Owner’s Mindset

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 unauthorized 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 effective 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 authorized Ingredion communications channels.
• Identify opinions as your own unless you are authorized 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. We 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.

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 organizations 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 significant 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, significant management changes; draft or unpublished accounts; and events regarding Ingredion securities would all qualify as confidential information. We must recognize 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 organizations or people. We must always take reasonable precautions to prevent unauthorized disclosure. Protect confidential information:

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

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.