DuPont Code of Conduct Ensuring a Sustainable Future OUR CORE VALUES IN ACTION June 2013 Copyright © 2013 DuPont. All Rights Reserved. The DuPont Oval Logo, DuPont™, The miracles of science™ and all products denoted with ™ and ® are trademarks or registered trademarks of DuPont or its affiliates. The following are registered trademarks of E. I. du Pont de Nemours and Company: DuPont™ Tedlar® films, DuPont™ Fodel® photoprintable thick film, DuPont™ Cyrel® FAST digital printing system, DuPont™ Delrin® acetal resin, DuPont™ Surlyn® resin, DuPont™ Hytrel® thermoplastic polyester elastomer, DuPont™ Kevlar® brand fiber, DuPont™ PowerSoft® cake enzymes, DuPont™ Sorona® high-performance biopolymer, DuPont™ Tyvek® protective material, DuPont™ Corian® solid surfaces and DuPont™ XIVIA™ Xylitol sweetener. Pioneer® brand seeds is a registered trademark of Pioneer Hi-Bred International, Inc. Solae® soy protein is a registered trademark of Solae LLC. K15805-C DuPont Code of Conduct A Message from the CEO In This Code DuPont Colleagues: A Message from the CEO 2 Our Purpose. Our Core Values. 3 Ensuring Sustainable Practices for Society 27 For centuries, DuPont employees have used market-driven science to About This Code of Conduct 5 make a difference in an ever-changing world. Even as our company Responsibilities & Violations 6 Competition Practices 28 and the world has grown and evolved, we have never changed the commitment we share to our core values. They are more important now Competitive Information 28 than ever before. Providing Sustainable Solutions for Government Relations, Government Business Our Customers and Consumers 10 & Travel of non-U.S. Government Officials 29 Today, our business environment offers opportunities, challenges, and Environmental Protection & Sustainability 30 surprises at every turn. Our actions are watched by our customers, Gifts, Entertainment & Payments 11 Product Stewardship 30 partners, the media, and government authorities around the world. No Gifts & Entertainment 11 Human Rights 31 matter what demands are placed on you during your workday, any Bribes & Kickbacks 11 Contacts with Outside Parties 31 violation of our core values is inexcusable. These principles distinguish Payments for Products & Services 12 DuPont employees and the way we do business and often speak to legal Business Across Borders 13 Preserving a Culture of Sustainability for or regulatory responsibilities that we must rigorously adhere to. Export Control Compliance 13 Our Employees 33 Customs & Imports 14 The DuPont Code of Conduct was designed to help you understand our Antiboycott / Economic Boycotts & Trade core values and your personal accountability as a DuPont employee. It Respect for People 34 details our policies and procedures and should be considered a guide with Potentially Sensitive Countries 14 Equal Opportunity & Non-Discrimination 34 to help you make decisions. To keep pace with changes in the world Customer, Consumer, Supplier, or other Third Non-Harassment 34 and in our markets, enhancements are occasionally made to the Code of Party Privacy 15 Privacy & Personal Information 34 Conduct. That’s why it’s important for you to regularly review the Code of Safety & Health 35 Conduct and talk with your manager if you have any questions about it. Creating Sustainable Growth for Our Shareholders 16 Adherence to our core values is an expectation of every employee. Take Supporting Information 36 time to read and use the Code of Conduct and review your actions in light Conflicts of Interest 17 of these guidelines. Outside Employment, Work, or Activities 18 Making Better Decisions 36 Insider Trading 19 Getting Assistance & Raising Concerns 37 Corporate Opportunities 20 Addressing Possible Misconduct 37 Political Contributions or Activities 20 Company Ethics & Compliance Program 37 Company Assets 22 Index 38 Ellen Kullman Computers & Communications Systems 22 Non-Public Information 23 Inventions 24 When you see this symbol, there is additional Brands, Trademarks & Copyrights 24 information on the topic which can be found only in Records & Reporting 24 RESOURCES on the DuPont intranet. Expense Reporting & Reimbursement 25 Departing the Company 26 DuPont Code of Conduct 2 3 Our Purpose. Our Core Values. About This Code of Conduct OUR PURPOSE DuPont is a science company. We work collaboratively to find sustainable, What each of us does at DuPont impacts our collective reputation as a company. innovative, market-driven solutions to solve some of the world’s biggest challenges, making At all times, employees are expected to follow laws and regulations, the DuPont So how we conduct business is as important as what business we conduct. DuPont Code of Conduct, and other company lives better, safer, and healthier for people everywhere. employees conduct business by following the DuPont core values of Safety & Health, policies. Environmental Stewardship, Highest Ethical Behavior, and Respect for People. Our core values guide our actions and influence company policies and programs. OUR CORE VALUES The core values of DuPont are the cornerstone of who we are and what This Code of Conduct reinforces our core values. The Code sets expectations for every we stand for. They are: employee about how we are to operate our businesses, work with customers, suppliers, and other business partners, serve our shareholders, and interact with our communities and with each other. The Code serves as a resource guide to help all employees make decisions that reflect our DuPont core values. • Safety and Health We share a personal and professional committment to protecting the safety and health of our Central to ethics at DuPont is ensuring that each of us purposefully upholds the company’s standards. Any act that intentionally violates the law or regulation, and any employees, our contractors, our customers and the people in the communities in which we effort to conceal non-compliance with this Code of Conduct, or a company policy, is an ethics violation. operate. How to Use This Code of Conduct 1. Become familiar with the Code’s purpose and contents. Understand how the topics • Environmental Stewardship covered in the Code relate to your own business activities. 2. Understand your responsibilities listed in Employee Responsibilities on page 6. We find science-enabled, sustainable solutions for our customers, always managing our 3. Know how to use the decision tools in Making Better Decisions on page 34. 4. Know about the resources for resolving questions and ethics and compliance issues businesses to protect the environment and preserve the earth’s natural resources both for today in Getting Assistance & Raising Concerns on page 35. and for generations into the future. Please Note This Code of Conduct is a guide for the uniform management of company rules that affect our operations. It serves the best interests of our employees and stakeholders. The • Respect for People company will administer this Code equitably and responsibly. This Code of Conduct is not a contract. The company reserves the right to modify, change, or alter any section We treat our employees and all our partners with professionalism, dignity and respect, fostering of this Code of Conduct at any time, as needed. Significant changes to this Code will be communicated broadly to employees and disclosed on the company’s website. an environment where people can contribute, innovate and excel. This Code of Conduct applies to all DuPont businesses and subsidiaries and to operations where DuPont has a controlling interest. • Highest Ethical Behavior In the rare circumstance where a waiver of the Code would be appropriate, waivers for We conduct ourselves and our business affairs in accordance with the highest ethical Corporate Officers will be considered by the Audit Committee of the Board of Directors, and waivers for all other employees will be considered by the DuPont Corporate standards and in compliance with all applicable laws, striving always to be a respected Compliance Committee. corporate citizen worldwide. DuPont Code of Conduct 4 5 Responsibilities & Violations Employee Responsibilities • Customer, Consumer, Supplier, or other Third Party • Government Relations If authorized to work with government • When an employee raises a question or concern that may Privacy Safeguard DuPont customers’, consumers’, suppliers’, or officials, make certain that relationships with government officials and be difficult for the manager to resolve, seek assistance from As DuPont employees, we are entrusted with ensuring that the other third parties’ privacy by carefully guarding their information employees follow the law and meet the requirements imposed by Getting Assistance & Raising Concerns on page 35. company’s operations reflect responsible business practices. and disclosing it only to others authorized to receive it. the government. Always ensure that actions cannot be perceived as • Appropriately respond to employees’ conflict of interest situations • Conflicts of InterestDisclose personal interests that could improper or as presenting a conflict of interest. to ensure business decisions are wholly in the company’s best Overall Responsibilities possibly pose a conflict with the company, including, but not • Environmental Protection & Sustainability In business interest. To meet this responsibility, each employee must: limited to: outside employment; other activities and financial activities, safeguard the environment by minimizing pollution, • Demonstrate the DuPont core values in everyday business