Be Preferred
We earn the right to be customer-preferred by delivering mutual enduring value at every touchpoint of the customer experience.
Competing Fairly
We believe in competing fairly. In our pursuit to deliver ingredient solutions that enable our customers to create consumer-preferred, winning products in their local marketplace, we never use illegal or unethical means to obtain a competitive advantage.
Obtaining Competitive Intelligence
Competitive intelligence can be obtained fairly and ethically from publicly available sources, such as media reports, trade journals, annual reports, governmental filings, speeches of company executives, and from customers in the context of meeting competitive offers.
Competitive intelligence should never be obtained through misrepresentation, trespassing, theft, invasion of privacy, or obtaining information from co-workers about previous employers.
When dealing with competitors, never enter into any agreement—whether formal or informal, written or verbal—to set prices or other terms of sale; coordinate bids; allocate customers, sales territories, or product lines; or engage in any other activity that violates applicable antitrust or competition laws. We never discuss such topics with a competitor, even in an informal setting such as a trade show or customer event. If you have any concerns, contact your local Legal department.
Our Values in Action
Q: I have a good friend who works for a competitor. At a trade show, my friend proposed a strategy for each of us to increase sales by dividing territories. Should I go along with the plan?
A: No. Allocating customers or geographic territories between competitors could be a violation of the law. If a competitor ever initiates a discussion about allocating territories, stop the conversation immediately. If you are at a trade show and this type of conversation starts, then end the conversation immediately. Report any attempt to discuss anti-competitive behavior immediately to the Legal department.
Living our Values
We compete vigorously based on the quality of our products, aiming to meet or exceed our customers’ needs and delivering superior ingredient solutions that will help our customers succeed. Compete fairly:
- do not use illegal or unethical means to obtain competitive advantage
- do not agree to fix prices, rig bids, or unlawfully divide up products, territories, customers or markets, or limit production or sale of products
- do not make false, baseless, or misleading remarks about our company, its competitors or their products
- do not use information obtained by unfair or illegal methods
- do not engage a third party to obtain competitive information that would be unlawful if gathered directly by Ingredion.
Gifts and Entertainment
We are responsible for ensuring that our relationships with customers, suppliers, and other business partners are based on objective decisions and are not infuenced by gifts or entertainment ofers. This section also applies to our partners or third parties, working on Ingredion’s behalf.
GIFTS AND ENTERTAINMENT TO GOVERNMENT OFFICIALS
Giving or offering even a simple gift or meal to a government official (or someone with a close personal or family relationship with a government official) may violate local and U.S. law (and, if you are not located in the U.S., the applicable laws of the country in which your business is located, as well). Contact the Legal Department or Corporate or local Compliance Department before giving or offering any gift, meal or entertainment to a government official (or someone with a close personal or family relationship with a government official)—and also before you agree to receive a gift.
LOANS
Executive officers, directors, and employees may not receive loans from or have obligations guaranteed by the company, except as expressly authorized by company policy
Our Values in Action
Q: I am part of a team working on a renewal contract with a current supplier. During negotiations, the supplier offered four tickets to a regular season ballgame. While the individual tickets were not very expensive, their value was more than what would be considered a modest amount in my location. Also, because of the teams playing, the tickets are hard to get. Given the situation, I notified my manager. We decided that it was best to not to accept the tickets. Did we do the right thing?
A: Yes. Seeking guidance from your manager before accepting this gift, which is of more than modest value, was the right approach to the situation. Given the circumstances, the supplier’s offer could be viewed as an attempt to infuence the outcome of the renewal of the contract.
A gift is GENERALLY ALLOWED as long as it:
- Does not violate local law or the recipient’s business standards
- Does not make the recipient feel obligated or give the appearance of an obligation
- Is not solicited
- Is infrequent
- Does not exceed generally accepted local business practices
- Is a reasonable complement to the business relationship
- Is consistent with Ingredion’s Code of Conduct
- Is accurately reflected in the employee’s expense report and on Ingredion’s books and records.
A gift is GENERALLY PROHIBITED if it:
- Is illegal
- Could cause—or give the appearance of causing— an employee to grant or receive any favour in return
- Is extravagant under the circumstances
- Coincides with purchasing or sales decisions, since these could appear to improperly influence the decisions
- Involves giving or accepting cash or cash equivalents such as gift cards, gift certificates, or vouchers with denominated spending amounts
- Is unsavory, sexually-oriented, or offensive.
Do NOT in any event request or solicit (or expect) gifts, favours, or entertainment, from any Ingredion business partner. Keep in mind that special rules apply when interacting with government officials.
Conflicts of Interest
We act in the best interest of Ingredion and do not allow our business decisions to be influenced, or appear to be influenced, by personal or family interests or friendships, or other connections we may have.
What is a conflict of interest?
A conflict of interest arises any time a personal or private interest interferes with, or gives the appearance of interfering with, work being performed fairly and ethically without bias or undue influence. Some instances are obvious, such as having a close relative as a manager or serving as a director on the board of a competitor.
Conflicts can arise in many situations, and our Code cannot possibly address all of them. When in doubt, contact your manager, Legal, Business Integrity, Local Compliance Committee, Human Resources, or the Business Ethics Line before taking any action.
Remember, having a conflict of interest is not necessarily a violation of our Code of Conduct, but failing to disclose it is.
Our Values in Action
Q: Don works in corn procurement. He was recently transferred to a plant near his hometown and promoted to manager. His uncles own farmland nearby, and he has learned that they occasionally sell corn to Ingredion. Don is concerned that these transactions could create or appear to create a conflict of interest with his new role. Should Don disclose the potential conflict?
A: Yes. Don has a valid concern and should bring the situation to the attention of his manager, the Legal Department or local Compliance Committee. After disclosure, the company can review the situation and determine whether it in fact poses a conflict of interest.
Living our Values
Conflicts of interest can negatively affect Ingredion’s reputation and business, and can have negative consequences for individuals as well. To help avoid the negative consequences of conflicts of interest:
- never let our business decisions be influenced, or appear to be infuenced, by personal or family interests or friendships
- avoid any situation that looks like it could affect your judgment
- never solicit or accept anything of value that may be perceived as a means to unduly infuence business judgment
- award business solely on merit in order to obtain the best products and services at the best prices and terms
- always make decisions related to Ingredion based on the company’s objectives and priorities
- never pursue any business opportunity we discover through our work with Ingredion for personal gain or the gain of any entity other than Ingredion
- promptly disclose potential conficts of interest by contacting a manager, Legal, Business Integrity, Human Resources, or the Business Ethics Line.
Political Activity and Contributions
We comply with all applicable laws regarding political activities and disclosure requirements.
LOBBYING
Lobbying is an attempt to influence the actions, policies, or decisions of officials in their daily life. No employee, contractor, or agent may engage in any lobbying activities on behalf of Ingredion without prior written approval and coordination with the Government Affairs professional or legal counsel responsible for the country or region. Any approved lobbying activities must be in full compliance with applicable laws. If you are not sure whether your communications or interactions with a government official are considered lobbying, contact the Government Affairs professional or legal counsel responsible for the country or region.
POLITICAL PARTICIPATION AND CONTRIBUTIONS
Ingredion does not give political contributions to candidates, political party organizations, political committees, or political organizations in return for express or implied official acts.
Our Values in Action
Q: I have been asked to work on a local political campaign. May I do so?
A: Yes. Our company encourages participation in the political process. However, it is important that your political activities remain separate from the workplace, done on your own time and at your own expense. Therefore, you cannot use company resources, including work hours, company vehicles, use of the company’s computer network or telephones, or use of the company’s name or other assets, when working on personal political activities.
Living our Values
Many countries in which Ingredion does business strictly regulate lobbying activities. Remember:
- never engage in lobbying on behalf of Ingredion without prior written approval and coordination with the Government Affairs professional or legal counsel responsible for the country or region
- lobbying activities must be in full compliance with applicable federal, state, and local laws.
If you are not sure whether your communications or interactions with a government official are considered a lobbying activity, contact the Government Affairs professional or legal counsel responsible for the country or region.
PERSONAL POLITICAL ACTIVITIES AND CONTRIBUTIONS
Ingredion respects the right of employees and others working with the company to participate in political activities on their own time, outside of work. Where personal political contributions are permitted by law, understand the following additional conditions related to your relationship with the company:
- do not make contributions from company funds
- do not submit expenses for personal political activities to the company for reimbursement
- do not use company resources or disclose Ingredion’s confidential information when participating in the political activity
- do not, in any way, state or suggest that you are representing Ingredion in the individual political activity (e.g., on social media).
The above rules also apply to any individual contractors and others who work for Ingredion.
International Trade Compliance
We comply with all trade regulations, agreements, and restrictions that apply to our business during exchange of goods between countries, including import customs declarations and export control laws.
Our Values in Action
Q: To avoid paying customs duties in its home country, an international customer has asked that an employee in the U.S. sign an origin declaration or certifcate of origin identifying that the company’s products originate in Mexico. I know the product was packaged in Mexico but am not aware of the manufacturing process and where the product was originally made. May I sign the document?
A. No, not without prior approval of the Corporate or United States/Canada Trade Compliance team or your local trade compliance contact. Origin declarations and certifcates of origin are governed by local and international laws and they require a detailed analysis of the manufacturing process under an established set of rules. An incorrect statement may result in false declarations to customs authorities and subject the company to significant fines and penalties, even when Ingredion is not the importer or exporter.
Living our Values
If you are responsible for the movement of Ingredion products, or an offeror of non-commercial materials across borders, you must be familiar with and comply with applicable U.S. and any local laws outside the U.S. governing trade, regardless of where you are actually based or located. Remember:
- Ingredion does not conduct unauthorized business with countries or third parties that are subject to trade embargoes or economic sanctions (e.g., Iran., Syria, North Korea)
- As a U.S.-based company, Ingredion is prohibited from participating in boycotts (e.g., refusals to sell to customers located in a particular country) that the United States government does not support
- Import of Ingredion goods shall undergo proper assessment of duties from tarifs using accurate valuations based on purchased cost (price paid) or transaction value (Ingredion Transfer Pricing policy) for related party transactions
- Follow your local trade compliance policies and procedures relevant to the country and location where you work
- Contact your local trade compliance representative or your local Legal Department if any customers, suppliers, or forwarding agents ask Ingredion to participate in a boycott or do business with embargoed or restricted parties. Remember that sanctions can and do change. Always seek advice for the most up-to-date positions before you take any actions.
A gift is GENERALLY ALLOWED as long as it:
- Does not violate local law or the recipient’s business standards
- Does not make the recipient feel obligated or give the appearance of an obligation
- Is not solicited
- Is infrequent
- Does not exceed generally accepted local business practices
- Is a reasonable complement to the business relationship
- Is consistent with Ingredion’s Code of Conduct
- Is accurately reflected in the employee’s expense report and on Ingredion’s books and records.
A gift is GENERALLY PROHIBITED if it:
- Is illegal
- Could cause—or give the appearance of causing— an employee to grant or receive any favour in return
- Is extravagant under the circumstances
- Coincides with purchasing or sales decisions, since these could appear to improperly influence the decisions
- Involves giving or accepting cash or cash equivalents such as gift cards, gift certificates, or vouchers with denominated spending amounts
- Is unsavory, sexually-oriented, or offensive.
Do NOT in any event request or solicit (or expect) gifts, favours, or entertainment, from any Ingredion business partner. Keep in mind that special rules apply when interacting with government officials.
Reporting Concerns
Your voice matters. Each of us is responsible for building and protecting Ingredion’s culture of integrity. A suspected violation of this Code of Conduct, company policy, or violation of law could be a serious matter. We expect everyone to speak up about any potential violations.
The company does not tolerate retaliation against those who speak up in good faith or participate in investigations. If you have a question about this Code or if you are concerned about a potential violation, you have a number of options:
- discuss the issue with your manager;
- discuss the issue with another manager;
- contact the Human Resources, Legal, or Regional or Business Integrity department; and
- use the Business Ethics Line, to report concerns or ask questions (anonymously, if you wish) in your language.
Go to our Ingredion Ethics Website to contact the Business Ethics Line via the internet or to look up toll-free numbers by country on Ingredion’s InSite intranet site. The site is available 24 hours a day, 7 days a week.
Question or Concern?
If you suspect a possible violation of Our Code of Conduct, we encourage you to speak up and report it on the Ingredion Business Ethics line at our INGRethics.com.
Go to the next section:
Care First | Be Preferred | Everyone Belongs | Innovate Boldly | Owner's Mindset | Ethical Standards
Go to a specific section:
Care First: Environmental, Health, and Food Safety | Human Rights | Sustainability | Privacy | Anti-Bribery | Report Concern
Be Preferred: Competing Fairly |Gifts and Entertainment | Conflicts of Interest | Political Activity | International Trade Compliance | Report Concern
Everyone Belongs: Diversity & Inclusion | Harassment & Discrimination | Anti-Violence & Intimidation | Report Concern
Innovate Boldly: Intellectual Property & Company Assets | Email & Internet Information Systems | Report Concern
Owners Mindset: Accuracy of Books & Records | External Communication & Social Media | Confidential Information | Report Concern
Ethical Standards: Living our Values | Compliance with policies | Business Integrity | Report Concern