Living

Our
Values
Kellogg Company’s Global Code of Ethics

®
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Our Core
STANDARDS

K ValuesTM
INTEGRITY
We Act with Integrity and Show Respect

ACCOUNTABILITY
We Are All Accountable

PASSION
We Are Passionate About Our Business, Our Brands and Our Food

HUMILITY
We Have the Humility and Hunger to Learn

SIMPLICITY
We Strive for Simplicity

RESULTS
We Love Success

Global Code of Ethics Principles

OUR PEOPLE
We act with integrity. We treat each other with fairness and respect.

OUR CONSUMERS
We delight our consumers with safe, high-quality, great-tasting foods.

OUR MARKETPLACE
We compete vigorously and with integrity. We partner with those who
demonstrate our values.

OUR INVESTORS
We are a preferred investment because we deliver the present while
creating the future.

OUR COMMUNITIES
We use natural resources responsibly and support our communities.

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Message from
STEVE CAHILLANE

Dear Colleagues,

If you are reading this, you are part of a legacy more than 100 years in
the making. A lot can change in the course of a century, but at Kellogg,
we know that the need for a trusted source of nourishment is timeless.
That’s why we take seriously our commitment to providing high-quality
sustenance to people everywhere. It is this conviction that moved W.K.
Kellogg to found the company in the first place. It is this attitude that has
earned our food and brands both recognition and love worldwide.

The responsibility to protect this long-standing reputation falls to each

of us. This means performing our jobs to the very best of our abilities. It
also means acting with the utmost integrity in everything we do. When
we act with integrity, we foster a safe, respectful and inclusive workplace.
A healthy workplace is the foundation on which we can build healthier
relationships with our consumers, our investors, our marketplace, our
communities and with each other. Our continued success starts with
every one of us, making the right decisions, every day.

That’s what our Global Code of Ethics is all about. Our Code establishes
a shared set of values and policies to which all of us are expected to
adhere. Please read it carefully. Let it guide your actions and interactions Our Vision:
with others. Speak up if you suspect any violation of its principles. Seek To enrich and delight the
help if you are ever in doubt as to what our Code says, what actions are world through foods and
appropriate or what your duties are in upholding the Code. brands that matter.
Thank you for taking the time to read our Global Code of Ethics, and for Our Purpose:
using the information found here to help make Kellogg even better and Nourishing families so they
stronger. Your dedication to living our values has never been more vital to can flourish and thrive.
our continued success.

Sincerely,

Steve Cahillane
Chairman and Chief Executive Officer

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Table of Contents
Our Core Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Protecting Personal Information. . . . . . . . . . . . . . . . . . . . . . . 17
We protect the confidentiality of our colleagues’ personal,
Message from Steve Cahillane. . . . . . . . . . . . . . . . . . . . . . . . . . 5 medical, family and financial information. We do this by not
disclosing such information to anyone, internally or externally,
How We Do What’s Right. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
other than those with a business need for such information and
Introduction to Living Our Values where we are legally permitted to do so.
Everyone, Everywhere, Every Day. . . . . . . . . . . . . . . . . . . . . . . 9 Engaging in Social Media.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
We have a shared identity as Kellogg employees. But we are also
Everyone’s Responsibilities individuals with our own thoughts, opinions and interests.
Special Responsibilities for Leaders and Managers Avoiding Conflicts of Interest. . . . . . . . . . . . . . . . . . . . . . . . . . 19
Making Decisions the Kellogg Way At Kellogg, we thrive together. We make decisions and act in the
best interests of Kellogg rather than for personal gain.
Responsibilities of Suppliers and Other Business Partners
Relatives and Friends
How We Uphold the Code.. . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 We avoid situations where our judgment and decision-
The Importance of Seeking Guidance and making could be influenced by close personal or family
Speaking Out relationships.

Seeking Guidance Personal or Close Relatives’ Investments

We ensure that our investments and those of our close
Office of Ethics and Compliance relatives do not create conflicts of interest that could affect
our objectivity and judgment when making work decisions.
Speaking Out: Expressing Concerns and Calling
the Ethics Line Outside Employment and Other Activities
We each give our best effort every day at Kellogg. We do
Retaliation Is Strictly Prohibited
not allow outside jobs or other activities to hinder our
Investigations contributions to Kellogg.
Government Investigations Corporate Opportunities
We share knowledge of opportunities we uncover and
Disciplinary Action discoveries we make at work. This lets us better pursue our
Waivers goals as a company and serve those who count on us.
Gifts and Entertainment
Living Our Values for We do not give or receive inappropriate gifts, favors and
entertainment.
OUR PEOPLE
Living Our Values for
Promoting a Safe and Healthy Workplace. . . . . . . . . . . . . . . 14
We are committed to maintaining a safe and healthy workplace.
Our colleagues, business partners, visitors and communities
OUR CONSUMERS
deserve no less. Delivering on Quality, Safety and Value. . . . . . . . . . . . . . . . . 24
Valuing Diversity and Inclusion. . . . . . . . . . . . . . . . . . . . . . . . 15 We delight our consumers with great-tasting, high-quality
We believe in the power of people. We have respect for products. We are committed to providing safe foods our
individuals of all backgrounds, capabilities and opinions. We consumers can trust.
encourage an inclusive environment that promotes individual Promoting Honest Marketing Practices. . . . . . . . . . . . . . . . . 24
expression, innovation and achievement. We show pride in our brands and understand the importance of
Preventing Harassment and Discrimination.. . . . . . . . . . . . . 16 accuracy and transparency in advertising and packaging.
We are committed to maintaining a work environment where Protecting Consumer Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
our people are treated with dignity and respect and are free of We respect the privacy of all individuals and take the necessary
harassment and discrimination. and legally required precautions to protect personal data.

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Living Our Values in Using Equipment, Information and Communications

Systems Responsibly. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
OUR MARKETPLACE We use company equipment, information and communication
systems responsibly.
Doing Business Globally. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Avoiding Insider Trading and Market Abuse. . . . . . . . . . . . . 40
We are a global company doing business around the world and We never use or improperly disclose material, nonpublic
committed to complying with applicable laws that govern both information about Kellogg or another company for the purpose
domestic and international trade. of buying or selling securities. Nor do we ever attempt to
manipulate the price of publicly traded securities.
Promoting Fair Competition. . . . . . . . . . . . . . . . . . . . . . . . . . . 29
We seek to outperform our competitors fairly and honestly. Responding to Inquiries from Investors, Analysts and the
This means achieving competitive advantage through superior Media. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
performance and never through unethical or illegal business At Kellogg, we speak with one voice when communicating with
practices. the media, financial analysts, investors and the public.
Gathering Competitive Intelligence.. . . . . . . . . . . . . . . . . . . . 30
We believe it is important for us to understand our customers, Living Our Values in
OUR COMMUNITIES
our suppliers and the value proposition of our competitors. This
helps us to understand our global marketplace and to advance
our business objectives.
Promoting Fair Purchasing Practices. . . . . . . . . . . . . . . . . . . . 30 Protecting the Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . 44
We select business partners fairly and objectively. This ensures We are committed to building a more sustainable society. This
the best value for Kellogg while protecting our reputation. means minimizing our environmental footprint and developing
solutions that conserve resources and protect our planet.
Preventing Bribery and Corruption. . . . . . . . . . . . . . . . . . . . . 31
We base our business relationships on trust, transparency and Contributing to Our Communities. . . . . . . . . . . . . . . . . . . . . . 45
accountability. We never offer or accept any form of payment or We are committed to supporting the communities where our
incentive intended to improperly influence a business decision. employees live and work. We also explore ways to address
broader challenges in society.
Safeguarding the Intellectual Property of Others. . . . . . . . . 33
We safeguard others’ intellectual property as we do our own. Participating in Politics and Government Affairs.. . . . . . . . . 45
We encourage our employees to participate in the political
Sourcing Responsibly and Protecting Human Rights. . . . . . 33 process as active citizens. As a company, we will engage
As a responsible, global corporate citizen, Kellogg seeks to do constructively with all governments in whose jurisdictions we
business only with business partners who always obey the law operate.
and operate fairly and ethically.
Personal Political Activity
We encourage individual participation in civic and political
Living Our Values for activities, including holding political office.

OUR INVESTORS Corporate Political Activity

Wherever we do business, we comply with federal, state and
local political campaign finance and election laws.
Creating and Maintaining Accurate Records and Accounts.36
We maintain complete and accurate records. We do so to make Lobbying
responsible business decisions and provide truthful and timely We will never attempt to apply improper influence on any
information to the investing public and various governments. government agency, representative or legislator to produce
an outcome favorable to Kellogg.
Safeguarding Our Reputation and Other Assets. . . . . . . . . . 37
We protect Kellogg’s reputation and other tangible and intangible W. K. Kellogg: A Legacy of Integrity. . . . . . . . . . . . . . . . . . . . . 47
assets. We do so to better serve our consumers and preserve
value for our investors and other stakeholders. Speaking Up and Seeking Guidance. . . . . . . . . . . . . . . . . . . . 48

Protecting Our Proprietary and Confidential Information.. 38

We must safeguard Kellogg’s proprietary and confidential business
information against unauthorized disclosure and misuse.

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How We Do What’s Right

Introduction to Living Our Each topic is divided into three sections:

Values: Kellogg Company’s

Global Code of Ethics HOW We Do What’s Right
A summary of the essence of our approach to doing business.
More than 100 years ago, our founder, W.K. Kellogg, saw This sets the expectation for how we conduct ourselves.
the promise in a single grain. Through his passion and
commitment to nutrition, Kellogg’s Corn Flakes® were
created. The cereal industry was born.
WHY It Matters
An explanation of why following the relevant standard is
Today, Kellogg Company (“Kellogg”) pursues its Vision and
important to protecting our company’s reputation. This helps
Purpose in more than 180 countries. At the same time, the
us avoid unwanted risk and contributes to our company’s
world has never been more interconnected. This means the
long-term sustainability and growth.
actions of a single individual can affect more people in more
ways than ever before in a matter of seconds. This creates
huge opportunities for Kellogg—but also risks. It’s why we WHAT It Means
must be more focused than ever on HOW We Do What’s The practical implications of the relevant standard. This is how
Right. we behave to meet or exceed our expectations and those that
When it comes to doing the right thing, our K ValuesTM are the others have of us.
foundation. They are part of our DNA. They guide the way we
work with our business partners, within our communities and The following two sections explain why our Code is so
with each other. Through integrity, accountability, passion, important, how it works and how we ensure that it is
humility, simplicity and a focus on success, we have created a followed.
vibrant, ethical performance culture.
We named our Global Code of Ethics Living Our Values Note: Policies in the Code
because the K ValuesTM are essential to our individual and
collective success. We embody these values in our daily If you are an employee and need to access a specific policy
decisions and actions. This helps us achieve sustainable mentioned in the Code:
business success and maintain a strong reputation. The Code
contains important information and resources that help us • For HR policies, go to myHR and visit Policies & Information.
conduct our business legally, ethically, responsibly and in • For Information Security policies, visit K Connect > Information
accordance with our values. It is readable, easy to use and Technology > Quick Links > IT Policies.
relevant to our day-to-day jobs. We should all be very familiar • For Global Corporate Affairs and the Government Relations
with the Code and use it often. Department, visit K Connect > Government Relations.

The topics in the Code are organized under five major

headings. These headings represent our key stakeholders—
those who have a stake in or are affected by how we run
our business. They are: Our People, Our Consumers, Our
Marketplace, Our Investors and Our Communities.
We have organized the topics this way for ease of reference.
They are not mutually exclusive, since some topics may apply
to more than one group.

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Everyone, Everywhere, Every Day

Our reputation and success depend upon the decisions and actions
of our people, all over the world. Every action we take should honor
Making Decisions the Kellogg Way
our K Values and be in full compliance with the law and our Code. How we make a decision says as much about who we
are as a company as the decision itself. It is important to
Everyone’s Responsibilities make decisions we can be proud of. Such decisions lead to
behaviors that are legal, ethical and responsible.
As employees, we are all responsible for how Kellogg does business
Use this Decision Tool to navigate the gray areas of business
and the impact Kellogg has around the world. We uphold a legacy
and ensure we make the best choices.
of integrity through the right behaviors, which always involve:
• Acting with integrity: honoring our commitments, upholding
our Code, obeying the law and acting responsibly and in good faith. CAN We Do It? Is it permitted by Law?
• Showing respect: valuing diversity of thought and
opinions, encouraging open and frank dialogue, and
considering the impact of our decisions on stakeholders. Not Sure? No
• Building trust: seeking fair resolutions, making decisions • Consult with others • Don’t Do It
based on the merits, dealing honestly with all stakeholders and • Contact Legal forguidance
maintaining transparency in our decision-making.
Yes
We seek guidance as needed and report actual or suspected SHOULD We Do It? Is it ethical and consistent with our
violations of our Code, company policies and the law (see K Values, our Code and company
How We Uphold the Code).

Special Responsibilities for Not Sure? No

Leaders and Managers • Consult with others
• Contact myHR, local HR
• Don’t Do It

All employees are required to act with integrity, show or the Office of Ethics and
respect and build trust. Additionally, leaders and managers Compliance for guidance
have special responsibilities under our Code. If you lead or
supervise others, Kellogg requires you to demonstrate ethical Yes
leadership with the following actions:
HOW Do We Do It? Will it enhance our culture
1. Foster a positive work environment in which only legal, and reputation and benefit our
ethical and responsible behaviors are acceptable. Bear stakeholders?
this in mind when you hire, promote or delegate.
2. Model appropriate behaviors in line with our Code and K Values.
3. Communicate the importance of ethically sound business Not Sure? No
practices. Discuss the ethical and legal implications of • Consult with others • Don’t Do It
business decisions. • Discuss with your manager
4. Provide employees with training and development to guide their for guidance
performance, enhance their capabilities and grow their careers.
5. Use our performance review process to evaluate employees Yes
on what business objectives they achieve and how.
6. Identify and mitigate ethics and compliance risks, as well • Proceed with Confidence
as other business risks.
7. Respond in a timely way to those who seek advice or
raise concerns. Help them feel secure and at ease.
Responsibilities of Suppliers and
8. Keep commitments and manage employees’ expectations. Other Business Partners
9. Expect accountability among all employees, regardless of We work with business partners who share our values and our
position or job title. approach to doing business. We expect these business partners
10. Manage conflicts of interest to achieve fair and to understand and act consistently with the standards set out in
appropriate outcomes. our Global Supplier Code of Conduct.

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How We Uphold the Code

Our Global Code of Ethics applies to all employees and
officers of Kellogg and its subsidiaries. Contractors, You may contact the Office of Ethics
consultants and others working on our behalf must also and Compliance in any of these ways:
follow the Code. We apply the Code, conduct investigations
and take remedial action in a fair and consistent manner. Ethics Line
See Ethics Line Global Access Numbers.
The Importance of Seeking Email
[email protected]
Guidance and Speaking Out Mail
At Kellogg, we maintain a culture where our ideas and Office of Ethics and Compliance
concerns are encouraged, acknowledged and considered. This Kellogg Company
gives us the freedom to be at our best, extend and build trust, One Kellogg Square
and demonstrate ethical leadership. If you have a concern P.O. Box 3599
about a business situation, there are a number of resources Battle Creek, MI 49016-3599
available to you. Web
https://www.tnwgrc.com/Kellogg

Seeking Guidance
You should always feel free to go to your manager with a Speaking Out: Expressing Concerns
question or concern. He or she is likely to have insight and
experience in the matter and can seek expert assistance if
and Calling the Ethics Line
necessary. You can also consult with the departments that If something does not feel or look right, each of us should
provide oversight for the policy or law in question, the Human feel empowered to act. If you are concerned about a possible
Resources Department (myHR) or the Legal and Compliance violation of the Code, company policy or the law, you are
Department. At any point, you may also seek advice and required to notify at least one of the following:
assistance from the Office of Ethics and Compliance.
• Your manager (provided your manager is not involved in
the violation),
Office of Ethics and Compliance • Human Resources (myHR),
• The Legal and Compliance Department,
The Office of Ethics and Compliance is a resource that: • Internal Audit, or
• The Office of Ethics and Compliance.
• Provides guidance and clarifies how to apply the Code or
a company policy to our business activities.
If you see something, say something—as soon as possible.
• Provides ethics and compliance training.
It is always best to raise your concerns early. The longer you
• Receives reports of all actual or suspected violations of
wait to address a concern, the worse it may become.
our Code, company policies and the law.
It is helpful when you identify yourself. This enables us to
follow up and provide feedback when appropriate. You may
also report any actual or suspected violations anonymously
by contacting the Ethics Line. Our Ethics Line is maintained
by a third-party confidential reporting company. Its
representatives will forward your concerns to our Office of
Ethics and Compliance for investigation. Reports submitted
will be handled promptly and discreetly. We will maintain
confidentiality to the greatest extent possible.
See Ethics Line Global Access Numbers.

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Retaliation Is Strictly Prohibited Government Investigations

We support honest and open communication and encourage Though unlikely to occur, we must know how to respond to a
our employees to report concerns. We will not tolerate government request for information or investigation. We must
retaliation against anyone who discloses actual or suspected cooperate lawfully and provide truthful and accurate information.
violations. Retaliation will result in disciplinary action up to It is important to seek advice from the Legal and Compliance
and including termination of employment. Department before responding to a nonroutine request for
information. This will ensure that we act appropriately while
For more information, see the Ethics and Compliance Anti-
protecting Kellogg Company’s legitimate interests.
Retaliation Policy.

Investigations Disciplinary Action

All employees are required to comply with our Global Code
We investigate reports of actual or suspected Code violations
of Ethics. Failure to comply with the Code, company policies
promptly. All employees are required to cooperate fully in
and applicable laws can result in disciplinary action. This can
any Kellogg investigation. The existence and details of an
include termination of employment, as well as potential civil
investigation will be kept confidential and shared only with
and criminal liability.
individuals with a reasonable and actual need to know.
Individuals who have knowledge of and participate in such
investigations must also keep such investigations confidential.
Waivers
This safeguards the integrity of the investigation, protects We recognize that in rare circumstances a strict application
witnesses and secures relevant evidence. We protect the of the Code may result in a significant hardship. In these
confidentiality of the reporting source. exceptional cases, a waiver of the Code to mitigate hardship
may be sought.
Our investigations seek to identify and address misconduct.
This is done while preserving the dignity of those involved, For senior financial and executive officers or directors, any
consistent with our K Values and our Code. waiver or amendment must be approved by the Nominating
and Governance Committee of the Board of Directors for
Kellogg Company. For all other employees, any waiver of
Key Points this Code must be approved by the Office of Ethics and
Compliance in accordance with procedures adopted by the
• Raise concerns early. Nominating and Governance Committee.
• You may remain anonymous.
• Confidentiality is protected.
• Retaliation is prohibited. We Live Our Values
We act with integrity. We treat each other with fairness
and respect.
Our Investigation Process
• Assign investigation team: Individuals with the right
knowledge, objectivity and discretion.
• Conduct investigation: Determine facts through
interviews and/or document reviews.
• Corrective action: Recommend corrective actions to
appropriate managers for implementation (if necessary).
• Feedback: Provide general feedback to the person who
raised the concern (if appropriate).

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 11

 Living Our Values for
OUR PEOPLE

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We drive positive change by seeking opportunities to grow personally and

professionally. Our managers and colleagues support this growth. We deserve
to be treated with fairness and respect. We invite conversation to create the
best possible outcome for everyone involved. Together, we can unlock an even
brighter future for our company, ourselves and those we serve.

This section covers some important standards we must follow. Doing so allows us to
support each other and build a culture where everyone can thrive. The K Values
IN ACTION
SAFE & HEALTHY WORKPLACE
We are committed to maintaining a safe and healthy workplace. Our
INTEGRITY
colleagues, business partners, visitors and communities deserve no less. Show respect for and value all
individuals for their diverse
DIVERSITY & INCLUSION backgrounds, styles, and ideas.
We believe in the power of people. We have respect for individuals of all
ACCOUNTABILITY
backgrounds, capabilities and opinions. Personally commit to the
success and well-being of
HARASSMENT & DISCRIMINATION teammates.
We are committed to maintaining a work environment that is free of
harassment and discrimination. PASSION
Promote a positive, energizing
and fun environment.
PERSONAL INFORMATION
We protect the confidentiality of our colleagues’ personal, medical, HUMILITY
Value openness and curiosity to
family and financial information.
learn from anyone, anywhere.

SOCIAL MEDIA SIMPLICITY

We have a shared identity as Kellogg employees. But we are also Deal with people and issues
individuals with our own thoughts, opinions and interests. directly and openly.

SUCCESS
CONFLICTS OF INTEREST Help people to be their best
We act in the best interests of the company rather than for personal gain. by providing coaching and
feedback.

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Promoting a Safe and Healthy

Workplace
HOW We Do What’s Right • Never bringing illegal drugs or other controlled substances
onto company property or being under their influence
We are committed to maintaining a safe and healthy while at work.
workplace. Our colleagues, business partners, visitors and • Talking to a manager if we believe a colleague may be
communities deserve no less. under the influence of alcohol or drugs while at work.
• Using good judgment and exercising moderation when
WHY It Matters •
alcohol is served at company events.
Not saying or doing anything that could threaten the safety
At Kellogg, keeping people safe and healthy is a core value. or security of others or create fear.
This includes colleagues, business partners and others in • Not carrying firearms or other weapons onto company
and around our facilities. It’s the right thing to do and it also premises or while traveling on company business except as
promotes a positive, caring work environment where people permitted under applicable laws and regulations.
can thrive. • Never retaliating against anyone who reports a health or
We make health and safety a daily priority by observing safety concern or participates in an investigation of these
the health and safety rules of our job. All of us must take concerns.
precautions to protect ourselves, our colleagues and
our visitors. We also observe environmental laws. This For more information, contact the Office of Ethics and
ensures that our actions do not harm the environment and Compliance.
communities where we live, work and source.

To perform at our best every day, we report to work free

from any substance, including alcohol or drugs, that could
If in doubt, ASK!
prevent us from doing our jobs properly or that could create a Q. I have a safety concern. If I bring it up now, it will slow down
dangerous situation. production and we may miss our deadline. I don’t want my
supervisor to be upset with me. What should I do?
Acts of violence, threats and physical intimidation have
no place at Kellogg. Such actions can result in immediate A. Deadlines are important, but health and safety always come
disciplinary action, up to and including termination of first. So, we make tough calls when necessary. The company
employment. always wants you to bring up health and safety concerns
immediately, even if that may mean slowing production, missing
WHAT It Means a deadline or losing a business opportunity.
We foster an active health and safety culture by:
Q. I work in a plant as a production employee. I’m currently
• Making responsible choices and not allowing, directing or taking medication that may cause certain side effects, such as
ignoring unsafe acts on the job. drowsiness. Do I need to tell my supervisor?
• Knowing and complying with occupational health and
safety laws and related company policies. A. Yes. Employees who are using prescription or nonprescription
• Watching out for each other and helping others avoid drugs may have impaired alertness or judgment. This can
unsafe conditions or behaviors. jeopardize their safety and that of their colleagues. So, you
• Reporting unhealthy or unsafe conditions or behaviors. should inform your supervisor upon reporting to work. Each of us
This applies especially to workplace hazards, broken or must embrace the belief that all injuries are preventable and that
missing equipment, injuries or threatening or violent achieving a healthy and safe environment starts with me.
behavior.
• Knowing what to do in an emergency and cooperating
during the practice of emergency drills.

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Valuing Diversity and Inclusion

HOW We Do What’s Right WHAT It Means
We believe in the power of people. We have respect for • We treat each other with dignity and respect.
individuals of all backgrounds, capabilities and opinions. We • We foster an atmosphere of open and candid
encourage an inclusive environment that promotes individual communication.
expression, innovation and achievement. • We hire and promote based on qualifications, skills and
achievements.
WHY It Matters • We do not discriminate.
• We expect our business partners to behave consistently
Diversity fuels innovation, insights into our consumers and a with and to respect our fair treatment and equal
competitive advantage in the global marketplace. opportunity standards.
• We are courageous and speak up when we observe actions
Every one of our employees and applicants for employment and behaviors that are not consistent with our values.
is guaranteed the same fair treatment. We value individuals • We comply with all applicable labor and employment laws.
of diverse backgrounds, approaches and ideas, and we
demonstrate this by seeking to develop and retain a diverse For more information or guidance, contact the Office of Ethics
workforce. Promoting these views and practices with those and Compliance.
companies and individuals with whom we do business is
always a priority.

If in doubt, ASK!
Q. I’m considering an applicant for a job where she’d be
working directly with customers. I’m afraid our customers will
be uncomfortable with her physical disability. Is this a legitimate
reason not to hire her?

A. No. To deny an applicant a job based on disability, race or

other protected classification is unlawful discrimination. If the
applicant is the best qualified person for the job, we should
hire her. At Kellogg, we value all individuals for their diverse
backgrounds, approaches and ideas. Our stakeholders expect
nothing less.

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Preventing Hasassment and

Discrimination
HOW We Do What’s Right
We maintain a work environment based on dignity and
If in doubt, ASK!
respect and free of harassment and discrimination. Q. I can tell my colleague is upset by other women on our team
who tell jokes of a sexual nature. I’m not bothered by them.
WHY It Matters Should I just wait for her to say something?
We believe that every employee should be treated with
respect, regardless of their race, color, ethnicity, national A. Sexual harassment can be directed toward a person of the
origin, religion, age, disability, medical condition, veteran same or opposite sex. If it’s clear to you that your coworker is
status, marital status, gender, sexual orientation, gender offended, encourage her to let these women know their humor
identity or gender expression. A work environment free isn’t welcome. If she’s reluctant, inform a manager about the
from harassment and discrimination lets us grow and thrive situation or report it yourself. At Kellogg, we personally commit
together. to the success and well-being of teammates.

Many forms of harassment and discrimination are prohibited

by law. Behavior that interferes with another’s work
environment is also prohibited. This includes offensive,
intimidating, disruptive, abusive or hostile actions. Examples of Harassment:

WHAT It Means • Unwelcome sexual advances or remarks

• Disparaging comments, slurs, gestures or jokes
• We conduct ourselves appropriately in all dealings with • Displaying or storing written or graphic material that
others. ridicules or shows hostility toward a group or individual
• We are conscientious about how our actions and • Distributing or storing pornographic, obscene or sexually
comments might be perceived or misunderstood by suggestive content
others.
• We do not tolerate any form of abuse or harassment of
colleagues, business partners or anyone else with whom
we have business dealings.
• We have zero tolerance for unwanted verbal or physical
conduct (sexual or otherwise). This includes degrading and
disparaging jokes related to race, color, age, gender, sexual
orientation and any other categories protected by law.
• We report instances of harassment to our manager, myHR
or Local HR, the Legal and Compliance Department,
the Office of Ethics and Compliance or any member of
management.
• We take harassment claims seriously and will investigate
them. For more information, contact the Human Resources
Department.

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Protecting Personal Information

HOW We Do What’s Right
We protect the confidentiality of our colleagues’ personal,
If in doubt, ASK!
medical, family and financial information. We do this by not Q. A business partner wants to send a “get well” card and
disclosing such information to anyone, internally or externally, flowers to his Kellogg account manager. Can I share the
other than those with a need for such information and when employee’s home address with the business partner?
we are legally permitted to do so. When we transfer this
information to those with a business need, we do so securely, A. No. We demonstrate a commitment to integrity and ethics
following the methods required by the Information Security by not disclosing personal information such as a home address
and Legal and Compliance teams. without the explicit consent of the employee, a court order or
other similar legal request.
WHY It Matters
Kellogg collects, stores, uses and shares personal information Q. My coworker is having trouble accessing a file in our systems.
to run our business, comply with legal requirements and I can get to this information. Is it okay to just download it and
administer benefits. We use that information only as needed email it to her or put it on a shared drive?
for relevant business purposes and share with those only on a
need-to-know basis. We handle this data in accordance with A. No. Kellogg IT Security uses access controls mechanisms
the Human Resources Data Privacy Policy, the Information to ensure that data is accessible only to those who need it for
Security policies and applicable local data privacy laws. their individual job function. This helps ensure appropriate
These are designed to protect information from improper segregation of duties and helps protect our valuable information
disclosure. All information relating to employment candidates from accidental or even intentional loss and disclosure. If your
and the employment or employment history of current or coworker has a valid business need for this data, she must submit
former colleagues is subject to the Human Resources Data a request to obtain the needed access.
Security Policy.
Q. I have a very large file I need to send to one of our business
WHAT It Means partners. I think it might be too large to send via email, so I
would like to load it to a cloud storage service so the business
We protect colleagues’ personal information in the following partner can retrieve it. Am I allowed to do this?
ways:
A. No. Please contact Kellogg IT Security to identify the Kellogg
• Follow all applicable privacy laws and company privacy and preferred application used for sharing large files with external
security policies. parties or to identify an alternative sharing method. Files
• Collect, use and process personal data only as needed for should be sent via email only if the information they contain
legitimate business purposes. is appropriate to send via email; please refer to our data
• Protect the privacy and security of information entrusted classification policy, and if you are ever in doubt, reach out to
to us. Kellogg IT Security.
• Never share personal information with anyone who does
not have a business need to know it.

For more information or guidance, review the Human All Kellogg data must be protected based on its classification
Resources Data Privacy Policy and/or the Information level; this includes data at rest (data that is currently being
Security policies or contact myHR. stored), in use and in transit (data that is being transmitted
between systems). Depending on the classification of the data
being shared, IT Security will help to protect it accordingly.
Personal information can include:
An individual’s home address, date of birth, age, race, religion,
political affiliation, sexual orientation, identification or financial
account numbers, medical information and other information
that individuals may not wish to share publicly.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 17

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Engaging in Social Media

HOW We Do What’s Right
We have a shared identity as Kellogg employees. We are also
If in doubt, ASK!
individuals with our own thoughts, opinions and interests. Q. I post on blogs related to my professional expertise at Kellogg.
Should I be up front about my connection to Kellogg?
WHY It Matters
What we say, email, blog, post or tweet can reach millions of A. Yes. When online, being transparent about company
people in seconds. This means our communications can affect connections is good etiquette and consistent with our Code.
millions of people, for better or for worse. Everything we say Depending on where you are, it may also be required by law. At
and do affects our reputation. This power brings additional Kellogg, we value, promote and fiercely protect our reputation.
responsibility. Tell people you work for Kellogg, and add this line to your blog,
chat or other online entries: “The opinions expressed are my
We recognize the growing importance of social media. We own and do not represent the views of Kellogg.”
believe it can be a great vehicle for communicating our
passion and knowledge to our customers.

Outside of work, many of us blog, post on social networks and

Examples of Social Media:
contribute to wikis. Even in these personal pursuits, we all
have a responsibility not to disclose company confidential and • Social networking sites (Facebook, LinkedIn, Yammer)
proprietary information without authorization. • Video and photo sharing Web sites (Flickr, YouTube)
• Microblogging sites (Twitter, Weibo, Snapchat)
WHAT It Means • Blogs (corporate, personal media-hosted and industry
related)
We should engage with social media responsibly, in • Forums and discussion boards (Yahoo! Groups, Google
accordance with the following rules: Groups)
• Collaborative publishing (Wikipedia, Google Docs)
• Adhere to the K Values in all authorized business
communications.
• Comply with the Global Social Media Policy.
• Distinguish clearly between authorized business
communications and personal communications.
• When endorsing our company and its products, identify
ourselves as Kellogg employees, and do not comment
on competitors or their products and services without
identifying ourselves .
• Ensure that our time and effort spent with social media do
not interfere with our work commitments.
• Never disclose confidential, proprietary or privileged
information.
• Do not make false statements or statements that violate
the law.

Use your best judgment and exercise personal responsibility

to avoid any unintended consequences.

For more information or guidance, see the Global Social

Media Policy or contact the Office of Ethics and Compliance.

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Avoiding Conflicts of Interest

HOW We Do What’s Right Conflict of Interest Quick Test
At Kellogg, we thrive together. We make decisions and act in
the best interests of Kellogg rather than for personal gain. If I take this course of action:

WHY It Matters 1. Will I feel obligated to someone else?

2. Am I dishonoring the K Values?
Every choice we make is a chance to make people feel even 3. Is there a chance—however small—of my independent
better about one of the world’s most trusted brands. It’s judgment being compromised?
important to make business decisions based on the merits, 4. Could it give the appearance of impropriety or divided
the K Values and the best interests of Kellogg. loyalty?

WHAT It Means
Our Code provides guidance on some of the more common
If you answered “yes” to any of these questions, it’s
conflicts of interest. But it cannot cover every situation we
probable that your decision will result in a real or
may face. As a first step, ask yourself the questions in the
perceived conflict of interest. If you are unsure about
Conflict of Interest Quick Test (below) to determine if there
how to proceed, seek guidance from your manager or
might be a conflict of interest.
the Office of Ethics and Compliance.
Conflicts of interest can be avoided or addressed when
promptly disclosed and properly managed. If you’re in a
situation where there might be a real or perceived conflict of Relatives and Friends
interest, you must:
We avoid situations where our judgment and decision-
• Disclose your situation to your manager or the Office of making could be improperly influenced by personal or family
Ethics and Compliance. relationships.
• Remove yourself from the decision-making process on how To avoid an actual or perceived conflict of interest, it is not
to resolve the situation. appropriate to:
• Support the subsequent decision.
• Supervise, audit, evaluate or manage the performance
For more information or guidance, review the Conflict of of someone, directly or indirectly, with whom you have a
Interest Policy or contact the Office of Ethics and Compliance. close personal or familial relationship.
• Place colleagues who have a romantic or family connection
in a reporting relationship.
• Be involved in or influence the selecting or hiring of
What Is a Conflict of Interest? someone with whom you have a close personal or familial
relationship.
Conflicts of interest can arise when activities outside of • Participate in the selection or relationship management
work, ownership interests in other companies or personal of a business partner/vendor if the firm employs
relationships interfere or appear to interfere with our ability someone with whom you have a close personal or familial
to do our jobs or to make unbiased decisions on behalf of relationship.
the company.

Even the appearance of a conflict of interest can make

others think we are acting improperly and should be
avoided.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 19

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Avoiding Conflicts of Interest, continued

Personal or Close Relatives’ a second job, board service and community work are all
acceptable if they do not:
Investments • Interfere with your job responsibilities or performance.
We ensure that our investments and those of our close • Involve working for a competitor or supplier.
relatives do not create conflicts of interest. • Risk damaging the company’s business or reputation.
• Use company resources, including other employees or
• Employees may not own, directly or indirectly,
vendors.
a substantial interest in any business entity that does
• Create any other kind of conflict of interest.
business with or seeks to do business with Kellogg
without prior written approval of the General Counsel.
• Employees may not own, either directly or indirectly, Corporate Opportunities
securities in any business that competes with Kellogg
We share knowledge of opportunities we uncover and
(except through a mutual fund) without prior written
discoveries we make at work. This lets us better pursue our
approval of the General Counsel.
goals as a company and serve those who count on us.
• Employees must disclose to their manager any awareness
of a business entity that employs or is owned (even Working for Kellogg, you may sometimes identify a business
in part) by a close relative and seeks to do business or or investment opportunity that Kellogg may have an interest
compete with Kellogg. in pursuing. You must not:
“Substantial interest” means owning more than 1 percent of • Take for yourself opportunities that you discover through
the shares of a business entity (if a publicly traded company), Kellogg property, information or your position.
earning more than 10 percent of your net worth from the • Use Kellogg property, information or your position for
shares of a business entity (if a publicly traded company), improper personal gain.
owning more than 5 percent of the assets of a business entity, • Compete with Kellogg, either directly or indirectly.
or receiving more than 50 percent of annual compensation
from a business entity.
If you are in any doubt, contact the Office of Ethics and
Compliance.
If in doubt, ASK!
Q. I am responsible for the advertising budget for a brand. I
plan to spend a significant part of the budget with one Internet
Who is a “close relative”? search company. My husband and I have jointly invested in that
company’s stock. Is that a problem?
This includes a spouse; domestic partner; child; mother;
father; spouse or domestic partner of mother or father; A. Yes. Spending a large part of the advertising budget with
aunt; uncle; nephew; brother; sister; mother-in-law; father- that company could appear to be motivated by your personal
in-law; son-in-law; daughter-in-law; sister-in-law; brother- investment. Demonstrate a commitment to integrity and ethics
in-law; grandparent; grandchild; step, adoptive, and foster by discussing this investment with your manager or the Office of
relationships; or an individual who resides in your home. Ethics and Compliance before signing the agreement.

Q. I volunteer with a local food bank that lists Kellogg as a donor,

and it offered me a part-time position. Can I take the job, if it
Outside Employment and Other doesn’t cut into my working hours?
Activities
A. Probably. We encourage charitable and civic work. But
We give our best effort every day at Kellogg. We do not allow because the nonprofit receives financial support from Kellogg,
outside jobs or other activities to hinder our contributions to you should ask your manager before you accept the position.
Kellogg. Depending on the circumstances, accepting the job may require
We encourage our people to lead full and productive lives written approval.
outside of work. Outside activities such as your own business,

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Gifts and Entertainment

We do not give or receive inappropriate gifts, favors and
If in doubt, ASK!
entertainment. Q. A new vendor is grateful for the work I did to expedite the
Offering and accepting business gifts, favors and execution of its contract and sent me a bottle of champagne
entertainment is a customary business courtesy. Doing so valued at US$40. Since it’s not very expensive and is valued
can promote goodwill and enhance business relationships. below the acceptable gift threshold, can I accept it?
However, gifts, favors and entertainment should never affect,
or appear to affect, our impartial business decision-making. A. No. Although, the value of the gift is below the acceptable
Nor should these things be offered or received in exchange value threshold, you should politely return the gift to the vendor.
for preferential treatment in any business dealing. Employees who can influence or determine vendor selection
must avoid even the appearance of impropriety. Accepting a gift
Always avoid gifts, favors or entertainment that could appear in this circumstance could create the impression that such gifts
to be bribes, raise questions about conflicts of interest, or influenced your decision. Oftentimes with conflicts of interest,
damage our reputation. perception is reality. Make the tough call and avoid the situation.
Business gifts, favors and entertainment are generally
acceptable if they are: Q. Next week I will be traveling to a conference on behalf of
Kellogg. While I’m there, I will also be meeting with one of our
• Not requested or solicited. suppliers for dinner. We have a long-standing relationship with
• Nominal in value if given by a business partner for which this supplier and his company. As a gesture of goodwill, I’d like
you have purchasing or relationship management duties. to pay for his meal. Would Kellogg consider this an acceptable
• Otherwise modest in value and not lavish. business gift?
• Infrequently given or received.
• Not cash or cash equivalents. A. That depends. Gestures like this can often act as courtesies
• Allowed to be reciprocated in accordance with our that strengthen business relationships. If it is modest in value,
company policy. done infrequently and unlikely to influence a business decision,
• Not creating an obligation on the recipient. then it is probably acceptable. However, if you and the supplier
• Not likely to inappropriately influence their business have been discussing new or more favorable business terms,
decision. then paying for his meal may be perceived as trying to influence
• Not taking advantage of our position with vendors and his decision. Any appearance of exchanging favors for preferential
other business partners. treatment must be carefully avoided.

See Preventing Bribery and Corruption.

Special rules apply when offering gifts, favors and
entertainment to government officials and employees of
state-owned entities. You should obtain advice from the We Live Our Values
Legal and Compliance Department or the Office of Ethics and
Compliance before offering any gift, favors or entertainment We delight our consumers with safe, high-quality, great-
to such individuals. tasting foods.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 21

 Living Our Values for
OUR CONSUMERS

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We are passionate about our business, our brands and our food. Our vision is
to enrich and delight the world with foods and brands that matter. Our purpose
is to nourish families so they can flourish and thrive. Both our vision and our
purpose drive our desire to provide high-quality, great-tasting foods for our
consumers.

This section covers some important standards to which we hold ourselves. In doing so,
we honor our founder’s dedication to nutrition and people’s well-being. The K Values
IN ACTION
DELIVERING ON QUALITY, SAFETY AND VALUE
We delight our consumers with high-quality, great-tasting foods. We are
committed to providing safe foods our consumers can trust. INTEGRITY
Show respect for and value all
individuals for their diverse
PROMOTING HONEST MARKETING PRACTICES backgrounds, styles, and ideas.
We show pride in our brands. We understand the importance of accuracy
and prudent transparency in advertising and packaging. ACCOUNTABILITY
Personally commit to the
PROTECTING CONSUMER DATA success and well-being of
We respect the privacy of all individuals. We take the necessary and teammates.
legally required precautions to protect personal data.
PASSION
Promote a positive, energizing
ACCOUNTABILITY and fun environment.
Keep promises and commitments made to others.
HUMILITY
PASSION Value openness and curiosity to
Delight our consumers and serve our customers through the high quality learn from anyone, anywhere.
of our products and services.
SIMPLICITY
Deal with people and issues
SIMPLICITY directly and openly.
Seek to continually simplify and improve processes, procedures and
activities. SUCCESS
Help people to be their best
by providing coaching and
feedback.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 23

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Delivering on Quality, Safety and Value

HOW We Do What’s Right • Immediately report any threats to consumer safety so that
appropriate and prompt action can be taken.
We delight our consumers with great-tasting, high-quality
foods. We are committed to providing safe foods our For more information or guidance, contact the Office of Ethics
consumers can trust. and Compliance.

WHY It Matters
Our reputation is inside every package of food we produce If in doubt, ASK!
and sell. We’re proud that our consumers expect more from
our brands. We are invited to the table every day and around Q. I noticed a strong, unusual odor near the packing line during
the world, so we ensure our consumers can trust the quality production of a high-priority innovation project. My coworker
and safety of our foods. didn’t notice the odor and encouraged me to continue with the
run. I don’t want to be the cause of missing a tight deadline for
WHAT It Means this important project. What should I do?

To meet or exceed our consumers’ expectations, we: A. Making safe food that meets our quality standards is our
top priority. An unusual odor identified during production or
• Ensure that our products are produced in an environment packaging could negatively impact the taste or odor of the
that promotes food safety and quality as top priorities. finished product. In some instances, this could even harm a
• Take personal accountability for our success by reporting consumer. We need to make tough calls and report these types
or addressing any quality or food safety issue immediately. of incidents to our supervisor immediately for investigation.
• Never bypass quality controls or take shortcuts that
compromise the quality or safety of our foods.

Promoting Honest Marketing Practices

HOW We Do What’s Right • Comply with all laws and regulations.

We show pride in our brands. We understand the importance of For more information or guidance, contact the Legal and
accuracy and appropriate transparency in advertising and packaging. Compliance Department.

WHY It Matters
Our consumers are at the heart of everything we create. They If in doubt, ASK!
trust our foods and how we portray them. We must continue
to earn that trust every day. Q. I’m on a deadline to get advertising copy into a small online
publication. My approach is exciting. I’m going in a new direction
We strive to maintain high ethical standards when marketing
and have seen a draft food science report that supports my
our foods. We truthfully and accurately represent our
product claims. As it’s not a major media outlet, can I go ahead
products and avoid misleading consumer communications.
without having the final report confirming the claims?

WHAT It Means A. No. We demonstrate integrity by ensuring that all advertising

We must: claims are substantiated. This is done in advance of their
publication or broadcast, whether it’s in print, online or through
• Market our foods in a manner that is truthful and not any other media. Fair and accurate advertising must comply with
misleading. the law, and it’s something our consumers count on.
• Ensure that every claim in our advertisements and
marketing materials is substantiated as required by law.

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Protecting Consumer Data

HOW We Do What’s Right
We respect the privacy of all individuals. We take the
If in doubt, ASK!
necessary and legally required precautions to protect Q. We have a great new product we know is going to be a big hit
personal data. and want to tell people about it. We have engaged a marketing
vendor who has a list of email addresses of prospective
WHY It Matters consumers. Can we use the list for our marketing campaign to
We are committed to keeping personal information private. get the word out?
Our consumers demonstrate their trust in us when sharing
their personal information. We must maintain that trust by A. Maybe. It depends on the applicable legal requirements. Most
protecting the privacy and security of this information. countries have rules about whether and how email addresses
can be collected, whether and what type of consent is needed

WHAT It Means from consumers to receive email, and when and how you can use
emails for marketing purposes.
We ensure consumer data is protected by:
• Always handling personal data responsibly and following all
applicable privacy laws and company privacy and security
policies.
• Collecting, using and processing personal data only for We Live Our Values
legitimate business purposes.
• Never releasing the personal information of others to We compete vigorously and with integrity. We partner with
anyone within Kellogg who does not have a clear business those who demonstrate our values.
need to know and authorization to receive the information.
• Never releasing the personal information of others to third
parties without a current contract with respect to such
information or a legal requirement to do so.

For more information or guidance, contact our Legal and

Compliance Department.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 25

 Living Our Values in
OUR MARKETPLACE

Section 2
Opener (Photo?)

26
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We compete in the global marketplace with integrity and purpose. Our

consumer-driven insights fuel our innovations and our quest to expand our
global reach. We look beyond the horizon to meet evolving needs in more
ways and more places. We embrace our truly global future while honoring
our founder’s century-old legacy of quality and foods that delight.

We do this by maintaining strong relationships with the business partners who support
us. We seek business relationships based on trust, fairness and mutual advantage. This is The K Values
especially important as we expand into new global markets. We hold our business partners
and their employees, representatives and subcontractors to the same high standards of IN ACTION
business integrity to which we hold ourselves.

This section of the Code provides guidance in the following areas: ACCOUNTABILITY
Focus on finding solutions and
achieving results.
DOING BUSINESS GLOBALLY
We are a global company doing business around the world and committed PASSION
Delight our consumers and
to complying with applicable laws that govern international trade. serve our customers through
the high quality of our products
FAIR COMPETITION and services.
We seek to outperform our competitors fairly and honestly. This means HUMILITY
achieving competitive advantage through superior performance and Never underestimate our
never through unethical or illegal business practices. competition.

COMPETITIVE INTELLIGENCE SUCCESS

Make the tough calls.
We strive to understand our customers, our suppliers and the value
proposition of our competitors. This helps us to understand our global
marketplace and to advance our business objectives.

FAIR PURCHASING
We select business partners fairly and objectively. This ensures the best
value for Kellogg while protecting our reputation.

BRIBERY & CORRUPTION

We base our business relationships on trust, transparency and
accountability. We never offer or accept any form of payment or incentive
intended to improperly influence a business decision.

OTHERS’ INTELLECTUAL PROPERTY

We safeguard others’ intellectual property as we do our own.

RESPONSIBLE SOURCING & HUMAN RIGHTS

We do business only with business partners who always obey the law and
operate fairly and ethically.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 27

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Doing Business Globally

HOW We Do What’s Right
We are a global company doing business around the world
If in doubt, ASK!
and committed to complying with applicable laws that govern Q. I’m investigating new international markets. How can I find
international trade. out where I am and am not permitted to do business?

WHY It Matters A. Contact the Legal and Compliance Department for

As Kellogg does business in more than 180 countries around information on countries and persons affected by U.S. or other
the world, we are subject to numerous international trade relevant country sanctions and restrictions. We value, promote
laws. These laws can affect our ability to sell foods to and and fiercely protect our reputation throughout the world.
conduct business with certain countries and individuals. The
laws are also complicated and change frequently, sometimes Unfamiliar Invoice Charges
on a daily basis. Penalties for violations can be severe, Q. While reviewing an invoice from one of our foreign freight
including fines, revocation of permits or even imprisonment. vendors, I noticed a couple of unfamiliar charges, including a
We must take particular care in relation to import and export “consultant fee” and a “handling fee.” When I asked the vendor
controls, trade sanctions and boycotts. about this, I was told that these costs were necessary in the
receiving country in order to ensure the processing and release

WHAT It Means of our products. At under $50, the charges were small. Can I
authorize payment?
If you are involved in the sale, marketing, distribution or
transportation of products or services, or the transfer of A. No. You should never authorize payments for items or
technology across international borders, you must: services that are not clearly defined and were not previously
or contractually agreed upon. If you notice any such charges or
• Be familiar and comply with all applicable laws and discrepancies in payment terms, you must report them to the
company policies regarding international trade restrictions. Legal and Compliance Department right away.
• Notify the Legal and Compliance Department if you receive
any requests from customers, suppliers or others to
participate in a boycott against individuals, companies or
countries.
• Seek guidance from the Legal and Compliance Department
Red Flags and Things to Watch for
if you have a concern about a trade-related issue. Regarding Boycotts
Contract language or business documents that:

• Reference “The Arab League.”

• Contain prohibitions on dealing with Israel or any other
country.
• Appear to discriminate against a specific race, religion,
gender or nationality.
• Seek information about business relationships with Israel
or any other country.
• Seek information about business relationships with
“blacklisted countries.”
• Request that a transaction be structured to avoid certain
countries or regions.

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Promoting Fair Competition

HOW We Do What’s Right • Immediately contact the Legal and Compliance
Department if a competitor attempts to discuss any topic
We seek to outperform our competitors fairly and honestly. listed above.
This means achieving competitive advantage through superior • Conduct all relations with competitors, including social
performance and never through unethical or illegal business activities, as if they will be scrutinized by the government.
practices.
In relation to customers and suppliers, we:
WHY It Matters
• Do not offer or accept bribes or kickbacks.
We compete for business aggressively but always honestly. • Never agree to establish the resale price of a product or
We believe in free and open competition that is vigorous, to condition the sale of Kellogg products on the purchase
ethical and merit-based. We recognize that laws that regulate of other Kellogg products without approval from the Legal
competition and trade practices vary around the world. and Compliance Department.
However, we never engage in certain activities, such as price • Refuse to bill sales to third parties at prices exceeding the
fixing, agreeing with a competitor to allocate customers or established price for the product. This prevents overbilling
territories, and bid rigging. and possible rebate abuses.
We comply with all applicable laws, rules and regulations • Ensure that prizes provided in sales promotions and
that govern the way companies compete. These include contests are won legitimately. This means achieving criteria
laws designed to foster free and fair competition. Even the specified in advance and made available to the entire class
appearance of improper agreements with competitors can of contestants.
harm our reputation and risk legal action. So we approach • Do not misrepresent product and price attributes or make
competitor interactions carefully and strive to avoid even the false claims about competitors’ offerings.
appearance of impropriety. • Do not discuss our terms of dealing with rivals of a
customer.
Antitrust/competition laws are complex and vary from
country to country. Proven violations carry significant fines For more information or guidance, contact the Legal and
and even imprisonment. They will also result in company Compliance Department for guidance.
discipline up to and including termination of employment.

WHAT It Means If in doubt, ASK!

In relation to our competitors, we:
Q. I was recently at a trade association meeting and overheard
• Never discuss or reach agreements about any aspect of one of our competitors talking about their pricing strategy. I
the following without written approval from the Legal and immediately left the room. Was that the right thing to do?
Compliance Department:
■
Pricing or price formulas A. Yes. Removing yourself from the meeting reduces the risk that
■
Territories someone might think you were trying to fix prices or engage in
■
Markets other inappropriate activity. Contact the Legal and Compliance
■
Contracts Department immediately to report the incident and to receive
■
Production instructions. And don’t share the information with anyone
■
Customers else unless told otherwise. While we never underestimate our
■
Suppliers competition, we always demonstrate a commitment to integrity
■
Competitors and ethics in the marketplace.
■
Inventory
■
Costs
■
Capacity

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Gathering Competitive Intelligence

HOW We Do What’s Right WHAT It Means
We strive to understand our customers, our suppliers and When gathering competitive intelligence, we act with integrity
the value proposition of our competitors. This helps us to by:
understand our global marketplace and to advance our
business objectives. • Using information from public sources. This includes
advertisements, published articles, public records and
WHY It Matters brochures offered by competitors at trade shows.
• Never misrepresenting ourselves or using illicit means to
We are committed to pursuing innovative ideas that will move secure information.
us forward. In today’s highly competitive global marketplace, • Never seeking proprietary information about other
understanding our competition is increasingly important. companies from job applicants or Kellogg employees who
While we may develop strategies based on information about previously worked elsewhere.
our competitors and their products, we always obtain and • Never accepting, sharing or using any information that may
make use of this competitive intelligence legally and ethically. have been gathered improperly.
We treat competitors’ proprietary information as we would • Respecting requests for confidentiality from our business
want them to treat ours. partners.
• Purchasing a competitor’s product to analyze its qualities.

For more information or guidance, contact the Legal and

Compliance Department or Office of Ethics and Compliance.

Promoting Fair Purchasing Practices

HOW We Do What’s Right • Treat all our suppliers and business partners with fairness
and integrity. We do this regardless of the value of the
We select business partners fairly and objectively. This transaction or the length of the relationship.
ensures the best value for Kellogg while protecting our • Select suppliers who best meet our business needs and
reputation. objectives while being mindful of our commitment to
diversity in our supplier base.
WHY It Matters • Base our decisions on objective criteria such as quality,
price, service, reliability, availability, technical excellence
Our reputation depends upon the quality, taste and and delivery as well as ethical business practices.
dependability of the foods we make. We can count on • Avoid conflicts of interest or the appearance of them.
trustworthy partners to provide the ingredients and other These can raise questions about our ability to exercise
support we need reliably, safely and at a fair price. independent judgment on our company’s behalf.
• Do not accept from business partners anything other than
WHAT It Means nominal gifts, favors and entertainment (see Avoiding
Conflicts of Interest).
Those of us involved in purchasing and relationship
• Ensure all suppliers comply with our Global Supplier Code
management with business partners should follow these
of Conduct.
important guidelines:

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Promoting Fair Purchasing Practices, continued

If in doubt, ASK!
Q. Is Kellogg obligated to award its business to the lowest bidder
who responds to a request for proposal (RFP)??

A. Not necessarily. To be sure, we always seek the best possible

pricing when choosing among suppliers. However, there are
other important considerations in an RFP selection process. For
example, we want to do business with suppliers who share our
commitment to quality and integrity. In some circumstances, we
may determine that we need to pay more to ensure that level of
supplier commitment.

Preventing Bribery and Corruption

HOW We Do What’s Right be no safe alternative to making a payment in such cases. If
possible, contact the Legal and Compliance Department first.
We base our business relationships on trust, transparency and If not, you should do so as soon as is practical afterward.
accountability. We never offer or accept any form of payment
or incentive intended to improperly influence a business WHAT It Means
decision.
We prevent bribery and corruption by:
WHY It Matters • Never offering, promising or giving anything of value to
Kellogg prohibits all forms of corruption (including bribery, a government official or anyone else to gain a business
kickbacks and fraud). They harm not only our company and its advantage.
reputation, but also the communities where we do business. • Never offering or accepting bribes or kickbacks.
Many of the countries where we do business have stringent • Recording all payments and receipts completely and
laws against corruption. We do not tolerate corrupt practices accurately.
in our business anywhere in the world. • Never making improper payments—either on our own or
via third parties.
This position aligns with the law. But it also protects our
• Avoiding facilitating or “grease” payments. These are
reputation and enhances our stakeholders’ confidence in our
generally prohibited even if they are legal under local laws.
management practices.
• Following Kellogg policies related to giving and receiving
Corruption is the abuse of entrusted power for personal gain. gifts and entertainment.
A bribe occurs when someone gives or promises another • Only covering proportionate, reasonable, bona fide
person something of value to obtain favorable treatment. hospitality and business expenditures.
Kickbacks involve giving or receiving personal payments as
a reward for the awarding of a contract or other favorable See Gifts and Entertainment.
outcome. Bribes and kickbacks of any kind are unethical,
violate our Code and are illegal. For more information or guidance, contact the Office of Ethics
and Compliance.
In exceptional cases, employees may face the imminent
threat of physical violence or duress. We recognize there may

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Preventing Bribery and Corruption, continued

Example of a Bribe Red Flags and Things to Watch for When
Working with Third Parties
If a customer gives cash or other consideration to a
company employee to get the employee to fulfill the • Refusal to agree or adhere to our Global Supplier Code
customer’s order ahead of other customers’ orders, that’s of Conduct.
a bribe. • Not following laws or operating without required
environmental permits.
Example of a Kickback • Refusal to certify compliance with anti-corruption
requirements.
If a supplier pays an employee a percentage of the • Refusal to disclose relationships or interests involving
supplier’s sales to the company in return for the government officials.
employee’s assistance in steering business to the supplier, • The third party is related to a government official.
that’s a kickback. • The country has a reputation for corruption and bribery.
• Requests for commissions to be paid in a third-party
country, to a third party, or in cash or untraceable
funds.
If in doubt, ASK! • Heavy reliance on third party in political or government
contacts instead of on knowledgeable staff to promote
our company’s interests.
Q. During a company social event, a local government • Nonspecific description for payments made in
representative approached me. Her office had approved our
accounting entries.
operating permits, and she expressed her delight at having
• Documents conceal the true identify of an in-country
Kellogg operating in her region. She then handed me an envelope
representative or agent.
containing the curriculum vitae of her nephew. She said, “Many
• Payment descriptions that do not correspond to the
of our young people are having a hard time finding jobs in our
appropriate account.
economy, and I thought you might be able to help. Of course,
• General purpose or miscellaneous accounts that can be
you are under no obligation.” I reviewed it, and her nephew is
used to hide improper payments.
qualified for several open positions. What should I do?
• Over-invoicing or false invoices.
A. Contact the Legal and Compliance Department immediately.
Situations like this need to be handled with care to avoid harmful
legal repercussions.

What is a facilitating payment?
Facilitating payments are typically small payments
made to government officials to expedite or secure a
nondiscretionary, routine government action. By contrast,
paying government taxes, fees and other legally required
charges would not be considered a facilitating payment.

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Safeguarding the Intellectual

Property of Others
HOW We Do What’s Right • Following all applicable intellectual property laws.
For more information or guidance, contact the Legal and
We safeguard others’ intellectual property as we do our own. Compliance Department for guidance.

WHY It Matters
We understand that unauthorized copying of others’ If in doubt, ASK!
protected works is impermissible and may create financial
and legal liability for Kellogg. If we want to use the intellectual Q. May I use information I learned from my former employer in
property belonging to someone else, we will obtain the my new role with Kellogg?
necessary authorizations.
A. Maybe not. If that information is not generally known outside
WHAT It Means of your former employer and would give Kellogg a competitive
advantage, that information is very likely a trade secret. You may
We safeguard the intellectual property of others by: face civil and criminal prosecution if you disclose it. Check with
the Legal and Compliance Department for guidance on what
• Respecting others’ trademarks, logos, names, designs and types of information can and cannot be used in your new role.
copyrights in our advertising, marketing and related materials.
• Respecting others’ patent rights, trade secrets and
proprietary information as we innovate internally and work
with our partners.

Sourcing Responsibly and Protecting

Human Rights
HOW We Do What’s Right WHAT It Means
We do business only with business partners who always obey Doing the right thing ourselves also means being vigilant and
the law and operate fairly and ethically. setting the right example in our business dealings with other
companies.
WHY It Matters • If you deal with current or prospective suppliers, ensure
their business practices comply with our Global Supplier
Kellogg embraces its responsibilities as a global corporate Code of Conduct.
citizen in an increasingly interconnected world. We act with • Report to the Office of Ethics and Compliance any concern
integrity and show respect, and we expect the same of those that a Kellogg business partner may be operating illegally
who want to do business with us. We expect our business or unethically. Do this whether or not there’s an imminent
partners to act ethically and protect the rights of all workers. risk to the company’s business or reputation.
We are committed to responsible and sustainable sourcing and
expect the same commitment from our business partners.
We are committed to maintaining an ethical and transparent supply We Live Our Values
chain free of forced labor, including slavery and human trafficking.
We are a preferred investment because we deliver the
Our position on human rights is compatible with the United present while creating the future.
Nations Universal Declaration of Human Rights and the core
conventions of the International Labour Organization.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 33

 Living Our Values for
OUR INVESTORS

Section 2
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W.K. Kellogg saw a better way. He saw how to shape our industry through a
passion for people and the goodness of food. Every day, we take the steps
that show the way. And along the way, our investors put their trust in us to
deliver sustainable performance and create long-term value. We maintain
that trust by always being honest, open and reliable.

In this section of the Code, we will explore:

The K Values
ACCURATE RECORDS AND ACCOUNTS IN ACTION
We maintain complete and accurate records. We do so to make
responsible business decisions and provide truthful, timely information to INTEGRITY
the investing public and various governments. Demonstrate a commitment to
integrity and ethics.
OUR REPUTATION AND OTHER ASSETS
ACCOUNTABILITY
We protect Kellogg Company’s reputation and other tangible and Focus on finding solutions and
intangible assets. We do so to better serve our consumers and preserve achieving results.
value for our investors and other stakeholders.
PASSION
Value, promote and fiercely
PROPRIETARY AND CONFIDENTIAL INFORMATION protect our reputation.
We safeguard Kellogg Company’s proprietary and confidential business
information against unauthorized disclosure and misuse. SUCCESS
Have a “can-do” attitude and
drive to get the job done.
EQUIPMENT AND INFORMATION AND COMMUNICATION
SYSTEMS
We use company equipment and information and communication
systems responsibly.

INSIDER TRADING AND MARKET ABUSE

We never use or disclose material, nonpublic information about Kellogg
or another company for the purpose of buying or selling securities. Nor
do we ever attempt to manipulate the price of publicly traded securities.

INVESTOR AND MEDIA INQUIRIES

At Kellogg, we speak with one voice when communicating to the media,
financial analysts, investors and the public.

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Creating and Maintaining

Accurate Records and Accounts
HOW We Do What’s Right
Trade Loading or Channel Stuffing Is
We maintain complete and accurate records. We do so to Prohibited by Company Board Resolution
make responsible business decisions and provide truthful
and timely information to the investing public and various These practices, which involve inducing customers to
governments. purchase more product than is reasonably necessary for
their resale needs, are prohibited
WHY It Matters
Business and financial records are essential to our business
operations. We rely on the integrity and accuracy of those
records. This matters for both internal decision-making and
the benefit of investors, government agencies, regulators and
others to whom we report. Accurate and transparent record
keeping protects our reputation, promotes organizational
efficiency and helps us to meet our legal and regulatory
obligations.

WHAT It Means
We have a responsibility to ensure the integrity, accuracy and
effectiveness of our record keeping. We do so in the following
ways:

• Record all assets, liabilities, revenues, expenses and

business transactions completely, accurately, in the proper
period and in a timely manner.
• Ensure that records and accounts conform to generally
accepted accounting principles and our internal controls
system.
• Never set up or maintain for any purpose cash funds, other
assets or liabilities that are secret or unrecorded.
• Do not participate in “trade loading” or “channel stuffing.”
• Use thoughtful, appropriate and accurate wording when
creating records. This means stating just the facts and
avoiding exaggeration, colorful language, guesswork,
conclusions beyond your expertise and derogatory remarks
about others.
• Never conceal or destroy documents or records that
are subject to investigation or may be used in an official
proceeding.
• Maintain and destroy company records in compliance
with our records management and retention policy, and
litigation hold protocol.

For more information or guidance, contact the Office of Ethics

and Compliance.

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Safeguarding Our Reputation

and Other Assets
HOW We Do What’s Right Our Company Assets

We protect our reputation and other tangible and intangible
assets. We do so to better serve our consumers and preserve We must take care and use good judgment in relation to the
value for our investors and other stakeholders. following types of assets:

WHY It Matters Information assets: Any data relating to Kellogg’s business,

irrespective of how it is created, distributed, used or stored.
Kellogg assets are essential to running our company profitably
and successfully over the long term. We all share the Financial assets: The company’s money, financial
responsibility to be good stewards of those assets. This means instruments and anything that can be converted to money.
taking care to avoid loss, damage, waste and improper use.
Physical assets: Anything of a tangible nature provided
WHAT It Means by the company to employees for use in conducting
Kellogg’s business. They include computers, mobile phones,
We are good stewards of Kellogg assets by: materials, tools, machinery, company vehicles, office
equipment and supplies.
• Safeguarding Kellogg assets entrusted to us personally or
to which we have access. Intangible assets: Things such as our reputation; ideas;
• Taking reasonable care to prevent loss, damage, inventions; improvements; intellectual property; registered
destruction, theft, unauthorized or improper use, or waste and unregistered copyrights; trademarks; patents; and
of Kellogg assets. service marks or trade secrets conceived, developed or
• Protecting, securing, retaining and destroying Kellogg practiced.
information in accordance with corporate or local company
requirements.
• Safeguarding data from unauthorized access, modification,
duplication, destruction or disclosure, whether accidental
or intentional.
• Protecting both nonpublic and publicly available company
information in which Kellogg has intellectual property
rights.
• Using or authorizing the use of any Kellogg asset only
for Kellogg business purposes, regardless of condition or
value.
• Never taking, selling, lending, borrowing, giving away or
disposing of Kellogg assets without proper authorization.
• Reporting any concerns about the use, abuse or
endangerment of Kellogg assets to Corporate Security.

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Protecting our Proprietary and

Confidential Information
We must safeguard Kellogg’s proprietary and confidential
business information against unauthorized disclosure and misuse. What Is Confidential Information?
Proprietary information that Kellogg owns is a valuable asset. • Information that Kellogg owns such as proprietary
This is especially true of confidential business information. information like recipes, formulas, etc.
Our company’s proprietary information, especially our • Trademarks, patents, trade secrets and other intellectual
intellectual property, is vitally important in helping us develop property
new products and markets, attracting new customers and • Nonpublic financial information or projections
consumers, and maintaining our competitive advantage. • New product or marketing plans
• Research and development ideas or information
We must all help protect our confidential information by: • Manufacturing processes
• Detailed procurement information
• Limiting access to confidential information to those whose • Salary data
jobs require it. • Employee lists
• Not talking about confidential information in public areas. • Information concerning potential acquisitions,
These include planes, elevators and restaurants, whether divestitures and investments
talking in person or on mobile phones. • Legal opinions and work product
• Not working in a public place when there’s a risk of such
information being viewed by others.
• Never using confidential information for personal gain or
to benefit anyone outside of Kellogg.
• Remembering that the obligation to protect the company’s
confidential information continues after leaving Kellogg.

For more information or guidance, contact the Legal and

Compliance Department.

If in doubt, ASK!
Q. Recently, I was having dinner at a restaurant with my old college
roommate. As we were catching up, he asked me which company I
work for. I proudly told him I work for Kellogg. He immediately told
me about all the great Kellogg products he grew up consuming. In my
excitement over his excitement, I mentioned a few of the great new
products we will be launching in a few months. I told him not to tell
anyone, and he promised he wouldn’t. Was this okay?

A. Probably not. Unless the new products you mentioned had

been previously announced by official company representatives,
you inadvertently divulged confidential company information.
It is great to see your passion for our brands and products.
However, we must always be careful about keeping confidential
information to ourselves. In addition, you discussed confidential
company information in a public place where you may have been
overheard. Contact the Office of Ethics and Compliance so we
can discuss next steps and develop a path forward.

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Using Equipment, Information and

Communications Systems Responsibly
We use company equipment, information and communication • Malicious software or instructions for compromising the
systems responsibly. company’s security.

We all must be responsible in our use of the company’s For more information or guidance, review the IT Acceptable
information and communications systems. By using the Usage Policy or contact the IT Department.
security controls and measures established by Kellogg, we
protect company information and data from accidental or
unauthorized disclosure, misuse, improper alteration or
destruction. Company information stored on company-issued
If in doubt, ASK!
removable media, such as flash drives, must be encrypted
by our IT Department. Storage of company information on
Q. I recognize that malware is a huge problem. After doing
some research on my own, I’ve discovered a free application that
personal removable media is not permitted.
protects computers from malware. I’ve loaded it on my home
computer, and it works. Can I load it on my company computer?
Personal use of company telephones, computers, faxes, photocopiers
and network bandwidth is acceptable if it is incidental, infrequent
and permitted under local Kellogg policy. This privilege
A. No. Kellogg IT uses professional-grade software that has
been tested for our IT environment. Feel free to contact the IT
must not be abused. The same principle applies to use of
Department with your suggestions. But do not load unauthorized
our personal wireless devices during working hours because this
software on your company computer.
potentially reduces bandwidth as well as productivity.

Personal use of company equipment is not acceptable if it:

DO DON’T
• Significantly reduces the value of Kellogg assets. • Use company electronic mail • Assume that an inappropriate
systems for business purposes only. Internet site is okay to access if
• Incurs significant additional costs to the company. • Store only business-related it has not been specifically
• Places company information at risk. material on Kellogg computers or blocked by filtering software.
• Interferes with our productivity. Kellogg issued data storage devices • Hide, misrepresent, replace or
such as CDs, DVDs and flash drives. obscure your identity
• Violates Kellogg policy • Confirm the legitimacy of social while Internet browsing, posting
• Places Kellogg at risk of liability. networking contacts before or sending email.
trusting them with any information. • Share passwords to email
• Send electronic communications accounts.
We recognize that we have no reasonable expectation (such as forwarding messages or • Use personal email and
of privacy when using company-provided services and meeting invitations) only to noncompany electronic mail
equipment. We understand that the company reserves the those individuals with a business systems to conduct Kellogg
need for the information. business.
right to inspect its facilities and property in accordance with • Use a valid company email • Send anonymous electronic
local laws and Kellogg policy. This includes but is not limited to address in the message communications unless
computers, telephone records, lockers, email, Internet usage, “FROM”field. Disguised/ they are company-sanctioned
misrepresented/spoofed email (e.g., newsletters).
business documents, offices and other workspaces. addresses are prohibited. • Use a Kellogg domain address
• Include a legal disclaimer notice (e.g., @kellogg.com) to send
We strictly prohibit the use of Kellogg systems (including email, for all externally bound emails. email from systems not operated
• Use the “Delegate Access” by Kellogg.
instant messaging, the Internet or intranet) for activities that option in the email application if • Ask recipients to use a non-
are unlawful, unethical or otherwise contrary to this Code or access is required by another Kellogg email address as a
company policy. Usage will always be inappropriate if it involves: user, such as an administrative contact when using the “out of
assistant. office” function.
• Contact IT Security if you believe • Send security alerts. Only the
• Pornographic, obscene, offensive, harassing or that confidential information has IT Security team is authorized
discriminatory content. been released. to send security alerts.
• Use careful communications,
• Chain letters, pyramid schemes or commercial ventures. stick with the facts and avoid
• Gambling, auctions or games. exaggerations or opinions that
• Large personal files containing graphic or audio material. are outside of your area of
expertise.
• Unauthorized mass distributions.
• Violation of others’ intellectual property rights.

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Avoiding Insider Trading and

Market Abuse
HOW We Do What’s Right
What Is “Inside” Information?
We never improperly disclose material, nonpublic information
about Kellogg or another public company. We do not trade in Material, nonpublic or “inside” information is information
securities of Kellogg or other public companies based on that about any company that has not been made publicly
information. Nor do we ever attempt to manipulate the price available. It is also information that a reasonable investor
of publicly traded securities. would consider important when deciding to trade in the
securities of that company.
WHY It Matters Some examples include:
• Many of us have access to information about Kellogg that
may not be known to the public. This is known as “inside • Company financial results and dividends
information.” • Significant management changes
• Trading based on inside information is illegal, as is tipping • New business relationships
others to inside information so that they can trade based • New product launches
on it. Enforcement is rigorous and penalties are severe. • Important developments in litigation
• We support fair, open securities markets. We strive to • Anticipated mergers, acquisitions or divestitures
preserve Kellogg’s reputation as a company that can be
trusted to deal honestly, everywhere we do business.

WHAT It Means If in doubt, ASK!

We can help prevent insider trading and market abuse in the Q. How does the guidance on insider trading affect my purchase
following ways: of Kellogg stock?
• Never trade in Kellogg securities when you are in
possession of inside information. A. Our employees, officers and directors are encouraged to
• If you acquire inside information of any other public invest in Kellogg by purchasing company stock. We may purchase
company, do not trade its securities. Kellogg securities and exercise options granted to us if we are not
• Never buy or sell securities until the inside information you aware of material inside information. Board members, executive
have becomes generally available and investors have had a officers and certain other individuals are subject to blackout
chance to evaluate it. periods during which they are prohibited from trading in Kellogg
• Do not disclose inside information to anyone outside stock.
Kellogg, including family members, relatives or friends.
• Only share inside information with fellow employees on a
“need-to-know” basis.
• Take care to protect inside information from accidental disclosure.
• Avoid even the appearance of trading on inside
information. Do this by refusing to engage in “short sales”
or trade in puts, calls or other derivatives on Kellogg stock.
• Do not engage in “tipping.” This means providing inside
information about a company to anyone who may trade in
that company’s securities.
• Do not encourage others to trade on inside information.
• Never spread false information or do anything to
manipulate the price of publicly listed securities.

For more information or guidance, contact the Legal and

Compliance Department.

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Responding to Inquiries from Investors,

Analysts and the Media
HOW We Do What’s Right • Be friendly and courteous.
• Not speak or share information about Kellogg.
At Kellogg, we speak with one voice when communicating • Refer the inquiry, as appropriate, to Corporate
with the media, financial analysts, investors and the public. Communications through our Media Hotline or to Investor
Relations.
WHY It Matters
For more information or guidance, contact Corporate
Our customers, consumers and investors deserve clear, Communications or Investor Relations.
complete and consistent communications about Kellogg.
Only employees who are specifically trained and authorized
to do so should represent Kellogg to the public or the media.
This ensures that we comply with the law and protect our
We Live Our Values
interests.
We use natural resources responsibly and support our
communities.
WHAT It Means
If you receive an inquiry from outside the company and are
not authorized to respond, you should:

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 41

 Living Our Values in
OUR COMMUNITIES

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Every day, we manufacture and sell our foods globally. We embrace our
role as a global corporate citizen, take our environmental responsibilities
seriously and are honored to contribute to the communities where we work
and live. We look for opportunities to create even better days and brighter
futures for our consumers, employees, communities and environment
everywhere we do business.

How we live the K Values and hold ourselves to the standards in this Code will define the
contribution we make to our communities and society. This section of the Code focuses on The K Values
the following areas:
IN ACTION
PROTECTING THE ENVIRONMENT
We are committed to building a more sustainable society. This means PASSION
Show pride in our brands and
minimizing our environmental footprint and developing solutions that heritage.
conserve resources and protect our planet.
HUMILITY
CONTRIBUTING TO OUR COMMUNITIES Value openness and curiosity to
learn from anyone, anywhere.
We are committed to supporting the communities where our employees
live and work. We also explore ways to address broader challenges in SIMPLICITY
society. Seek to continually simplify and
improve processes, procedures
and activities.
POLITICS AND GOVERNMENT AFFAIRS
We encourage our employees to participate in the political process as SUCCESS
active citizens. As a company, we engage constructively with governments Make people feel valued and
appreciated.
where we operate.

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Protecting the Environment

HOW We Do What’s Right WHAT It Means
We are committed to building a more sustainable society.
We must all contribute to our company’s environmental
This means minimizing our environmental footprint and
stewardship efforts in the following ways:
developing solutions that conserve resources and protect our
planet.
• Comply with all applicable environmental laws and
company policies.
WHY It Matters • Meet the requirements of all environmental permits.
Kellogg has been committed to good stewardship of the • Report to management any spills, leaks or unauthorized
environment since our founding more than 100 years ago. discharges.
Today, it is widely agreed that humankind is using the Earth’s • Be vigilant to ensure we do not use more energy or water
natural resources faster than they can regenerate. And that than necessary.
means that everyone needs to play a part in building a more • Ensure that our suppliers and business partners follow
environmentally sustainable society. agreed-upon environmental standards.
• Minimize waste and recycle or find appropriate alternate
We have conducted a social and environmental sustainability uses for waste materials.
assessment for our entire value chain to better understand • Take personal actions such as turning off lights, using less
risks and set priorities. We work with our growers and paper, shutting off electronics and recycling. These small
processors to optimize inputs and limit environmental actions can make a big difference.
impact without compromising quality. Inside the company,
we focus on reducing our energy and water usage as well To learn more about our environmental initiatives, review our
as greenhouse gas emissions. This includes using either Corporate Responsibility Report.
100-percent recycled paper fiber or certified sustainably
grown material for our packaging. It also involves increasing
the number of our zero-waste-to-landfill facilities.

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Contributing to Our Communities

HOW We Do What’s Right • Honor our K Values and uphold the standards in our Code.
This ensures that we always conduct our business ethically
As a leading global food company, Kellogg is driving and in accordance with the law.
transformational change by addressing the issue of food • Make sure that outside activities do not interfere with our
security. This includes supporting the communities where our job performance or create a conflict of interest.
employees live and work, with an emphasis on hunger relief. • Obtain proper approval before donating company funds or
making contributions in Kellogg Company’s name.
WHY It Matters • Verify that company charitable contributions comply with
applicable laws.
Our founder, W.K. Kellogg, was not just a great entrepreneur. • Never pressure others to contribute to charitable
He was also a leading philanthropist, early conservationist and organizations or other community causes.
the original well-being visionary. At Kellogg, we have a long
history of investing in our communities. We believe in giving
back in meaningful ways.
If in doubt, ASK!
We strongly encourage each of our employees to become
actively involved in their community by participating in Q. I regularly volunteer at a local homeless shelter. I know
initiatives that contribute to a better quality of life. We that Kellogg advocates for the hunger needs of children. Can I
encourage employees to support our communities by represent to the shelter that my service is being provided on
volunteering and participating in charitable activities and behalf of Kellogg?
professional development opportunities, such as serving on
nonprofit boards. A. Kellogg values and praises community involvement by our
employees. We encourage your involvement in social issues
WHAT It Means that the company supports. While you may represent yourself
as an employee of Kellogg Company, you must consult with
We can contribute positively to our communities and society Global Corporate Affairs before making any commitments to the
in the following ways: organization on behalf of the company.

Participating in Politics and

Government Affairs
HOW We Do What’s Right WHAT It Means
We encourage our employees to participate in the political Whether participating in the political process or engaging
process as active citizens. As a company, we will engage with governments, there are standards to which we must hold
constructively with governments where we operate. ourselves. These are covered below.

WHY It Matters
As a company, we believe that an active, inclusive and fair
political process promotes open government and healthy,
productive societies.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 45

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Personal Political Activity

Kellogg encourages individual participation in civic and
If in doubt, ASK!
political activities, including holding political office. Q. I am a volunteer for a political campaign. Because traffic
can be so bad after work, can I stay in the office and use my
Kellogg employees have the right to provide personal financial computer to work on some campaign materials?
support to candidates, political parties and other interest
groups of their choosing. They also have the right to run for A. No. While we support everyone’s right to participate in the
elective office and to interact with officeholders on their own political process, you act with integrity and show respect by using
time and in their personal capacity. However, employees your own resources and time for personal political activities.
must not engage in personal political activities during working
hours and may not use company resources for personal Q. I attended a conference and met an attendee who gave
political activity. me his business card. He works at a government agency that
is studying a new regulation that might impact our business
When engaging in personal political activities, it is important prospects in an important new market. Can I call him and ask to
to: set up a meeting?

• Make it clear that your political views and actions are your
A. In this situation, you should reach out to the Government
own, and not those of Kellogg. Relations Department to determine the right approach.
• Inform our Government Relations Department when
considering running for political office and following
your appointment or election. This will help to avoid any
potential conflicts of interest.
• Pay for all personal political activities from your own funds.
Kellogg does not reimburse employees for personal political
contributions or other expenses related to political activities.

Corporate Political Activity

Wherever we do business, we comply with federal, state and
local political campaign finance and election laws.

Kellogg may contribute to candidates, political parties, political

committees and ballot initiatives that reflect the interests
of Kellogg, as permitted by law. We also have a political
action committee, the Kellogg Company Better Government
Committee (KCBGC PAC). This is funded by personal, voluntary
contributions from eligible employees and supports candidates
aligned with our business objectives. KBCGC PAC complies with
all applicable laws, including disclosure requirements.

Employees may not make any direct or indirect political

contribution or expenditure on behalf of Kellogg or with
company funds unless permitted by applicable law and
approved in advance by the Legal and Compliance Department
and Government Relations Department. This applies to
contributions or expenditures in support of or opposition to
any political party, candidate, campaign or public official.
Political contributions or expenditures include:

• Buying tickets for a political fundraising event.

• Loaning personnel during working hours for fundraising
activities.
• Paying for advertisements and other campaign expenses.

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Lobbying Any engagement with government stakeholders requires

the involvement of the Government Relations Department.
Kellogg will never attempt to apply improper influence on any You must also obtain advice from the Legal and Compliance
government agency, representative or legislator to produce Department before offering or giving hospitality, gifts, favors
an outcome favorable to Kellogg. Lobbying is a legitimate and entertainment to a government official.
pursuit for companies, but it can involve many kinds of
activities that may require public disclosure and reporting See Gifts and Entertainment and Preventing Bribery and
requirements that are subject to specific rules. You may be Corruption.
engaged in lobbying if your work involves:

• Contacts with legislators, senior regulatory officials,

executive branch officials or their staffs.
• Government contract sales.
• Efforts to influence legislative or administrative action.

W.K. Kellogg: A Legacy of Integrity

Our company founder, W.K. Kellogg, invested in people, When we’re guided by values and not just rules, we
relationships and the promise of tomorrow. He leaves us a understand the how and the why, as well as the what. When
legacy of integrity—of doing business the right way. we see the bigger picture, we think more broadly. We think
beyond ourselves and beyond the limits of what any of us
• Other companies tried to strike the sharpest bargains with can do on our own. Our Code helps us support each other
their distributors. Mr. Kellogg instituted a practice to give in delivering today while creating a future that continues to
every distributor the same favorable arrangements. honor our founder’s legacy:
• During the Great Depression, finding meaningful
employment and taking care of your family’s needs was Our People
a daunting task. Mr. Kellogg reduced hours and created We act with integrity. We treat each other with fairness and
more shifts so more people could work and support their respect.
families.
• During a particularly profitable year, other corporate Our Consumers
leaders were focusing on amassing fortunes. Mr. Kellogg We delight our consumers with safe, high-quality, great-
invested his corporate profits in people. tasting foods.
• During his lifetime, Mr. Kellogg became one of the world’s
wealthiest men. He used his wealth to establish the Our Marketplace
W.K. Kellogg Foundation and better the lives of millions We compete vigorously and with integrity. We partner with
of people. Today, communities, families and children those who demonstrate our values.
worldwide continue to benefit from his generosity and
philanthropy. Our Investors
We are a preferred investment because we deliver the
Integrity can be defined as doing the right thing. Mr. Kellogg present while creating the future.
embodied this virtue. He taught that the best way to build
the promise of tomorrow is to stand on a solid foundation of Our Communities
values today. This legacy of integrity still guides our culture We use natural resources responsibly and support our
and our approach to business. It inspires us to live our values communities.
with every action we take on behalf of Kellogg Company—
everywhere, every way, every day.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 47

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Speaking Up and Seeking Guidance

We encourage everyone to speak up and seek guidance on
the topics covered in our Code. We have many resources You may contact the Office of Ethics and Compliance in
available to help, including: any of these ways:
Corporate Communications and Media Hotline: Ethics Line
+1-269-961-3799 Refer to the list of numbers on the next page.
email: [email protected] Email
General Counsel: [email protected]
email: [email protected] Mail
Global Corporate Affairs Office of Ethics and Compliance
Government Relations Department Kellogg Company
Information Security One Kellogg Square
Internal Audit P.O. Box 3599
email: [email protected] Battle Creek, MI 49016-3599
Human Resources Department (myHR): Web
Url: https://sts.kellogg.com/my.policy https://www.tnwgrc.com/Kellogg
Investor Relations:
Email: [email protected]
IT Department
Legal and Compliance Department:
Email: [email protected]
Url: https://www.tnwgrc.com/Kellogg

Ethics Line
Our Ethics Line offers a confidential way to address your
questions and concerns in relation to ethics, compliance or
any other requirements in our Code.

The Ethics Line is operated for Kellogg by a third-party,

confidential reporting company. It is available for you anytime
day or night, every day of the week.

If you would like to use the Ethics Line, please call the number
below that corresponds with your location. Your call will be
answered in your local language. The operator will listen to
your concern or inquiry, ask questions, then write a summary
report of the call. The summary will then be provided to the
Office of Ethics and Compliance for assessment and further
action, as appropriate.

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Ethics Line Global Access Numbers

Country/Provider Access Code Toll-Free Number
Australia – Telstra 1-800-881-011 888-292-7127
Australia – Optus 1-800-551-155 888-292-7127
Belgium 0-800-100-10 888-292-7127
Canada 888-292-7127
China, North – Beijing CNCG 108-888 888-292-7127
China, North – Beijing CNCG – Mandarin 108-710 888-292-7127
China, South – Shanghai – CT 10-811 888-292-7127
China, South – China Telecom – Mandarin 108-10 888-292-7127
Columbia, English 01-800-911-0010 888-292-7127
Columbia, Spanish 01-800-911-0011 888-292-7127
Ecuador – Andinatel 1-999-119 888-292-7127
Ecuador – Pacifictel 1-800-225-528 888-292-7127
Ecuador – Pacifictel, Spanish 1-800-999-119 888-292-7127
France 888-292-7127
Germany 0-800-225-5288 888-292-7127
Guatemala 999-910 888-292-7127
India 000-117 888-292-7127
Ireland 1-800-550-000 888-292-7127
Italy 800-172-444 888-292-7127
Japan – KDDI 00-539-111 888-292-7127
Japan – Softbank Telecom 00-663-5111 888-292-7127
Japan – NTT 0034-811-001 888-292-7127
Korea, Republic of – Korea Telecom 00-729-11 888-292-7127
Korea, Republic of – ONSE 00-369-11 888-292-7127
Korea, Republic of – Dacom 00-309-11 888-292-7127
Mexico 01-800-288-2872 888-292-7127
Mexico 1-800-462-424 888-292-7127
Mexico, Spanish – Pro Cobrar 01-800-1122-2020 888-292-7127
Mexico, Spanish 1-800-658-5454 888-292-7127
Puerto Rico 888-292-7127
Russia 8*10-800-110-1011 888-292-7127
Singapore 800-011-1111 888-292-7127
South Africa 0-800-99-0123 888-292-7127
Spain 900-99-0011 888-292-7127
Switzerland 0-800-890011 888-292-7127
Thailand 1-800-0001-33 888-292-7127
Turkey 0-811-288-0001 888-292-7127
United Kingdom – British Telecom 0-800-89-0011 888-292-7127
United Kingdom – NTL 0-800-013-0011 888-292-7127
United Kingdom – C&W 0-500-89-0011 888-292-7127
United States 888-292-7127
U.S. Virgin Islands 888-292-7127
Venezuela 0-800-225-5288 888-292-7127
For the most current list of AT&T Access Codes, visit www.business.att.com/bt/access.jsp.

LIVING OUR VALUES Kellogg Company’s Global Code of Ethics 49

Our Vision:
To enrich and delight the world
through foods and brands that matter.

Our Purpose:
Nourishing families so
they can flourish and thrive.

Kellogg Company
One Kellogg Square
P.O. Box 3599 ®

Battle Creek, MI 49016

September 2019