Owner’s Mindset

Accuracy of books and records

We are responsible for ensuring that Ingredion’s business records are accurate and complete.

NEVER falsify, omit, misstate, alter, or conceal any information or otherwise misrepresent the facts on a company record.

NEVER encourage or allow anyone else to compromise the accuracy and integrity of our records.

NEVER keep hidden or unrecorded funds, accounts, or assets.

Records management

We are committed to managing our documents and other recorded information consistently and in accordance with relevant legal obligations and business needs. We must:

• Comply with our Records Management policy for all documents, files, electronic records, and emails. Information that relates to personal information of employees requires special care
• Follow the retention periods specified in the Records Retention Schedule for your country and function
• Follow the instructions in a Legal Hold notice. Destruction of information subject to a Legal Hold, even inadvertently, could expose the company and you to civil and criminal liability

What is a record?

Information recorded in any medium, hard copy or electronic, in the company’s custody or control that relates to its business is considered a record.

A variety of information categories may be considered records. Some examples include fnancial statements, presentations, diagrams, illustrations, formulas, spreadsheets, payroll documents, time cards, attendance records, legal agreements, inventory records, invoices, purchase orders, contracts, market research tests, lab tests, quality control tests, data related to our products, travel and expense reports, inspection records, transportation, logs, hazardous material records, accident reports, and business plans.

Insider trading

We do not use or share confidential, nonpublic information about Ingredion or any other company for the purpose of buying or selling Ingredion stock or the stock of any other company.

Living our values

While working for Ingredion, you may learn or have access to nonpublic information that could be relevant to an investor. This information, called “material nonpublic information” or “inside information” consists of nonpublic information that an investor would consider important in making an investment decision.

In order to protect investors, securities laws have special procedures for those with material inside information about a company or its securities to trade in its securities. We are prohibited from unauthorised disclosure of the company’s or others’ confidential, nonpublic information. To prevent insider trading:

• Never trade in Ingredion shares or any other publicly traded company while aware of inside information concerning any applicable company or securities
• Never share inside information with anyone outside of Ingredion, including immediate family, relatives, or friends
• Take care to protect inside information from accidental disclosure by being careful with company documents and talking discreetly
• Avoid tipping: passing along material, nonpublic information about Ingredion or any other company to anyone who may trade in securities

External communication and social media

Having an Owner’s Mindset means we embody a culture of personal accountability in everything we do, including our communications. We communicate truthfully, factually, and responsibly about Ingredion.

Living our values

We are committed to engaging our customers and stakeholders through efective communication. Social media, such as social networking sites, blogs, photo- and video-sharing sites, forums, and chat rooms have provided us with new ways to engage and collaborate with others. We embrace these communication opportunities, and we are committed to using them responsibly. This means we:

• Communicate truthfully and accurately about Ingredion and always through the authorised Ingredion communications channels
• Identify opinions as your own unless you are authorised to speak on behalf of the company
• Never post, discuss, or disclose confidential information belonging to Ingredion or entrusted to us by customers or others
• Do not use Ingredion’s logos, trademark, or copyrighted materials when using social media outside of work
• Do not post confidential information, images, photos, videos, or audio clips of Ingredion facilities without written permission
• Refer all media inquiries to Corporate Communications or Investor Relations (or the local equivalent of these functions in your region)
• Never use Ingredion communication systems or information technology to post harassing or discriminatory content, or anything that could reasonably make others feel bullied or threatened

Confidential information

What is confidential information?

Confidential information includes nonpublic information that, if improperly disclosed, could be useful to competitors or harmful to Ingredion, our suppliers, our customers, or other organisations or people. Confidential information might be relevant in an investor’s decision to buy, sell, or hold Ingredion securities or the securities of any of our business partners.

Confidential information is generally something of commercial value to Ingredion, for example, earnings forecasts, business plans, strategies, and signifcant restructurings or investments; potential mergers, acquisitions, or divestitures; pricing, sales information, research, new product development, formulas and product recipes; manufacturing processes; undisclosed marketing and promotional activity, signifcant management changes; draft or unpublished accounts; and events regarding Ingredion securities would all qualify as confidential information. We must recognise when something is confidential and take steps to keep that information secure, and not lost, damaged, or given away accidentally.

Disclosure of nonpublic, material information, whether intentional or inadvertent, may trigger certain public disclosure requirements for the company. Employee information, including particularly sensitive personal information, such as health records, should also be kept confidential and only accessed by the Ingredion staff who need to know that information for the purpose of their role, for example to an employee’s manager.

Living our values

While working at Ingredion, you may have access to confidential information of our customers, suppliers, business partners, or other organisations or people. We must always take reasonable precautions to prevent its unauthorised disclosure. Protect confidential information:

• Do not disclose the confidential information of one customer to another
• Disclose confidential information only to those who are authorised and have a business need to know it
• Do not share confidential information with anyone outside our company without proper authorisation

Contact the Business Integrity department or your local Legal department immediately if you know or suspect that information was mishandled in any way, even inadvertently, or is at risk.

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.

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 and inclusion | Harassment and discrimination | Anti-violence and intimidation | Report concern

Innovate Boldly: Intellectual property and company assets | Email and internet information systems | Report concern

Owner's Mindset: Accuracy of books and records | External communication and social media | Confidential information | Report concern

Ethical Standards: Living our values | Compliance with policies | Business integrity | Report concern