Land O'Lakes, Inc. Code of Conduct

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LAND O’LAKES, INC. // CODE OF CONDUCT

CODE OF CONDUCT

INTEGRITY MATTERS cv1


TABLE OF CONTENTS 1

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

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HOW WE WORK

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

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HOW WE COMPETE

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

BEING A GLOBAL CITIZEN

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 For 100 years, Land O’Lakes has conducted business ethically and with the highest integrity. We have built our reputation as a trusted and ethical company through hard work, dedication and an unwavering commitment to doing the right thing. It is who we are and who we have always been. Our reputation and our commitment to integrity allows us to move forward with purpose and take our place among the leaders and problem solvers. Only by acting with integrity— by doing the right thing, every time—will we be able to solve the important issues before us such as food security, climate change and investment in rural communities. Each and every one of us has the privilege—and the responsibility—of upholding our century-long commitment to integrity. Our members, their communities and our consumers expect it from us—and we expect it from each other. Our Code of Conduct is our shared understanding of those expectations and responsibilities. Use it as your guide. Refer to it often and reach out when you have questions. As we move forward into our next 100 years, thank you for your commitment to integrity and for doing the right thing, every time.

Beth Ford President + Chief Executive Officer

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AB OUT T HE C O DE

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 OUT O UR P O LI C I E S

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 Front Door.

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LAND O’LAKES, INC. // CODE OF CONDUCT WHY DO WE NEED A CODE OF CONDUCT? Even though no Code of Conduct can address every possible situation an employee might encounter, our Code (with its

Code can, in minutes, tarnish a company reputation that’s been built up over decades.

emphasis on our values, integrity and compliance with the

HOW ARE INVESTIGATIONS HANDLED?

law) provides guidance for situations when the right answer

All reports of possible Code violations will be promptly

is not perfectly clear.

reviewed and investigated as appropriate. We observe con-

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

fidentiality to the extent possible. We also strictly prohibit

“wrong” answer, ask yourself the following:

retaliation against those who make good-faith reports of

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

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? The Code applies to all employees and anyone acting on behalf of Land O’Lakes.

WHAT AM I ACCOUNTABLE FOR?

WHO ANSWERS THE HOTLINE CALLS? CAN I CALL ANONYMOUSLY? Our Connect Hotline is staffed and maintained by an independent third party, not Land O’Lakes. The hotline is staffed seven days a week, 24 hours a day. Callers may speak in their local language and may remain anonymous, except in certain international locations where complaete anonymity may not

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

be permitted under local law. In those situations, we will

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

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.

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

WHAT HAPPENS TO THOSE WHO VIOLATE THE CODE?

the hotline by:

Violations of this Code, Company policies or the laws and

» Phone: In the U.S. or Canada, dial 855-TELL-

regulations that govern our business can have significant

LOL (855-835-5565). International callers

consequences. Besides disciplinary action and even the loss

should dial an operator and ask to call

of employment, there can be civil or criminal penalties for non-compliance. Most importantly, behavior that violates this

470 219 7131. Both are toll-free numbers. » Web: connecthotline.ethicspoint.com

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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 Confidential information is any information that is not public. It includes trade secrets, strategic plans, consumer insights, engineering and manufacturing ideas, product recipes, designs, databases, records, price information and unpublished financial information. Never disclose, or allow the disclosure of, confidential information unless required by law or directed by Company leadership. Use special care in storing or transmitting confidential information, as required by Company policy and our Informa-

cially those relating to discrimination, harassment, confidentiality, privacy and compliance with the law. Take care to protect those assets from theft or damage. Passwords matter! Never share your password and don’t leave your laptop unattended in an exposed location. Land O’Lakes monitors the use of its assets. Employees should not have an expectation that information stored on or transmitted via those assets is private.

tion Classification standard. Honor confidentiality

PROTECT INTELLECTUAL PROPERTY

commitments made to our customers, vendors and

How can employees safeguard the Company’s intel-

business partners. Never disclose their confidential

lectual property?

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 confi-

» 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, tech-

dentiality continues, even if your employment with

nology or unique business solution devel-

Land O’Lakes ends. Likewise, never disclose the

oped while working for Land O’Lakes.

confidential information you learned while working for other employers to Land O’Lakes. If you believe that Company confidential informa-

Respect the intellectual property rights of others as well. Never use intellectual property that does

tion has been stolen or disclosed without permission,

not belong to Land O’Lakes without permission

contact the Law Department immediately.

from its owner.

RESPECT PRIVACY

COMMUNICATE WITH CARE

Members, employees, customers and business partners

Communications are the lifeblood of any business.

all trust Land O’Lakes with sensitive, and sometimes

They also carry substantial risk if done carelessly

private, information. Before collecting, using, shar-

or thoughtlessly. As technology makes communica-

ing or deleting any such information, make sure you

tion increasingly virtual, the nuances of in-person

understand your responsibilities under the Company’s

communication can be lost.

Privacy policy, our privacy notices and any applicable

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

agreements with the information’s owner.

instant messages—they carry the same weight and

USE COMPANY ASSETS RESPONSIBLY

ting “send,” ask yourself how you would feel reading

importance as an old-fashioned memo. Before hit-

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, espe-

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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.

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 or

most common types of conflicts, such as:

private information. » Make sure your communications are consis-

» Gifts and entertainment » Working with family members

tent with the Company policies on Appropri-

» Insider trading

ate Behavior in The Workplace, Confidential-

» Doing business with Land O’Lakes

ity 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 agen-

KEEP ACCURATE BUSINESS RECORDS

cies, including all requests for comment, must be

Land O’Lakes is committed to the integrity of its

directed to the Communications Department.

AVOID CONFLICTS OF INTEREST

records, and requires that all reports, documentation, financial statements and other business records are accurate and comply with all applica-

A conflict of interest is a situation where an employ-

ble accounting procedures and internal controls.

ee’s personal interests conflict with—or even appear

Every employee is responsible for ensuring the

to conflict with—the Company’s best interests. Nothing is more corrosive to an employee’s or business’ reputation for integrity and ethical

accuracy and completeness of business records they create or maintain. Always consult the Company’s Records Man-

behavior than an actual—or even perceived—con-

agement policy and Retention Schedule before

flict of interest. An employee who accepts lavish

destroying any business record. If the record is

entertainment from a vendor, then later chooses

subject to a litigation hold, maintain the record

that same vendor for a lucrative contract, will

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.

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LAND O’LAKES, INC. // CODE OF CONDUCT

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

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

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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 the

A customer needs me to alter the date on a purchase order—something about their accounting rules. Can I help them out? No. All business records must be complete and accurate—no exceptions.

perception that his or her judgment may be clouded by frequent, lavish entertainment. Employees are required to avoid actual—and perceived —conflicts of interest by following the Conflict of Interest policy whenever gifts or business entertainment are offered.

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HOW WE WORK 10


LAND O’LAKES, INC. // CODE OF CONDUCT

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t Land O’Lakes, we have an important purpose. Fulfilling our purpose 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 O’Lakes,

tolerance for discrimination, harassment or other

and nowhere is that more apparent than the safety

forms of inappropriate or unprofessional behavior—

of our employees. Our extensive safety program is

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

designed to create a culture of safety excellence at

or others. These behaviors are not only a violation

every level in the organization.

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 negative effects of inappropriate behavior, and

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, and don’t take shortcuts when it comes to safety.

every employee must hold themselves, and others, accountable for ensuring a culture of dignity,

DRUGS AND ALCOHOL AT WORK

respect and welcome for all.

Our commitment to the health and safety of

Contact any of the resources listed in this Code if you see, hear or experience any inappropriate behavior.

ANTI-RETALIATION

drugs or alcohol at work. Consult the Company’s Drug and Alcohol policy for more information, including alcohol at Company functions.

Land O’Lakes prohibits the retaliation against any

WORKPLACE VIOLENCE

employee who makes a good-faith report of sus-

Another safety priority is preventing workplace

pected or actual violations of the Code or Company policy.

DIVERSITY AND INCLUSION

violence. Contact the Global Security team immediately if someone’s behavior or words creates fear or concern about possible harm to others or to Company property. Except where prohibited by

Diversity and inclusion is vital to our success— and

law, the Company also bans weapons on Company

core to who we are. This means valuing and respect-

property or while acting on Company business.

ing the perspectives, experiences and talents of all individuals. 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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employees includes a ban on the use or abuse of


LAND O’LAKES, INC. // CODE OF CONDUCT

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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? My behavior on my own time is my own business, right? Usually. But there are rare occasions when an employee’s behavior off the job can make it impossible for him or

Never put production ahead of safety. The rules are there for your protection, and that of your co-workers. Follow every safety rule, every time.

her to be successful on the job. In those situations, the personal and 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? You are right to be concerned. Domestic problems can spill into the workplace, with sometimes deadly results. Global Security can provide advice for the location and the employee before anyone gets hurt. Security should be contacted immediately, as well as location management and HR.

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 protected factors violates Company policy and possibly the law. They may also be ignoring a wealth of talent. You should contact any of the resources listed in this Code to report your concerns.

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HOW WE COMPETE 14


LAND O’LAKES, INC. // CODE OF CONDUCT

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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 Antitrust laws, which are designed to promote free and fair competition, make a number of activities strictly unlawful. Never discuss, exchange information or agree with a competitor (or a prospective competitor) about any of the following “prohibited topics”: » Past, present or future bids » Costs, including ingredient costs » Sales data or plans » Customers » Territories or markets » Inventory » Production plans » Market surveys » Prices or pricing policies » Promotions or discounts » Terms and conditions of sale » Profits Refer to the Company’s Antitrust policy for more information and be sure to contact the Law Depart-

and wholesomeness. Product safety and quality are core values. There is nothing more important than the safety and health of the humans and animals we feed. Every employee has a part to play in our quality and safety mission. Be a Product and Safety Champion and be sure to report any concerns to leadership.

MARKETING WITH INTEGRITY At Land O’Lakes, we support marketing that will positively benefit society at large, our sustainability efforts and our purpose. Our sales and marketing practices are grounded in honesty and responsibility in serving our consumers, customers, members and employees. False or deceptive statements do not align with our company value of doing the right thing and our commitment to drive trust in our brands. As leaders and committed partners, we leverage these principles across all sales and marketing

ment with any questions.

channels—including packaging and product labels,

TRADE ASSOCIATIONS/INDUSTRY EVENTS

sorships and all forms of advertising (television,

Whenever competitors gather, such as at trade association or industry events, antitrust risk is present. Any employee who plans to attend such an event must comply with the Trade Association and Industry Event Certification Program prior to the event.

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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regulatory standards for safety, quality, security

sales materials, trade advertising, brand sponprint, radio, digital media, websites, promotions and events). All sales, marketing and promotional materials are reviewed prior to publication by the Marketing and Law departments to ensure our quality standards are met.


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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COM PETITIV E INTE LLIGE NC 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


LAND O’LAKES, INC. // CODE OF CONDUCT

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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 do

As a farmer-owned cooperative, serving as a stew-

business. There are no exceptions and no excuses,

ard of the earth and preserving its natural resources

including pressure from others or the demands of

for generations to come is more than just a way of

the job. There are no work-arounds, such as hiring a

doing business—it's part of our DNA.

consultant or third party to do something employ-

Land O'Lakes employees are expected to go beyond compliance with applicable environmental

ees are prohibited from doing. Every day, every time—we do the right thing.

laws and regulations. They are expected to honor and abide by the Company’s commitment to con-

PROTECTING HUMAN RIGHTS

ducting its business in a manner that is scientifically

Land O’Lakes is committed to protecting fundamen-

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 commitment to complying with the law, whether those

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tal 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 to

laws address employment, competition or the

uphold these principles and others outlined in our

environment.

Supplier Code of Conduct.


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

Our Government Relations Department is respon-

commitment extends to being a leader in our com-

sible for representing the Company on all legislative,

munities. We encourage employees to be engaged

regulatory and public policy issues. They will handle

in their communities—and to decide when and

all requests for information or comment to, or from,

how to contribute their time, money or resources

any public officials or government agencies.

to civic and political activities. However, Company funds may not be used for

Because contact with government officials to influence legislation or policy-making could be

any personal political activities, such as a contrib-

considered lobbying, which requires registration

uting to, or paying the expenses of, a candidate,

and disclosure, be sure to contact the Government

campaign, political party or organization, or office

Relations or Law Department for guidance before

holder.

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. Contact

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? 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.

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

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 Front Door) 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., 2022 | V14:08/2022

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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 Web: connecthotline.ethicspoint.com

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