About Cargill’s Code of Conduct

Why do we have a Code?

Cargill’s Code of Conduct outlines our ethical standards for business conduct wherever we operate. It’s your guide to answer questions and resolve ethical dilemmas.

Our Code has 7 Guiding Principles. They express Cargill’s core values and ethics. Use them to guide your actions and decision-making on our behalf. The Code also summarizes key compliance policies. It highlights the key legal and ethical issues and provides guidelines for appropriate conduct.

Who must follow our Code?

Our Code applies to all employees of Cargill, its affiliated companies and to members of our Board of Directors when acting on behalf of Cargill. Our Code cannot be waived unless the General Counsel or Board of Directors approves such a waiver.

What does the Code require of me?

As employees of Cargill, we must follow our Code by making decisions consistent with it. We must speak up if we have any concerns and report any Code violations that we discover or experience. Disciplinary action will also apply for the failure to report Code violations or refusing to participate with an investigation

What does the Code require from managers?

Managers set the tone for their teams. They are often the first people employees will turn to with questions. As a result, we expect managers to:

• Set a strong example of ethical conduct
• Provide support to employees in complying with the Code of Conduct and compliance policies
• Encourage employees to speak up when they have questions or concerns.
• Appropriately address misconduct