice or perceived Are facilitation customs. Bribery is illegal in most places payments okay? where we do business, and it can cripple We conduct A facilitation payment is a small sum Cargill’s long-standing reputation of con- of money paid to a government official our business ducting business with integrity. in order to expedite routine and non- discretionary activities, such as obtain- 2 with integrity. A bribe is giving or offering to give some- ing a visa or work order. Facilitation thing of value to someone in exchange for payments are illegal under the laws of getting or keeping business or for any many countries. In very limited situations, it may be permissible to make a other business advantage. Never directly facilitation payment. Consult with the or indirectly offer, give, solicit, or accept Law Department before making the any form of bribe, kickback or other payment to ensure it is legal, custom- corrupt payment. Select third parties who ary and reasonable under local act on our behalf carefully (e.g., sales standards. You must also properly report the payment and record it in agents, representatives, consultants and company records. distributors). Do not allow such third parties or our joint venture partners to offer or accept a bribe, as you and Cargill may be held responsible for their actions.

Dealing with Government Officials:The anti-corruption rules that apply to our Who are dealings with government officials are Government Officials? especially strict. Under the U.S. Foreign Corrupt Practices Act (FCPA), it is a crime • Employees of government agencies— to offer or give anything of value, either for instance, tax and customs inspectors and police officers directly or indirectly, to a government official in order to improperly influence the • Employees of government-owned or official. The FCPA, along with many other government-controlled companies or public international organizations We take pride in conducting our business with integrity. We similar laws, can apply to all of Cargill, our employees and third parties acting • Political parties, officials, candidates compete vigorously, but do so fairly and ethically. We do not offer on our behalf around the world. If you and office holders or accept bribes or inappropriate gifts and we comply with the interact with government officials, you laws and regulations that support fair competition and integrity in must understand and strictly follow all anti-corruption laws. the marketplace.

10 We conduct our business with integrity 11 Business Gifts Fair Competition and Entertainment Competition laws, known as “antitrust” careful when interacting with competi- Used correctly, gifts and entertainment carry value for the recipient, it’s important laws in the United States, help foster and tors—for instance, in connection with trade can promote goodwill and reinforce strong to consider them carefully and avoid preserve fair and honest competition in associations and benchmarking. business relationships. In some cultures, situations in which they might diminish—or the market place. Another way of preserving fair and honest gifts may be customary and expected. appear to diminish—your objectivity or Conducting business in compliance with competition involves the proper collection However, because gifts and entertainment someone else’s. these laws has contributed to Cargill’s and use of competitive intelligence. Gath- growth and prosperity throughout the ering competitive information and busi- years. While these laws are complex and ness data is an appropriate business prac- Follow these requirements can vary from country to country, they tice, but it must be done legally and generally prohibit competitors from work- ethically. It is never acceptable to engage ing together to limit competition. They also in fraud, misrepresentation, trespassing or Always follow your location’s gifts and entertainment policy . prohibit improper attempts to monopolize other illegal or unethical methods to In addition: markets or control prices. obtain competitive intelligence.

Do not give or accept any gift or entertainment where it All employees are expected to follow com- For additional guidance, see Cargill’s could cause—or give the appearance of causing—Cargill petition laws, as well as Cargill’s own com- Competition Policy and the Principles of to grant or receive any favor in return. petition policy. Employees must also be Competition Law Guide.

Do not give or receive extravagant gifts or entertainment. The value of all gifts and entertainment should be reasonable and modest. Competition Do’s and Don’ts Avoid gifts or entertainment that coincide with purchasing, sales or trading decisions, since these could appear to improperly influence the decisions. Do: Don’t:

Do not give or accept cash or cash equivalents such as Compete vigorously, but legally. Discuss prices, sales plans or gift cards, gift certificates or vouchers with denominated volumes with competitors. spending amounts. Win based on our merits. Divide customers, markets or If you interact with the government, understand the laws and Recognize competition laws are territories with competitors. regulations for dealing with government officials. These laws complex. Seek help when in doubt. and regulations vary from place to place and are often stricter Agree with others to limit production than the rules that apply to commercial counterparties. Even or not do business with customers or suppliers. simple offers such as buying lunch for a government official may be unacceptable or against the law in some situations.

For additional guidance, contact the GECO via the [email protected] inbox.

12 We conduct our business with integrity 13 Third Party Derivatives Transactions Intellectual Property Cargill enters into derivative transactions, These transactions are entered into on We respect the intellectual property rights Some sanctions impose a complete ban including futures, swaps and options, organized exchanges, as well as bilaterally of individuals and companies outside of on all transactions, while others may ban throughout the world. with counterparties. Cargill and will not attempt to obtain their a specific type of transaction, such as confidential information, or otherwise use trading in specific goods or providing par- their intellectual property, inappropriately. ticular services. Follow these requirements

Intellectual property includes trademarks, Cargill does not do business with any copyrights, patents and trade secrets. In sanctioned country, organization or indi- If you enter derivative transactions on Cargill’s behalf: some contexts, trade secrets are also vidual, unless permitted by law. If you are known as confidential information or involved in international business transac- Understand and comply with all regulations and exchange know-how. tions, you must be familiar with and com- rules that apply. ply with applicable trade sanctions. If you If you discover you have received confi- are considering business with a sanc- Do not engage in fraudulent activities in connection with dential information that doesn’t belong to tioned country, organization or individual, any derivative transaction or take actions to manipulate the market price of any derivative instrument in violation of rules Cargill, or may be using another’s intellec- consult with the Law Department first. tual property without having the rights to and regulations. do so, contact the Law Department Keep in mind that trade sanction laws can Do not make false reports or misleading statements to for assistance. be very complex and change frequently, government regulators or exchanges. so a transaction that was allowed in the Additionally, when a customer or other past might not be allowed now. Coordinate all contact with government regulators and party entrusts us with its intellectual prop- exchanges concerning questions on regulations or rules erty, you must comply with all contractual Anti-Boycott Laws: U.S. law prohibits all with Cargill’s Derivatives Compliance Group. commitments and restrictions regarding of Cargill from participating or cooperating its use. with boycotts that are not supported by the U.S. government and requires us to report boycott-related requests we receive. Trade Sanctions Cargill’s Commodity Markets Compliance Group (CMCG) provides detailed information You must be familiar with and follow these and resources on the subject of derivatives within their Commodity Trading Resource Various countries and organizations, such laws. Inform the law department or your Room site on Cargill Connects. You also can send an email to as the United Nations, have imposed trade local boycott reporting contact immedi- [email protected] for general information requests. sanctions against certain countries, orga- ately if you receive any request to partici- nizations and individuals, many of which pate or cooperate in a boycott not sup- apply to transactions beyond the borders ported by the United States. of the country imposing them.

14 We conduct our business with integrity 15 Creating and Managing Business Records Q&A

Every day, we create thousands of business A customer asked us to change records, from customer contracts and re- Q an invoice to make it look like ports for regulatory agencies to timesheets the sale took place on an earlier date than it actually did. Apparently, its and expense reports. At times, our email and import permit recently expired, and telephone communications are even consid- changing the sales date will help it We keep accurate ered business records. Cargill counts on avoid having to reapply for the per- their accuracy and truth to analyze and re- mit. The change is easy to make and 3 and honest records. port on our operations and to make sound it will really help our customer. Can I business decisions. There’s also a chance go ahead and make the change? any business record will be made public No, you can’t. It does not matter if through litigation, government investigations A the change is easy to make and it or a story in the media. will help the customer. Our invoices are business records and should reflect the For these reasons, all business records we actual date on which the sale took place. create, in whatever form, must reflect the true Changing the date on the invoice would create a false and misleading record—a nature of transactions and events. Never de- violation of our obligation to keep accu- liberately falsify a record or try to disguise rate and honest records. Also, since the what really happened and avoid exaggera- customer is making the change to avoid tion, colorful language and legal conclusions a legal requirement, your actions would in your communications. assist it in breaking the law.

It’s also important you hold onto or dispose of business records in keeping with our re- U.S. Generally Accepted Accounting Princi- cords retention schedules. If there is a law- ples (GAAP) for Cargill’s consolidated finan- suit or government investigation, you may be cial statements and local accounting rules required to retain certain documents for a for Cargill’s non-U.S. financial reporting re- period of time, so be sure to follow any in- quirements. We prepare and file our tax re- structions you receive in such an event. turns and other filings in accordance with all tax laws. Any employee who supplies information for financial or tax purposes must Financial Statements provide it in a timely manner and certify both Accurate and honest records are critical to making sound and Controls the accuracy of the information and their compliance with Cargill policies. Failure to business decisions and maintaining the integrity of our Our financial information is relied upon by provide timely and accurate information to financial reporting. Our business information, in whatever our management team, shareholders, credi- Corporate Financial Reporting or the Tax tors, rating agencies and counterparties. It’s Department can result in significant legal form, must reflect the true nature of our transactions. also used when preparing government re- and commercial risk for Cargill. For addition- turns and reports for tax, regulatory and sta- al guidance, contact the Tax Department for tistical purposes. When compiling and shar- tax-related questions and Corporate Finan- ing our financial information, we comply with cial Reporting for finance-related questions.

16 We keep accurate and honest records 17 Trust in Business Relationships Honoring our business obligations goes Q&A beyond just meeting our contractual responsibilities. We want to demonstrate that I’m in the final stages of signing We honor we approach our business relationships Q a contract with a customer, and with customers, suppliers, vendors, con- its most recent terms include product our business sultants, other business partners and one specifications that are a little different than what we actually offer. However, another from a standpoint of mutual trust. obligations. our product is functionally equivalent 4 and I am confident it will work well This means we: for the customer’s application. Time is running short and I need to get the Communicate honestly about our prod- contract signed soon. But I don’t feel ucts and services—in our conversations, right about agreeing to these prod- contracts, sales materials, emails and all uct specifications, knowing that the product we’ll supply does not meet other communications. them. What should I do?

Make only those commitments we We must supply product meet- can stand behind. A commitment means A ing the specifications provided in any promise—not just those that are cap- the contract. If we do not, we may be tured in our contracts. Be thoughtful about supplying false information or breach- ing the contract. It also conflicts with our your promises and don’t commit to some- guiding principle of honoring our busi- thing that Cargill can’t deliver. ness obligations, which includes being honest with our customers. You’ll need Handle changes to commitments re- to make sure the correct specifications sponsibly. Sometimes we won’t be able are included—even if that means that the to meet a commitment that we have made. contracting process takes a little longer. In this case, work with the affected customer or business partner to find a solu- tion and discuss appropriate next steps. Treat personal data about our cus- Make sure you properly amend or termi- tomers and other business partners nate existing contracts if needed. with care. In the course of business, we may collect, hold or process information Our business relationships are grounded in mutual trust, and Respect and protect the confidentiality about people who represent our custom- have been throughout Cargill’s history. We build and maintain and ownership rights of intellectual prop- ers’ and other business partners’ organi- the trust and confidence of our customers and other business erty entrusted to us. We should protect zations. If you handle such information, our customers’ and other business part- make sure it is protected and used lawfully partners by communicating honestly, respecting information ners’ intellectual property as diligently as and properly. For additional guidance, see entrusted to us and standing behind our commitments. we protect our own. Cargill’s Data Privacy for Business Infor- mation Policy.

18 We honor our business obligations 19 Protect customers and the market- nity to purchase products and services in Government Contracting place by complying with the requirements a fair manner. For additional guidance, see of the competition laws. These laws en- Cargill’s Competition Policy and the Prin- When we conduct business with govern- If you work on government contracts, courage free and open competition and ciples of Competition Law Guide. ment entities, including national, state, make sure you fully understand the special help ensure customers have an opportu- provincial and local governments, the legal legal rules and contract terms that apply to rules and contractual requirements that that customer relationship. Know which apply can be much stricter than the rules contract requirements apply to third par- Applying the Code for commercial customers. ties, like consultants, resellers, distributors or suppliers, and make sure the third party For instance, we may be prohibited from is aware of the requirements and can What does it mean to demonstrate trust in business relationships? offering any gifts to government officials, Here are some examples: meet them. even gifts of minimal value. Or we may be A product line manager realizes that Cargill will be unable to required to disclose detailed information deliver under the terms of a supply contract due to major flooding about our company and shareholders. at the plant where the product is produced. He works with his Still other government contracts regulate team and the Law Department to determine options for the basic sales-related communications with customer. He also reaches out to the customer to let them know government officials. about the situation and discuss next steps.

An account owner is having a telephone conversation with a customer when he realizes that the customer expects a quicker delivery timeline than what is probably possible. He explains that & he will need to work with the shipping team to put together a Q A delivery schedule. In this way, he avoids making commitments Our business is preparing a bid Not yet. Many times, government that he knows Cargill can’t meet. Q for a big government contract. A contracts require us to make cer- The request for proposal requires us tifications on behalf of the entire Cargill A plant engineer receives confidential technical information from to certify that we have not been sub- organization—not just your business. a supplier of engineering services to use in a capital project. She ject to any government investigations makes sure she understands her confidentiality obligations and over the past three years. You should work with the Law Depart- notifies her team that the information cannot be shared with any ment to determine what certifications we other party or used outside of this project. She also makes sure I know our business hasn’t been the can make. Making inaccurate certifica- subject of any investigations so can I it is marked as “supplier confidential” and safeguarded against tions may not only result in serious legal make the certification? consequences for you and the com- unauthorized access or sharing. pany, but also affect Cargill’s ability to contract with government customers in A sales representative receives an email from a prospect. the future. Reading it closely, she realizes that the prospect had intended to write to a competitor—and that the email contains information about the competitor’s pricing. The sales representative notifies her manager and the Law Department so that Cargill can handle the situation appropriately, including letting the sender know about his mistake. She does not forward the email, nor does she use the information in it.

20 We honor our business obligations 21 Safety and Health

ZERO. At Cargill, we believe all jobs can be For additional guidance, see Cargill’s Envi- done safely, and that zero injuries and fa- ronment, Health and Safety policy and talities are possible. Ensuring everyone re- corporate procedure manual. turns home safely from work every day is We treat people core to our operations. This requires an unwavering commitment from leaders, & with dignity employees and contractors who come to Q A work at Cargill. and respect. I work on the production floor. 5 Q The other day, a machine I was To help us do this, we operating became jammed. I remem- bered our safety procedures and • comply with all health and safety found a maintenance mechanic au- laws in addition to our own strict thorized to lock and tag the machine programs and safety requirements, which often go beyond the require- out (LOTO) when it breaks down or ments of the law; jams. This delay caused our production line to back up. I think I could • continuously improve our safety have cleared the jam myself in just a performance through learning from few minutes. Did I do the right thing, others, both inside and outside our or should I have stopped the machine organization, establishing aggressive and cleared the jam myself? goals and recognizing people for improving safety processes; and You did the right thing, even if the • insist on a culture that requires all A line needed to be shut down. Our work, however urgent, be done safety procedures require machines to safely. be locked and tagged out before they can be cleared or serviced, and only All employees are responsible for following employees trained and authorized to health and safety laws and company re- perform LOTO are allowed to do this. quirements that apply to their jobs. Em- While finding the right person and shut- ployees must also take precautions to pro- ting down the line may take some time, tect themselves, their fellow employees this requirement is in place for your safety and the safety of your coworkers. and visitors to our facilities and report any incidents or unsafe practices they witness to their manager. Cargill managers must We achieve our goals through our people. We provide a safe provide people with training, programs workplace and value the unique contributions of our global team, and resources to do their jobs safely and design and maintain our processes and enabling those who support Cargill’s goals to achieve their own facilities in a manner that ensures safe individual potential. working conditions.

22 We treat people with dignity and respect 23 Strength Through Diversity Alcohol and Drugs & Did you know? Cargill embraces the variety of back- Q A The misuse of drugs, alcohol and other grounds and life experiences our employ- I applied for an internal position Examples of Sexual Harassment controlled substances can threaten the ees bring to work. As colleagues, we offer and believe that someone less safety, health and productivity of our em- Q • Promises of special treatment for the perspectives of different genders, lan- qualified was chosen. I suspect I was ployees. Any employee reporting for work submitting to sexual conduct guages, local customs, physical abilities, not chosen due to my gender. Who must be free from the influence of illegal can I talk to? • Subjecting an employee to unwel- races, religions, sexual orientations, gen- drugs and alcohol. We also prohibit the come sexual attention or conduct der identities, life experiences and socio- possession or consumption of illegal drugs Employment decisions must be • Intentional physical contact which economic statuses, and we vary in our during work hours and at Cargill locations. A made based on skills, experience is sexual in nature personal styles of thinking, expressing and abilities—not gender or other dis- While alcoholic beverages may be served • Sexually oriented gestures, jokes ourselves and problem-solving. criminatory factors. If you are concerned at company-approved social functions, or comments directed at or made that your gender played a role in the de- this should be done only in accordance cision, you can talk to the hiring manager in the presence of an individual who To be successful as a global organization, with our drug and alcohol policies. If you or your HR manager. If you are not com- does not welcome such conduct each of us has to demonstrate respect for fortable discussing the situation with • Sexual or discriminatory displays are taking prescription medication that im- those who are different from us. This in- them, you can always contact the Ethics or publications anywhere in Cargill’s pairs your ability to work or poses a threat cludes recognizing that our own way of Open Line. workplace to safety, we encourage you to discuss the thinking is not the only way, and that situation with Human Resources or your when diverse backgrounds lead to diverse manager. Managers are further responsi- viewpoints, this is not a weakness. In fact, Harassment and Violence ble for providing people with the education our differences make us stronger and they need on Cargill’s alcohol and drugs better able to serve the needs of our We all have a right to work in an environ- If you witness or learn about harassment, policies and procedures. global organization. ment that’s free from violence or harass- violence or threats of violence, you should ment. At Cargill, we will not tolerate: report it immediately either to a manager, a For additional guidance, see Cargill’s alco- We provide equal opportunities in employ- human resource professional or submit- hol and drug policy for your location. • Harassment in any form ment to all employees without regard to ting a report using MyHR or the Ethics personal characteristics, such as race, • The use of physical force intended to Open Line. ethnicity, color, gender, age, disability or cause bodily harm Employee Data Privacy other characteristics protected by law. Managers are responsible for maintaining In the course of business, we may collect, Illegal discrimination and retaliation against • Acts or threats that are intended to a work environment that’s free of violence intimidate someone or cause them to hold or process personal information anyone for either sharing a concern or par- and unlawful harassment, which includes fear bodily harm about employees and others in an em- ticipating in an investigation have no place acting promptly to investigate all allega- ployment context. We treat such personal in the Cargill organization. This applies to tions in accordance with our laws and pol- This applies to the way we treat each other information with care and take responsibil- the way we treat each other, along with icies. For additional guidance, see Cargill’s and anyone else we interact with. Each of ity for protecting it and using it lawfully anyone else we interact with. violence and harassment policies for your us is responsible for conducting ourselves and properly. in a manner consistent with our harass- location. For additional guidance, see Cargill’s ment and violence policies. For additional guidance, see Cargill’s Em- Global Diversity and Inclusion Policy and ployee Data and HR Technology Stan- the anti-discrimination/equal employment dards Policy. opportunity policies at your location.

24 We treat people with dignity and respect 25 Cargill Property and Resources

Each of us is responsible for safeguarding materials and equipment, as well as our company property and resources made communication systems, such as our available to us in the course of our jobs. computers, Internet service, telephones We protect Cargill’s Our property and resources include both and email. information, assets our physical assets, such as our facilities, 6 and interests. Follow these requirements

We are all responsible for using Cargill’s property and resources responsibly .

Use facilities, materials, equipment and other physical assets, including corporate credit cards, only for authorized purposes that are related to your job responsibilities.

Never take part in any action that involves fraud, theft, misappropriation, embezzlement or similar illegal activities. Cargill takes these and other crimes seriously and will pursue prosecutions vigorously. To report a crime, contact your manager, the Global Security Department or the Ethics Open Line.

Use email, Internet, phone and other Cargill communication systems for business purposes—keep personal use to a minimum. Never use our systems in ways that could be perceived as illegal, harassing or offensive, or that could reflect poorly on Cargill. This applies any time you use Cargill equipment, both during and outside of working hours and while at work or at a remote location.

We count on one another to act as stewards of the organization. When you communicate about Cargill or matters that directly affect Cargill—whether through texting, email, instant mes- To preserve the value of Cargill, we protect the information saging, social networking or the Internet—follow our Guiding and assets entrusted to us and avoid situations that may let Principles and all company policies. personal interests influence our business judgment. For additional guidance, see Cargill’s Fraud, Theft and Misappropriation Policy and Cargill’s Electronic Communications Policy.

26 We protect Cargill’s information, assets and interests 27 Cargill Intellectual Assets Insider Trading Conflicts of Interest

Some of Cargill’s most valuable assets in- Cargill strictly prohibits all employees from: We must all avoid conflict of interest clude our confidential business and tech- situations where our personal interests • Trading on “material nonpublic nical information and other intellectual could inappropriately influence our busi- & information” about companies with Q A property like patents, copyrights and publicly traded securities (including ness judgment. trademarks. debt securities) and I’d like to pursue my own Examples of situations in which a conflict • Communicating “material nonpublic Q business venture. I’m confident To protect Cargill’s confidential informa- information” to others in violation of could exist include: it won’t compete or conflict with tion, never disclose it to anyone outside the law. Cargill’s interests. Can I do it? • Accepting outside employment that is the company unless you have explicit ap- inconsistent with Cargill’s interests—for Maybe. Even though you believe proval and it’s covered by a non-disclosure This conduct, commonly referred to as instance, working for a competitor or the business venture will not “insider trading,” is illegal in most places A agreement, if appropriate. Even inside of starting your own line of business that compete with Cargill, you should still and can result in severe penalties for both competes with Cargill Cargill, do not share such information un- discuss the potential venture with your less the person has a business need to you and Cargill, even if you do not person- • Allowing a personal relationship to manager to make sure that’s the case. know it. ally benefit from the violation. influence a business decision—for Your manager will also want to make instance, hiring a family member as an sure the potential venture won’t take employee or a vendor If you create or invent things as part of Information is considered “material” if away from your work time here at Cargill. your job, make sure you understand how there is a substantial likelihood that a rea- • Discovering a potential business opportunity for Cargill during your job and to protect the intellectual property that re- sonable investor would consider it impor- using it for your own gain sults from your work. For instance, you tant in making an investment decision, or • Accepting gifts or entertainment that may need to keep certain records, report the information would likely have a sub- affect—or could appear to affect— stantial effect on the price of a company’s Did you know? the development of innovations or assist your business objectivity with obtaining patents on behalf of Cargill. securities. • Having authority over or a reporting • Before accepting a for-profit board For additional guidance, see Cargill’s arrangement (either direct or indirect) position, you must obtain approval with another employee with whom you from both your manager and the Copyright, Patent and Trademark Polices Did you know? have a personal (familial, romantic or Global Ethics & Compliance Office. along with Cargill’s Confidential Informa- intimate) relationship. Approval request forms can be tion Policy. found on the Ethics & Compliance Examples of information you may It’s not always clear whether an activity page through Cargill Connects and learn about at Cargill that could creates a conflict of interest. For this rea- submitted to [email protected]. be considered “material” include: son, you should discuss any potential con- • You are not allowed to trade for your • Merger, acquisition or divestiture flicts with your manager. own account any swaps, futures, proposals or agreements options, or similar instruments For additional guidance, see Cargill’s related to commodities in which • New product development Cargill trades, other than for Conflicts of Interest Policy. • Major litigation legitimate hedging operations for personal business activities and • Sensitive information that is covered after obtaining approval from your by a confidentiality agreement business or function leader.

28 We protect Cargill’s information, assets and interests 29 Human Rights & As part of the global community, we rec- Q A ognize the important role we play in help- I’ve just done an audit of the We are committed ing to address some of the world’s most Q environmental permits that apply significant challenges. We partner with to various processes at our facility. to being a governments and social welfare organiza- We’re in compliance with most of them. However, one permit has expired tions to address concerns related to hu- and another has limits that we won’t responsible man rights, including forced labor, human be able to meet. Shutting down these trafficking and other illegal practices. processes would shut down the plant, 7 global citizen. which would hurt our business. What We respect human rights and support should I do? global efforts to protect them, including: Every Cargill facility is required to have necessary permits and to • Following all employment laws and A operate in compliance with them. If regulations, including rules about the employment of minors, and support- we are out of compliance with one or ing equal rights and the elimination of more permits, you must notify your plant discrimination in employment. management immediately. Your plant management will work with our environ- • Paying regular and competitive mental managers to promptly return wages and appropriate benefits, the facility to full compliance, obtain and investing in resources to assist regulatory permission to continue opera- employees who want to develop to tions until compliance is achieved or their full potential. curtail operations. • Maintaining our employees’ rights to freedom of association and collective bargaining. Before making changes to our businesses or operations—such as buying a plant or • Striving to ensure that child labor and illegal, abusive or forced labor undertaking a capital project—we evaluate have no place within our operations the environmental impact and obtain all or our supply chains, anywhere in necessary permits and approvals. the world. All Cargill employees must follow the envi- Environmental Standards ronmental laws and company requirements that apply to their jobs and report any envi- We strive to reduce the environmental ronmental incidents and violations. Our The breadth of our operations means that Cargill touches impact of our global operations and help managers must make sure employees have almost every aspect of society. With our global reach comes conserve natural resources. We comply the training and resources to help meet the responsibility to understand and manage our impact. with all environmental laws and our own these responsibilities. strict requirements and continuously im- We support the protection of human rights, maintain strict prove our performance through waste min- For additional guidance, see Cargill’s environmental and food safety standards within our operations imization, efficient resource use and other Environment, Health and Safety policy and and share our global knowledge and experience to help meet measures relevant to our businesses. corporate procedure manual. economic and social challenges.

30 We are committed to being a responsible global citizen 31 and processes they work with meet our Enriched Communities Q&A food and feed safety requirements and for informing their manager if they see a We apply our knowledge and expertise to of our commitment to being a responsible global citizen and to that end, we hold our- My business operates in a de- problem in our operations that could help meet economic, environmental and Q veloping country and competes compromise food safety. Our managers social challenges in communities where selves to high standards and encourage with companies that don’t have must make sure employees have the we live and work. By working together with others to do the same. Cargill’s strict food safety require- training and resources necessary to a wide range of public and private part- ments. This puts me at a competitive For guidance on how your business or understand and perform their role in food ners, our people and businesses contrib- disadvantage. I know I need to com- function can support worthy projects ply with the laws of the developing and feed safety. For additional guidance, ute time, talent and financial resources to in our communities, contact your local country. Isn’t that enough? see Cargill’s Food Safety policy and help make measurable progress against Corporate Affairs Manager. operating principles. the difficult issues that no one organization No. Because we touch the global alone can solve. This is an important part A food supply chain in so many ways and in so many places, we take a broad, Political Activity comprehensive approach to ensure the safety and integrity of our food and feed Cargill respects the right of its employees products. In addition to compliance with to participate in the political process and in applicable laws and regulations, our Looking for additional information? policy requires that our food and feed any political activities they choose. How- products be produced in accordance ever, employees must keep personal po- with Cargill’s Corporate Food Safety and litical activities and views separate from Contact the Global Ethics and Compliance Office Directly: Regulatory requirements, which often work activities. Do not use Cargill’s re- set even higher standards. sources, like our facilities, email or trade- Send an email to [email protected] marks, for your own political activities and Food and Feed Safety avoid giving any impression that Cargill Or use the Ethics Open Line at www.cargillopenline.com sponsors or endorses any position that Cargill’s goal is to provide safe food and you personally hold. feed every time, everywhere. We use Visit the Global Ethics and Compliance Office website: internal systems and only those external Corporate political activity, including suppliers that ensure our food and feed political contributions and lobbying to http://internal.Cargill.com/sites/ethics-compliance and find influence legislation, is highly regulated products meet our own strict Food Safety The latest version of our Code and Regulatory Affairs requirements, as and subject to special legal rules. At Car- well as all applicable laws. To improve gill, the Government Relations team man- Key compliance dates and requirements food and feed safety across Cargill and ages the organization’s political activities. within our industries, we share informa- Businesses and functions should contact Information on the GECO tion on food and feed safety matters both Government Relations for review and ap- internally and externally and encourage proval before making any political contri- Training and presentation materials our employees to bring forward ideas that bution in support of a candidate, party, can improve our efforts. campaign, public official or ballot issue, or engaging in lobbying activity. This helps Subscribe to our GECO panel through Cargill Connects All Cargill employees are responsible for ensure that our political activities comply to receive articles and updates on Cargill’s ethics and making sure the food and feed products with the law and support Cargill’s interests. compliance program

32 We are committed to being a responsible global citizen 33 Our Values and Leadership Expectations

We believe having one set of values is a powerful way to underscore how we work as one Cargill, becoming an integrated and connected operating company to leverage the entirety of our strategy, capital, size talent and culture to create competitive advantage.

Our values serve as the foundation of the Cargill Leadership Expectations. Because our values help us understand why we do what we do and the Cargill Leadership Expectations help us understand how our behaviors show up, it makes sense to reflect that strong interdependence in the way we depict them.

Cargill P .O . Box 9300 Minneapolis, MN 55440 www.cargill.com