Land O'Lakes, Inc. 2018 Code of Conduct

LAND O’LAKES, INC. // CODE OF CONDUCT

INTEGRITY MATTERS

CODE of CONDUCT

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TABLE CONTENTS OF

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A MESSAGE FROM BETH FORD

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ABOUT THE CODE & RESOURCES

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MY ROLE

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Respect Confidentiality Respect Privacy Use Company Assets Responsibly Protect Intellectual Property Communicate with Care Avoid Conflicts of Interest Keep Accurate Business Records

HOW WE WORK

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HOW WE COMPETE

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BEING A GLOBAL CITIZEN

Appropriate Behavior in the Workplace Anti-Retaliation Diversity and Inclusion Workplace Safety Drugs and Alcohol at Work Workplace Violence

Competing with Integrity Trade Associations / Industry Events Trade Regulations Product Quality Marketing with Integrity Competitive Intelligence

Environmental Stewardship Compliance with Laws Protecting Human Rights Anti-Corruption / Anti-Bribery Anti-Money Laundering Community and Political Activities

LAND O’LAKES, INC. // CODE OF CONDUCT

A MESSAGE FROM BETH Land O’Lakes is a unique company. We were formed by farmers back in 1921. Today, our businesses give us a farmto-fork view which helps bring innovative ideas and products to farms, fields and families. And, just like almost 100 years ago, we use our core values to guide our actions and uphold our integrity.

As a Land O’Lakes employee, you bring this to life in the work you do every single day. To help you better understand our core values, this Code of Conduct—Integrity Matters— translates them into standards for how we work, compete and behave in the workplace and marketplace. Because in everything we do, integrity matters.

The Code provides you with several options to ask a question or raise a concern, including a President’s Inbox that allows you to provide feedback—anonymous if you prefer— directly to me.

At Land O’Lakes, integrity is a part of everything we do.

Thank you for your commitment to protecting our valued reputation built on this value. Together, we are well on our way to fulfilling our mission of Feeding Human Progress.

Beth Ford President + CEO

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A BO U T T H E COD E Our Code of Conduct, Integrity Matters, is a set of legal and ethical principles to help employees understand the Company’s expectations for how they work, compete and safeguard the Company’s reputation for excellence and integrity.

It is also Land O’Lakes’ public commitment to the highest ethical standards. Every employee is required, and empowered, to make sure their words, actions and decisions meet those standards, every day.

AB O U T O U R POLI CI ES Our Code of Conduct refers to several important Company policies. The full text of these, and all Company policies, can be found in the Policy Center on The Source.

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LAND O’LAKES, INC. // CODE OF CONDUCT

WHY DO WE NEED A CODE OF CONDUCT?

this Code can, in minutes, tarnish a company reputation

Even though no Code of Conduct can address every possi-

that’s been built up over decades.

ble situation an employee might encounter, our Code (with its emphasis on our values, integrity and compliance with

HOW ARE INVESTIGATIONS HANDLED?

the law) provides guidance for situations when the right

All reports of possible Code violations will be promptly

answer is not perfectly clear.

reviewed and investigated as appropriate. We observe

When faced with a situation with no clear “right” or

confidentiality to the extent possible. We also strictly pro-

“wrong” answer, ask yourself the following:

hibit retaliation against those who make good-faith reports

» Is the behavior I am considering consistent with our Code,

of actual or suspected violations of the Code or policy.

Company policy and the law? » Would I be proud if my family, friends or co-workers learned of my actions? » Would my behavior reflect well on my personal integrity, or the Company’s reputation for integrity, if it became known? » Will I be able to sleep soundly if I take this course of action?

WHO CAN USE THE HOTLINE? Land O’Lakes employees, members, customers and vendors are all free to use the Connect! Hotline to voice their concerns about unethical, unlawful or any other type of concerning behavior.

If you can’t answer “yes” to all the above, ask for help. Navigating ethical situations is not easy, but help is available.

WHO DOES THE COC APPLY TO?

WHO ANSWERS THE HOTLINE CALLS? CAN I CALL ANONYMOUSLY? Our Connect! Hotline is staffed and maintained by an inde-

The Code applies to all employees and anyone acting on behalf

pendent third party, not Land O’Lakes. The hotline is staffed

of Land O’Lakes.

seven days a week, 24 hours a day. Callers may speak in

WHAT AM I ACCOUNTABLE FOR?

their local language and may remain anonymous, except in certain international locations where complaete anonymity

» Read and follow the Code of Conduct and Company policies.

may not be permitted under local law. In those situations,

» Obey the law. Don’t commit—or direct another employee

we will comply with local law.

or third party to commit—an unethical or illegal act. » Use good judgment and common sense. » Ask for help if you aren’t sure. » Report suspected violations of the Code and cooperate fully in any investigations. » Be an excellent steward of the Company’s information, assets and reputation.

WHAT IS EXPECTED OF LEADERS? Lead by example. Your behavior speaks louder than words.

Be familiar with the Code and related Company policies.

Use them to guide your conduct and respond to employee concerns. Finally, encourage employees to speak up if they have a concern and ensure no retaliation is taken against those who do.

WHAT HAPPENS TO THOSE WHO VIOLATE THE CODE? Violations of this Code, Company policies or the laws and regulations that govern our business can have significant

WHERE SHOULD I GO WITH QUESTIONS OR TO REPORT A CONCERN? » Your leadership. All Land O’Lakes leaders are expected to “act with integrity.” This is even more critical when it comes to ethical concerns.

» Your HR business partner can often point you to the best and most knowledgeable resource.

» Any attorney in the Land O’Lakes Law Department. » Ask Beth (President's Inbox) where you can reach out directly—and anonymously—to the CEO.

» The Connect! Hotline, which is maintained and staffed by an independent third party. You can reach the hotline by: » Phone: In the U.S. or Canada, dial 855-TELLLOL (855-835-5565). International callers

consequences. Besides disciplinary action and even the

should dial an operator and ask to call

loss of employment, there can be civil or criminal penalties

470 219 7131. Both are toll-free numbers.

for non-compliance. Most importantly, behavior that violates

» Email: Connect@tnwinc.com » Web: U.S. | International

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MY ROLE 4

LAND O’LAKES, INC. // CODE OF CONDUCT

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very Land O’Lakes employee—regardless of role—has a part to play in maintaining our reputation for fairness, integrity and ethics. This includes protecting information, communicating with care and avoiding conflicts of interest.

It can be easy to rationalize the wrong behavior by telling

yourself things like: Just this once. No one will ever know.

Ironically, those making the wrong decision sometimes do so believing they are acting in the Company’s best interests.

As a guardian of the Company’s reputation for integrity and ethical behavior, you should understand that while business challenges and ethical dilemmas may change, our commitment to doing what's right, every day, does not.

Here are some of the most important standards each employee must follow, every day, every time.

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RESPECT CONFIDENTIALITY

especially those relating to discrimination, harass-

Confidential information is any information that

ment, confidentiality, privacy and compliance with

is not public. It includes trade secrets, strate-

the law. Take care to protect those assets from

gic plans, consumer insights, engineering and

theft or damage.

manufacturing ideas, product recipes, designs,

Passwords matter! Never share your password

databases, records, price information and unpub-

and don’t leave your laptop unattended in an

lished financial information.

exposed location.

Never disclose, or allow the disclosure of,

Land O’Lakes monitors the use of its assets.

confidential information unless required by law

Employees should not have an expectation that

or directed by Company leadership. Use special

information stored on or transmitted via those

care in storing or transmitting confidential infor-

assets is private.

mation, as required by Company policy and our Information Classification standard. Honor confi-

PROTECT INTELLECTUAL PROPERTY

dentiality commitments made to our customers,

How can employees safeguard the Company’s

vendors and business partners. Never disclose

intellectual property?

their confidential information without their written consent.

Be aware of your surroundings when working, especially when traveling or away from the office.

Can others overhear your conversations? Is your laptop screen visible by others?

Keep in mind that the obligation to respect confidentiality continues, even if your employment

»» Only use approved and authorized Company trademarks. Report any suspected misuse of our trademarks, logos or brands. »» Never disclose Company trade secrets to unauthorized persons. »» Report to leadership any new product, technology or unique business solution developed while working for Land O’Lakes.

with Land O’Lakes ends. Likewise, never disclose the confidential information you learned while working for other employers to Land O’Lakes.

If you believe that Company confidential information has been stolen or disclosed without permission,

Respect the intellectual property rights of others as well. Never use intellectual property that does not belong to Land O’Lakes without permission from its owner.

contact the Law Department immediately.

RESPECT PRIVACY

COMMUNICATE WITH CARE Communications are the lifeblood of any busi-

Members, employees, customers and business

ness. They also carry substantial risk if done

partners all trust Land O’Lakes with sensitive, and

carelessly or thoughtlessly. As technology makes

sometimes private, information. Before collecting,

communication increasingly virtual, the nuances

using, sharing or deleting any such information, make

of in-person communication can be lost.

sure you understand your responsibilities under the

Don’t be misled by the casual nature of texts or

Company’s Privacy policy, our privacy notices and any

instant messages—they carry the same weight and

applicable agreements with the information’s owner.

importance as an old-fashioned memo. Before hitting “send,” ask yourself how you would feel

USE COMPANY ASSETS RESPONSIBLY Company information and technology are essential to performing your role successfully. Be sure to use—and safeguard—them appropriately.

Use all Company information and assets (such as hardware, software and internet access) consistently with this Code and Company policies,

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reading these words on tomorrow’s front page.

Be sure your communication passes these critical tests: »» Don’t use profanity, slurs or other offensive language. »» Don’t disparage other employees, customers, members or business partners.

LAND O’LAKES, INC. // CODE OF CONDUCT

»» If you need to include “Destroy after reading,” don’t write it in the first place. »» Avoid sarcasm or humor; they do not translate well into written communications. »» Don’t use antitrust red-flag words (e.g., “dominate” or “monopolize”) even jokingly.

will inevitably have their motivation for selecting that vendor questioned—even if that vendor was the best choice. Conflicts can also arise with existing vendors, as we expand the scope of our relationship with them.

Land O’Lakes expects every employee to “act

»» Don’t exaggerate; be completely factual.

with integrity.” Read and follow the Company’s

»» Don’t speculate on the legality of behavior.

Conflict of Interest policy, which addresses the

»» Be sure you are safeguarding confidential

most common types of conflicts, such as:

or private information. »» Make sure your communications are

»» Gifts and entertainment »» Working with family members

consistent with the Company policies on

»» Insider trading

Appropriate Behavior in The Workplace,

»» Doing business with Land O’Lakes

Confidentiality and Privacy.

»» Serving on an outside Board of Directors

»» If your communications are on social

»» Outside employment

media platforms, read and follow the

»» Working for competitors

Social Media policy.

»» Personal financial interests

All inquiries or requests from representatives of the media, industry or governmental agencies,

KEEP ACCURATE BUSINESS RECORDS

including all requests for comment, must be

Land O’Lakes is committed to the integrity

directed to the Communications Department.

AVOID CONFLICTS OF INTEREST

of its records, and requires that all reports, documentation, financial statements and other business records are accurate and comply

A conflict of interest is a situation where an

with all applicable accounting procedures and

employee’s personal interests conflict with—or

internal controls.

even appear to conflict with—the Company’s best interests.

Nothing is more corrosive to an employee’s

Every employee is responsible for ensuring the accuracy and completeness of business records they create or maintain.

or business’ reputation for integrity and ethical

Always consult the Company’s Records Man-

behavior than an actual — or even perceived—

agement policy and Retention Schedule before

conflict of interest. An employee who accepts

destroying any business record. If the record is

lavish entertainment from a vendor, then later

subject to a litigation hold, maintain the record

chooses that same vendor for a lucrative contract,

until notified otherwise by the Law Department.

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1 I see so much misinformation on social media about farming practices and bio-technology. These issues that are so important to our members and customers. Can I jump in to correct the record?

A N D

Land O’Lakes can best support our members when we speak with a strong, unified voice.

That's why our Social Media policy outlines the rules that apply when an employee uses social media on behalf of the Company, or when referring to the Company or its products.

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Can I use my Company computer for personal use?

While limited personal use is permitted, you should not have any expectation of privacy if you use Company assets for personal use.

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The local newspaper has contacted me for a quote about our plant expansion. Can I respond?

No. Refer all media requests to the Communications Department. See the Information Disclosure policy for more information.

LAND O’LAKES, INC. // CODE OF CONDUCT

5 Land O’Lakes isn't a public company, so I don’t need to worry about insider trading—right?

Wrong. Through your role at Land O’Lakes, you might learn material, non-public information

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I think someone might be recording my conversations. Is that OK? No. The Company prohibits the unauthorized, or secret, use of camera, sound or video recording or streaming equipment.

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about another company, such as merger or divestiture plans, a new product offering or other information that could have an impact on that company’s stock. Never share or use that information to your benefit. See the Conflict of Interest policy for more information.

A vendor regularly wines and dines our leader at fancy restaurants with expensive bottles of wine. Our leader won’t hear anything negative about this vendor and keeps giving them new business. Isn’t this a conflict of interest?

This scenario illustrates why gifts and entertainment by new or existing vendors can be a problem. This vendor may be capable and the best choice for our business, but the leader’s behavior has created

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A customer needs me to alter the date on a purchase order—something about their accounting rules. Can I help them out?

the perception that his or her judg-

No. All business records must be complete

perceived —conflicts of interest by

and accurate—no exceptions.

following the Conflict of Interest

ment may be clouded by frequent, lavish entertainment. Employees are required to avoid actual—and

policy whenever gifts or business entertainment are offered.

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HOW WE WORK 10

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t Land O’Lakes, we have an important purpose—Feeding Human Progress.

This commitment requires building and maintaining collaborative, high-performing

teams by attracting and retaining the best talent in the industry.

We are committed to providing a workplace of respect; where employees act, and are treated, with professionalism; and where every employee has the opportunity to reach their full potential and be a part of the Company’s success.

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APPROPRIATE BEHAVIOR IN THE WORKPLACE

WORKPLACE SAFETY

A high-performing work environment has no

Safety is core to everything we do at Land

tolerance for discrimination, harassment or other

O’Lakes, and nowhere is that more apparent than

forms of inappropriate or unprofessional behavior

the safety of our employees. Our extensive safety

—whether by a co-worker, manager, customer,

program is designed to create a culture of safety

vendor or others. These behaviors are not only a

excellence at every level in the organization.

violation of the Company’s Appropriate Behavior in the Workplace policy, they may also be unlawful.

It can be hard to speak up if you experience or observe this type of behavior. Often, the perpetrator is seen as more important, or more powerful, than his or her target, and in a position to hurt the career of those who object. Every employee, however, is entitled to a workplace free from the

You can participate in our safety culture by following all Company safety policies and practices and applicable laws concerning safety: »» Report every injury, near-miss or possible safety situation immediately. »» Own your own individual safety and the safety of those around you. »» Don’t put production ahead of people,

negative effects of inappropriate behavior, and

and don’t take shortcuts when it comes to

every employee must hold themselves, and oth-

safety.

ers, accountable for ensuring a culture of dignity, respect and welcome for all.

Contact any of the resources listed in this Code

DRUGS AND ALCOHOL AT WORK Our commitment to the health and safety of

if you see, hear or experience any inappropriate

employees includes a ban on the use or abuse of

behavior.

drugs or alcohol at work. Consult the Company’s

ANTI-RETALIATION

Drug and Alcohol policy for more information, including alcohol at Company functions.

Land O’Lakes prohibits the retaliation against any employee who makes a good-faith report

WORKPLACE VIOLENCE

of suspected or actual violations of the Code or

Another safety priority is preventing workplace

Company policy.

DIVERSITY AND INCLUSION

immediately if someone’s behavior or words creates fear or concern about possible harm to

Diversity and inclusion is vital to our success—

others or to Company property. Except where

and core to who we are. This means valuing and

prohibited by law, the Company also bans weap-

respecting the perspectives, experiences and

ons on Company property or while acting on

talents of all individuals.

Company business.

Our employee and member community, built on the principles of diversity and inclusion, allows us to unlock our greatest potential through a culture that embraces teamwork.

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violence. Contact the Global Security team

LAND O’LAKES, INC. // CODE OF CONDUCT

A N D

My behavior on my own time is my own business, right?

I’ve been trained on the Lock Out Tag Out policy, but if I follow it we're going to miss three big orders today. What should I do?

Never put production ahead of safety.

Usually. But there are rare occasions when an employee’s

The rules are there for your protection,

behavior off the job can make it impossible for him or her to

and that of your co-workers. Follow

be successful on the job. In those situations, the personal and

every safety rule, every time.

professional can collide. Employees should avoid conduct outside of work that could impair their work performance or hurt the Company’s reputation or business interests.

My co-worker just got out of an abusive relationship. She told me she's afraid her ex might show up at work and harm her. She is too afraid to talk to management. What should I do?

My department recently interviewed candidates for a newly-created position, and I heard my manager dismiss one of the candidates as being too “close to retirement." Is this OK? Someone who makes assumptions based on age, race, sex or other pro-

You are right to be concerned. Domes-

tected factors violates Company policy

tic problems can spill into the work-

and possibly the law. They may also be

place, with sometimes deadly results.

ignoring a wealth of talent. You should

Global Security can provide advice for

contact any of the resources listed in this

the location and the employee before

Code to report your concerns.

anyone gets hurt. Security should be contacted immediately, as well as location management and HR.

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HOW WE COMPETE 14

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t Land O’Lakes, we are proud of the products we bring to market, and the integrity and honesty with which we market them. We compete fiercely, but with integrity. We treat customers and suppliers fairly. We neither need nor use unfair

or deceptive marketing practices; we are proud to present our products in an honest and forthright manner.

We respect and follow laws that prohibit unfair competition, restraints of trade, predatory economic activities and unfair or unethical business practices. We are committed to the free enterprise system, as well as the regulations that are in place to keep it healthy.

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COMPETING WITH INTEGRITY

regulatory standards for safety, quality, security

Antitrust laws, which are designed to promote

and wholesomeness.

free and fair competition, make a number

Product safety and quality are core values.

of activities strictly unlawful. Never discuss,

There is nothing more important than the safety

exchange information or agree with a competitor

and health of the humans and animals we feed.

(or a prospective competitor) about any of the

Every employee has a part to play in our qual-

following “prohibited topics”:

ity and safety mission. Be a Product and Safety

»» Past, present or future bids

Champion and be sure to report any concerns to

»» Costs, including ingredient costs

leadership.

»» Sales data or plans »» Customers

MARKETING WITH INTEGRITY

»» Territories or markets

At Land O’Lakes, we support marketing that will

»» Inventory

positively benefit society at large, our sustainabil-

»» Production plans

ity efforts and our purpose of Feeding Human

»» Market surveys

Progress. Our sales and marketing practices

»» Prices or pricing policies

are grounded in honesty and responsibility in

»» Promotions or discounts

serving our consumers, customers, members

»» Terms and conditions of sale

and employees. False or deceptive statements

»» Profits

do not align with our company value of doing the

Refer to the Company’s Antitrust policy for more information and be sure to contact the Law Department with any questions.

right thing and our commitment to drive trust in our brands.

As leaders and committed partners, we leverage these principles across all sales and

TRADE ASSOCIATIONS/INDUSTRY EVENTS

marketing channels—including packaging and

Whenever competitors gather, such as at trade

product labels, sales materials, trade advertising,

association or industry events, antitrust risk is

brand sponsorships and all forms of advertising

present. Any employee who plans to attend such

(television, print, radio, digital media, websites,

an event must comply with the Trade Association

promotions and events).

and Industry Event Certification Program prior to the event.

All sales, marketing and promotional materials are reviewed prior to publication by the Marketing and Law departments to ensure our quality

TRADE REGULATIONS We are committed to complying with the import, export and economic sanctions laws of all countries where we do business. We also comply with the anti-boycott laws and regulations of the United States.

Compliance with U.S. foreign trade regulations is essential to our continued growth in foreign markets and reflects our commitment to conducting business ethically and with integrity. Consult the Trade Compliance policy for more information.

PRODUCT QUALITY We are committed to consistently bringing to market products that delight customers and consumers while meeting rigorous Company and

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standards are met.

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LAND O’LAKES, INC. // CODE OF CONDUCT

SCENARIOS

“CO-OPITITION” Land O’Lakes is in early discussions with Company X about forming a joint venture. Company X is currently a competitor to Winfield United. During a meeting, the VP of Sales at Company X offers you a list of their customers, products and prices. What should you do?

Sometimes a competitor can be a customer (or even a business partner), making it difficult to know where “competition” stops and “cooperation” begins. In this scenario, despite the potential joint venture, the competitive information cannot be shared until cleared by the Law Department. Do not accept the information and then document what happened—and how you responded—as soon as possible.

TRADE ASSOCIATION EVENTS You are participating at a roundtable event during a trade show where competitors are present. The first topic is an effort to lobby for changes to laws that will make it easier to bring new technologies to market. The conversation then turns to standardizing industry credit and payment terms, which would be a big boost to efficiency. Should you be concerned?

Lobbying efforts by a trade association are permissible, even when they are undertaken among competitors. However, when the conversation turns to credit and pricing terms—both a component of pricing—you should make a “noisy exit,” meaning you stop the conversation, state that you cannot participate in it and ask that all note the point at which you left the conversation.

Contact the Law Department immediately for further guidance.

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C OMP ETIT I VE I N T E L L I G E N C E Gathering information and intelligence about our competitors is permissible, as long as publicly available sources are used—such as industry journals and reports, government filings, speeches and media. This includes obtaining information from well-established sources (such as Dunn & Bradstreet), academic conferences or trade shows.

Never use illegal or unethical means to gain competitive intelligence. This includes fraud, misrepresentation, trespassing, unauthorized access to electronic records, or asking employees to disclose confidential or trade secret information about their previous employers. Never seek or accept such information from a competitor.

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LAND O’LAKES, INC. // CODE OF CONDUCT

1. Exercise independent judgement in all business decisions, especially those that impact how we compete (e.g., those related to pricing, territory, production, etc.).

2. Contact the Law Department for guidance prior to meeting with competitors.

3. Make sure there is a legitimate business reason for any meeting or discussion with a competitor.

4. If possible, establish and follow a written agenda for any such meeting, and keep a record of the agenda and meeting notes.

5. Stop any discussion that goes beyond the agenda and/or into a prohibited topic. Make sure your objection is noted by all, then make a “noisy exit” by leaving the discussion/meeting.

6. Use judgment in all communications with and to competitors, suppliers and customers. Prior to sending any communications, review the content through the lens of an antitrust regulator or plaintiff and re-write any portion that could be misconstrued.

7. Complete any required antitrust training.

8. Read and follow the Company’s Antitrust policy.

Dos ANTITRUST

Dont’s 1. Jokingly, or otherwise, use antitrust “red flag” words such as market share, take, beat, steal, dominate or monopolize when discussing competitive matters. Instead, use pro-competitive language such as percent sales, percent of industry, sales penetration, out-indexing, growth, earn and win.

2. Believe that any discussion with a competitor is “off the record.”

3. Relax antitrust vigilance too soon into a merger or acquisition.

4. Make any agreement, with any competitor, about a prohibited topic.

5. Discuss any prohibited topic with a competitor.

6. Engage in group boycott activity by agreeing with a competitor not to do business with a particular individual or vendor.

7. Accept competitive information from competitors. If you receive competitive information from a legitimate source (e.g., a customer or publicly available document), clearly document the source from which the information was received.

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A GLOBAL CITIZEN 20

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t Land O’Lakes, our commitment to doing the right thing doesn’t stop at the border. Building strong communities, creating enduring livelihoods and being effective stewards of our resources—these

commitments are just as important as quality products and services.

We work in communities around the globe to grow more food with less, foster innovation and preserve our planet. It’s all about working together for the common good—today and for future generations.

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ENVIRONMENTAL STEWARDSHIP

Simply put, we follow the law wherever we

As a farmer-owned cooperative, serving as a

do business. There are no exceptions and no

steward of the earth and preserving its natural

excuses, including pressure from others or the

resources for generations to come is more than

demands of the job. There are no work-arounds,

just a way of doing business—it's part of our DNA.

such as hiring a consultant or third party to do

Land O'Lakes employees are expected to go

something employees are prohibited from doing.

beyond compliance with applicable environmen-

Every day, every time—we do the right thing.

tal laws and regulations. They are expected to honor and abide by the Company’s commitment to conducting its business in a manner that is scientifically based, socially responsible, economically sound and designed to feed more people with fewer resources.

Employees are also expected and encouraged to act in ways that reduce the impact of our operations on the environment.

COMPLIANCE WITH LAWS Throughout this Code, you will find our commit-

Land O’Lakes is committed to protecting fundamental human rights throughout our organization and supply chain.

Consistent with the principles of the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work, we will not employ child labor. We will not use involuntary labor—whether bonded, prison, military, compulsory or indentured.

We expect our business partners and suppliers

ment to complying with the law, whether those

to uphold these principles and others outlined in

laws address employment, competition or the

our Supplier Code of Conduct.

environment.

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PROTECTING HUMAN RIGHTS

LAND O’LAKES, INC. // CODE OF CONDUCT

ANTI-CORRUPTION & ANTI-BRIBERY Every employee, and especially those with international touchpoints, must read and follow the Company’s Anti-Corruption/Anti-Bribery policy, which strictly prohibits offering or receiving anything of value to obtain or retain a business advantage of any kind.

This is especially true when operating in cultures where such practices are commonplace and widely accepted. The penalties for such behavior —even when carried out by a third party acting on behalf of the Company—are severe, including both criminal penalties and multi-million dollar fines. Contact the Law Department for guidance if you have any questions on this topic.

ANTI-MONEY LAUNDERING Money laundering refers to methods by which the proceeds of illegal activities are concealed, or the source of illegal funds are made to look legitimate. Land O’Lakes complies with all laws that prohibit money laundering activities.

Red flags to watch for include customers who: »» Make an unusual request about where to direct payments. »» Request that a payment be made in cash or cash equivalents. »» Ask that a payment be broken into small amounts to avoid reporting thresholds. »» Request that payments be made through an unrelated country and/or an unrelated party.

Contact the Company’s Treasury Department if you encounter these, or any other unusual, requests.

COMMUNITY AND POLITICAL ACTIVITIES Land O’Lakes is all about leadership, and that commitment extends to being a leader in our communities. We encourage employees to be engaged in their communities—and to decide when and how to contribute their time, money or resources to civic and political activities.

However, Company funds may not be used for any personal political activities, such as a contributing to, or paying the expenses of, a candidate, campaign, political party or organization, or office holder.

Our Government Relations Department is responsible for representing the Company on all legislative, regulatory and public policy issues.

They will handle all requests for information or comment to, or from, any public officials or government agencies.

Because contact with government officials to influence legislation or policy-making could be considered lobbying, which requires registration and disclosure, be sure to contact the Government Relations or Law Department for guidance before engaging in those activities.

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A N D We were contacted by a customer about shipping product to a country listed in our Trade Compliance policy as “sanctioned.”

When we told the customer that we could not make the sale, they said to ship it an adjacent country instead, one where exports are permitted. What should I do?

You are right to be concerned.

My spouse is running for a local school board election and I would like to help by sending emails to co-workers who live in our school district. Can I do this?

Contact the Import/Export Department or Law Department immediately. Land O’Lakes cannot participate in any attempt to evade the impact of trade laws.

While the Company encourages employees and their families to be engaged in the communities in which they live and work, Company assets (e.g., work time, email, hardware, software and certainly funds) cannot be used for private political activities.

A government official in another country where we sell product is insisting that we start wiring refunds on their account to a new bank account—not the one we are paid from. Should I be concerned?

While there may be a legitimate reason for this, it does require further investigation. Contact both the Company’s Treasury Department and Law Department for assistance if you receive a new or unusual request from an international business partner—especially one who represents a government, and especially around payment terms.

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LAND O’LAKES, INC. // CODE OF CONDUCT

It’s a Code, not a contract.

Our Code of Conduct is a collection of the most important principles by which we operate our business. It is not a contract and does not convey specific employment rights, nor guarantee employment for any length of time.

Changes to the Code.

The Code may be changed from time to time. The most up-to-date version will be available on the Company’s intranet (The Source) or our external website, landolakesinc.com.

Acknowledgement.

My signature below (actual or virtual) acknowledges that I have read, understood and agree to follow the Land O’Lakes Code of Conduct.

EMPLOYEE SIGNATURE

EMPLOYEE ID NUMBER

DATE

Published by Land O'Lakes, Inc., 2018 | V9:12/18

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Ask a question or raise a concern At Land O'Lakes, we do the right thing, every time. Sometimes, the right thing is reporting a concern or asking a question.

Phone: U.S. & Canada: 855-835-5565 International callers should dial an operator and ask to call 470 219 7131 Email: Connect@tnwinc.com Web: U.S.: https://www.reportlineweb.com/ Welcome.aspx?Client=landolakes International: https://iwf.tnwgrc.com/ landolakes

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