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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 coun- tries. 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.
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