Care First
We actively work to safeguard and enable the well-being of our people, the quality of our products, and our reputation for trust and integrity.
Quality and Food Safety
We provide products and services that fulfil our customers’ requirements and meet applicable governmental requirements.
Living our Values
We are committed to providing safe and high-quality products, services, and solutions, and need to be constantly up-to-date about customers’ desires and needs. We actively look to obtain and then listen to customer feedback. If our job duties involve any aspect of developing, handling, packaging, or storing Ingredion products, we must:
- know the applicable quality standards, policies, and procedures that apply to the products at the applicable manufacturing location
- follow good manufacturing practices and testing protocols
- comply with all applicable Ingredion manufacturing safety policies and all applicable laws and regulations, such as those relating to safety and quality with an emphasis on protocols that address consumer concerns relating to children.
Our Values in Action
Q: As an operator, you discover that there is a possibility that small metal pieces might contaminate a product, which is intended to be food grade. You believe that our procedures for screening processes are such that it is unlikely that a product contaminated with metal would be delivered to a customer. However, you know that some of the company’s customers do not have adequate means to screen for metal if contaminated products were delivered. Do you shut down the equipment causing the possible contamination, even if it means a slight decrease in production?
A: Yes. We never compromise quality or food safety, and immediately report (through the appropriate channels) any concerns about product safety or quality. Remember that this reporting will be confidential information about Ingredion. Contact your local Quality Management representative to discuss your concerns regarding product safety and quality.
Environment, Health, Safety, and Security
We strive to protect the environment and are committed to providing our employees with a safe and secure workplace. We strive for zero injuries and strive to be a global leader in workplace safety.
Living our Values
Environmental stewardship, workplace safety, and security are integral parts of our culture. Our commitment includes:
- acting in compliance with the environmental laws and regulations in the countries in which we operate
- following the environmental and safety policies, practices, and procedures applicable to our workplaces
- taking a proactive approach to environmental challenges by continuously seeking ways to protect natural resources, reduce our environmental impact, go beyond compliance, and create efficiencies while upholding product safety and quality standards
- promoting dialogue and innovation to improve workplace safety
- reporting and correcting unsafe or unhealthy conditions or behaviors, as well as incidents that may lead to spills, releases, or environmental non-compliance
- not using or possessing illegal drugs or controlled substances or working under the influence of drugs or alcohol in the workplace or while we are engaged in any job-related activity.
Human Rights
We respect the rights of workers throughout our supply chain, including contractors and suppliers.
Living our Values
We recognise the rights of our employees and those with whom we do business to be treated with dignity and respect, and in accordance with applicable laws. We expect our business partners to do the same. We will not tolerate the exploitation of children or the use of forced labour or human trafficking. Our respect for human rights means:
- Upholding the United Nations Guiding Principles on Business and Human Rights
- Performing appropriate due diligence on potential business partners
- Following our procurement policies when selecting new suppliers
- Paying fairly in the market and meeting or exceeding all legal requirements related to employee pay and benefits
- Respecting employees’ rights to organize and bargain collectively
Ingredion’s supplier partners must ensure that their workforces are free from child labour and any forms of forced labour, including slave, indentured, bonded, prison labour, or any form of human trafficking. Ingredion does not engage in or support the use of child labor.
Ingredion will make reasonable exceptions where the young workers are under the age of 18 if the young workers,
- exceed the local legal definition of a child;
- are working outside of school hours as defined by compulsory educational laws;
- the work is non-hazardous; and
- the job is an apprenticeship in line with requirements for their schooling.
Ingredion’s supplier partners must ensure that their workforces are free from child labour and any forms of forced labour, including slave, indentured, bonded, prison labour, or any form of human trafficking.
Our Values in Action
Q: Our due diligence on a supplier’s farm reveals that the farmer is paying less than the legal minimum wage. What should we do?
A: Contact the head of Corporate Sustainability. This farmer must pay the workers at least the minimum wage for each hour worked.
Sustainability
We strive to be an exemplary corporate citizen and community member and we work to make a positive, lasting impact on the communities where we work and live.
We operate with care and respect for the planet, our employees, and the communities in which we operate. We believe in creating a better, more sustainable business while delivering shared value to our stakeholders. And we believe in conducting business today in a way that protects our ability to continue to do business in the future.
Living our Values
We are committed to promoting sustainable practices throughout our organisation and adhering to high moral and ethical standards wherever we do business. From our high safety standards to our investments in operational excellence, to our efforts in environmental conservation, and our community stewardship activities, we believe that operating in a sustainable manner benefits more than our business; it benefits the communities where we operate. Ingredion is a member of the UN Global Compact and takes a “precautionary approach” to environmental protection.
Agricultural Sustainability
Ingredion believes in supporting the long-term sustainability of the agricultural and farming operations that provide us with raw materials. To that end, we seek to:
- promote safety in the production, storage, handling, and delivery of crops among the farmers who supply our raw materials
- encourage the efficient use of natural resources in farming and related activities to minimise potential environmental impact, reduce impact to water, and support the viability of agriculture and biodiversity for generations to come
- support the use of approved biotechnology (which may differ from country to country), and understand consumer preferences with respect to genetically modified organisms
- oppose the use of child and forced labour acting in accordance with local laws and globally accepted standards
- promote the responsible treatment of migrant workers doing business with our agricultural suppliers
- practice fair and ethical trading practices to promote the economic well-being of the communities in which we do business
- support reduction of pesticide use and promote integrated pest management.
Water Stewardship and Climate-Related Risk
Ingredion recognises the rights of all people to clean water, and as good stewards of the environment, we strive to reduce the impacts of our operations on the climate by:
- recognising that water is a significant, key raw material in our processes and may compete with other needs in water-scarce regions
- setting goals to reduce the water and CO2 intensities across our operations
- aligning our global operations with universally recognised principles on the environment as a signatory to the Global Compact
- utilising the United Nations Development Programme Sustainable Development Goals as a benchmark to better align our sustainability efforts with the greater needs of society
- designing and operating environmentally-sound supply chains as appropriate and working with our suppliers to educate and improve sustainability across our supply chain
- procuring sustainably sourced materials in areas where we have the ability to influence our suppliers
- educating our communities on the importance of water conservation
- advancing our commitment to continuous improvement through the exploration of innovative solutions to reduce the environmental impact of our operations, including water conservation and energy efficiency endeavours.
Privacy and Protection of Personal Information
We safeguard personal information entrusted to the company.
What is personal information?
Personal information (“PI”) is any data that could potentially identify a specific individual. PI must be protected until its secure disposal. Examples of PI include contact information, such as residential addresses, phone numbers, or email addresses; government assigned identification numbers; financial information such as banking details, salaries, and other compensation information; and employment data, including birth dates.
Living our Values
Personal information entrusted to us can belong to our employees, customers, or outside organizations. Keeping personal information secure is critically important to our employees, our business, and our reputation. Some Ingredion employees work with PI (including particularly sensitive personal information, such as health information) as a part of their jobs. If you work with PI, follow the company’s applicable policies regarding the access, transfer, and use of this information. Remember:
- follow local data protection and privacy laws
- only access, collect, and use personal information that is necessary for your job and that you are authorised to see for legitimate business reasons
- do not keep personal information for longer than required for the business purpose
- disclose personal information only to authorised persons who have a legitimate business reason to know the information and who are obligated to protect it
- securely store, transmit, and destroy personal information in accordance with applicable policies and laws
- promptly report any actual or suspected unauthorised access, data breach, or other risks to personal information to the IT department, HR, your local Legal Department, or the Data Protection Officer in your region, if you have one.
Our Value in Action
Q: I believe that one of my colleagues is selling employee email addresses to a marketing company. What should I do?
A: Employee email address lists are confidential and may not be disclosed in this way. Provide all the information you have on this issue to your manager, HR representative, Business Integrity, or a member of the Legal Department.
Anti-Bribery and Corruption
We win business based on the integrity of our employees, products and services, as well as commercial excellence and the exceptional customer experience we provide. Ingredion is committed to fully complying with all applicable anti-money laundering (AML) and terrorist finance laws, rules and regulations. We do not seek or maintain business by trying to corrupt the judgment of our customers or government officials. This applies equally to other parties engaged to act on our behalf. We do not tolerate or engage in bribery. That is, we do not exchange payment for government influence or to obtain a commercial advantage.
Most countries have anti-bribery laws that prohibit bribing a government official. Under some country laws, such as the UK Bribery Act, bribing anyone else (commercial bribery) is also a crime. In addition, all Ingredion employees, regardless of personal location or place of business, must comply with the U.S. Foreign Corrupt Practices Act (FCPA) as a result of the parent company “Ingredion” being based in the U.S. The FCPA makes bribery of government officials a crime and applies wherever Ingredion does business.
To comply with anti-bribery laws, do not offer— directly or indirectly—any form of gift, entertainment, inducement, or anything of value to any government official or his or her representatives to obtain or retain business; influence business decisions; or secure an unfair advantage.
These prohibitions apply to our business operations, partners, and to anyone acting on our behalf, including agents, consultants, suppliers, and contractors.
Some government payments are not forbidden. For example, payments may be made to a government entity in the normal course of business, to pay taxes or when the government entity is a customer or supplier. However, payment of any kind of bribe or facilitating payment to a government official in any country is prohibited. Facilitating payments are discretionary payments to government officials intended to expedite or ensure routine actions – such as issuing licenses, permits, or visas. If you receive a request from a government official for a bribe or facilitating payment, you must decline to make the payment unless you have a reasonable good-faith belief that failure to make the payment may subject you or others to physical harm. You must also report the request for a bribe or facilitating payment promptly and directly to your manager, the Legal Department, Business Integrity Department, or through the Business Ethics Line.
Note that there are some governmental agencies with formal provisions for paying a fee, for example, to expedite permit review. Those transactions, where payment does not influence the final decision on the permit and is used to pay for the resources and personnel necessary to expedite processing, are not considered facilitating payments.
Who is a Government Official?
The FCPA defines foreign official as “any officer or employee of a foreign government or any department, agent, or instrumentality thereof.” Government official includes a person who works for or is an agent of a government or government-owned or government-controlled entity. Examples of government officials include:
- an officer or employee of a government entity, department or agency
- an officer or employee of a state-owned business, school, hospital or other entity
- an officer, employee, or official of a political party
- a candidate for political office
- an officer, employee, or official of a public international organisation, or any department or agency of such organisations (such as the IMF or World Bank)
- a person acting in an official capacity on behalf of a government entity
- an officer or employee of a state-owned or state-controlled commercial enterprise
- other persons with government influence, such as an individual with a close personal or family relationship with a government official.
As the last item on the list shows, the definition of government official is not always simply someone holding the government job.
Living our Values
Corruption can take many forms. It is important that our partners and anyone engaged to act on our behalf are aligned with our standards and expectations and uphold our commitment to do business with integrity and in accordance with applicable laws. When dealing with external organisations, be aware of the warning signs that require further investigation before hiring or working with someone from outside Ingredion, such as:
- refusal to agree to Ingredion global standards or anti-corruption contract provisions
- inconsistencies or misrepresentations in the due diligence process or a reluctance to cooperate
- requests for unusual payment arrangements, such as payments in cash or payments to be made to a third-party intermediary (e.g., not to the vendor who is providing the services)
- requests to make charitable donations
- recommendation of a party by a government official
- hiring a relative of a government official or even the offer of an internship to the relative
- commission or fees higher than the going rate
- a reputation for questionable business practices
- close social, business, or family ties to a government official.
When selecting and retaining suppliers, always:
- follow our applicable bidding, negotiating, and contracting processes
- avoid potential or actual conflicts of interest with suppliers
- include FCPA clauses in all Ingredion supplier contracts
- perform appropriate due diligence to determine whether the supplier is a legitimate enterprise, has a reputation for integrity and ethical behavior, is connected with anyone from a government or a government organisation, or if the supplier has ever engaged in unlawful activities.
For guidance on supplier due diligence, contact your local Legal contact.
Our Value in Action
Q: It has been suggested that I give a $20 “tip” to an employee of a government-owned telephone company to ensure a telephone line is installed on time at a company office. Could giving such a small amount, even out of my own pocket, be against the law?
A: Yes. You need to contact your local Legal department, Business Integrity department, or the Business Ethics Line. The transaction would be considered a facilitating payment, which would be prohibited under our Ingredion policies, regardless of the amount. Paying from your own funds on Ingredion’s behalf does not change the nature of the payment. It is a bribe. Even if, thoughtlessly, the payment had already been made, it must still be reported in the company’s accounts.
Our Value in Action
Q: A local inspector visits an Ingredion plant regularly. Recently, the inspector stated that he found deficiencies and threatened to shut down the plant unless the plant manager agreed to make a cash payment to the inspector. The plant manager is concerned about any disruption to production. Since the amount requested is small, she thinks it would be okay to make the payment if it keeps the plant operating. Is she correct?
A: No. The plant manager may think she is helping Ingredion by avoiding disruption at the plant. However, giving anything of value to the inspector under these circumstances would be considered a bribe, as the payment was intended to influence the inspector’s review of the facility. She must not agree to make the payment—and she should contact the Legal Department, Business Integrity, or the Business Ethics Line immediately.
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