Our Guiding Principles
We all have to abide by applicable laws, rules and regulations of the countries in which we operate – that's the starting point. Also, we must follow our company policies. And if there is a difference between a legal requirement and our Code of Conduct or policies, we will always apply the higher standard. To help provide clarity, this Code sets out the 10 most important principles to doing business with integrity that apply company-wide. Each has a cross-reference to the relevant Compliance Policy in our Corporate Global Policy Center that contains more details on expectations.
Treat People Fairly
We value the authentic selves of the individuals who work hard every day to empower people to snack right. We see diversity and inclusion as tied to our success. We are committed to providing a respectful and safe working environment, and we believe that everyone deserves an equal chance to succeed based on their hard work, talent and commitment to the values of Mondelēz.
Laws and cultures may differ around the world, but the concept of treating others as you want to be treated is universal, regardless of race, color, religion, gender, age, ethnic or national origin, veteran status, disability, sexual orientation or preference, gender identity, marital status, citizenship status, genetic information or any other legally protected personal characteristic or status. Likewise, we do not tolerate discrimination, harassment, bullying, intimidation or any disrespect to human rights, including child and forced labor.
At Mondelēz, there is no room for discrimination or harassment.
Treating people fairly means, for example, that:
- We practice civility in our workplace; we treat our colleagues and partners with dignity and respect.
- We have fun while we work and grow, but not in a way that makes others feel excluded or offended.
- Managers lead by example, giving employees confidence that Mondelēz is a fair and safe place to work.
Make Food that Is Safe to Eat
We are a snack company, and "Snacking Made Right" reflects our relentless focus on food safety.
Therefore, we ensure that the food we make achieves our highest standards. We must be aware of and follow our company policies and procedures to protect this commitment. Whenever we face challenges, we will resolve them with urgency and transparency.
Market Responsibly
We take great care to market responsibly – to help consumers snack mindfully. Misleading marketing erodes consumers' trust in us and can ultimately hurt all our brands. We have clear guardrails to ensure our product claims are substantiated and that we comply with our Marketing to Children Policy.
Embrace Social and Environmental Responsibility
We care about the lives we touch and our goal is to treat everyone with respect, from employees in our plants to smallholder farmers and their communities in our agricultural supply chains.
Through our actions and policies, we strive to respect human rights within our own operations and our value chain. We also seek to do business with partners who share the same principles.
We care about our planet, so we work hard to prevent pollution, minimize waste and reduce our use of natural resources.
Be vigilant. Human rights risks can arise in any location or situation. If you identify a potential human rights violation, report it immediately to your manager, Human Resources, Legal or the Ethics & Compliance Office.
Protect and Respect Private and Proprietary Information
Many of us have access to confidential, sensitive, private or other nonpublic information through our work and it is our obligation to safeguard it. At Mondelēz we protect our employees', consumers', customers' and business partners' confidential information we may have access to as part of our business relationship.
We also protect our own confidential information. Mondelēz's confidential information is among our most valuable assets. This information represents the outcome of significant company investment and years of hard work by our team. Unauthorized disclosure may result in a competitive disadvantage. That means we will not share this information with our family, friends, colleagues or anyone who is not authorized to receive such information for business purposes – and this obligation continues even after we leave the company.
At Mondelēz, we also understand and respect the importance of proprietary intellectual property rights (including trademarks, patents and trade secrets) both for our company and for others. We protect the intellectual property rights of the company, and we do not knowingly violate the valid intellectual property rights of others.
We are all responsible for the information security of the company and keeping Mondelēz information systems, data, technology and equipment safe, whether working on-site or remotely. Be cybersecurity savvy, keep your passwords secure, stay vigilant on any phishing attempts, follow all information security policies and handle any incident appropriately.
Check: Always check with your supervisor or another designated resource before taking action or giving out information if you have questions or are uneasy about the validity of a message or request you receive.
Alert: Immediately report and preserve any suspicious messages you receive. Prompt reporting allows Mondelēz to alert others and take the necessary steps to contain the phishing attempt.
Compete Fairly and Follow International Trade Laws
We compete hard – but also fairly and equitably within the law. This means that we won't spy on our competitors or use their confidential information, and we expect our competitors to treat us the same. We won't engage in business practices or exchange information with our customers or competitors that reduces or limits competition. We implement fair and equitable pricing and promotional programs for our customers, and we follow the law when competing for our customers' business. We won't interfere with free markets, but instead we allow competition to take its course for the benefit of our consumers.
Mondelēz is committed to compliance with applicable laws in conducting our global business, including sanctions, export controls, and customs and import laws.
- Be aware of sanctions, which are imposed on certain countries, territories, entities and individuals, and which can impact our business.
- Be aware of export controls and other trade laws, which can impact our ability to move goods, software and technology around the world.
- Do not make your own assumptions regarding the applicability (or lack thereof) of sanctions, export controls, or other trade laws without guidance from Legal and Ethics & Compliance.
- Conduct appropriate due diligence on our suppliers, customers and other counterparties, and never take any action that seeks to circumvent or evade economic or financial sanctions – whether due to business pressure or a lack of knowledge.
Deal Honestly with the Government
The general rules here are obvious and simple. We won't bribe. We won't lie. We won't deceive. We won't hide information from government inspectors or falsify documents. We will not offer anything of value to a government official to obtain an improper business advantage.
We will also maintain the highest level of integrity when advocating on behalf of the company via lobbying or otherwise engaging with governmental entities.
The same is expected from our agents or service providers who interact with government officials on our behalf.
- We will not make any payments, directly or indirectly, to improperly obtain a business advantage or expedite a permit or license — no matter what. Mondelēz does not permit facilitation payments of any kind.
- If a government official requests a bag full of products to avoid imposing a fine on us, we say no.
- There is no "cultural aspect" more important than our ethical standards. Stop and speak up if you hear "that's the way we do business in this country."
- We will ensure the third parties we hire are aware that we will deal honestly with the government – and expect the same of them.
Never Trade on Inside Information
Employees shall not trade Mondelēz stock ("MDLZ") or options based on "inside" information. That means we, our family members, or anyone living in our household must not buy or sell company stock or exercise options based on material things we know about the company that the public doesn't know. Not only is it basic fairness, insider trading a crime. Our investors should be able to trust that everyone trading in the market has the same information.
Keep Accurate Books and Business Records
Our financial statements must be complete, timely, accurate and fair and comply with applicable accounting principles. We won't hide liabilities, overstate earnings, keep things off our balance sheets that belong there, or disguise our transactions. We will provide investors with accurate data they need to make informed investment decisions, since omissions and distortions would severely harm their trust.
We will not engage in fraud, theft or misuse of our assets. We will not obscure any record or circumvent a policy or process for personal gain.
We will manage all records and information securely and in full compliance with all applicable laws and regulations and business needs – everywhere we do business.
Avoid Conflicts of Interest
Doing what's right goes both ways. The company works hard to earn our trust, and in turn, expects our loyalty. That means we won't have personal interests that conflict with those of Mondelēz or use our position with the company for any advantage or gain to ourselves or our close friends and relatives. For the same reason we generally may not accept gifts from business partners, since it could affect our objectivity in pursuing Mondelēz's best interests, and, of course, we never accept a bribe or kickback.
If an employee has a potential or actual conflict of interest, he or she must report this per our Conflicts of Interest Policy.
Some examples of potential conflicts of interest:
- Hiring a firm owned by a close relative to do consulting work for Mondelēz.
- Having a financial interest in one of our suppliers, customers or competitors.
- Serving on the board of directors of a competitor.
- Having an outside job that could interfere with our work for Mondelēz.