Owner’s Mindset
We think and act like owners—where everyone takes personal responsibility to anticipate challenges, proactively search for opportunities, and make decisions that are in the best interest of the company.
Accuracy of Books and Records
We are responsible for ensuring that Ingredion’s business records are accurate and complete.
Living our Values
Ingredion’s public disclosures and flings are based on the accuracy and truthfulness of our books and records. Our company books and records must be complete, accurate, and reliable, and must follow Generally Accepted Accounting Principles. Each of us plays a role in ensuring that Ingredion’s business records are accurate and complete:
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Follow all internal controls and finance policies, including travel and expense policies
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Follow applicable laws, regulations, industry standards, and company policies when you produce, store, or destroy records and documents
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Speak up if you detect fraud or notice an inaccuracy in a company record or a failure to follow our internal controls
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.
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Our Value in Action
Q: I am new to my department. When I started my new position, I was told by a colleague that it was okay to delay accruing certain expenses until the next period. He said, “If we move them to next fiscal year, we are not doing anything wrong.” Is that true?
A: No. Deliberately delaying the accrual of expenses, regardless of the amount, would be a misleading, unacceptable, and possibly unlawful practice. Every business and financial transaction, however immaterial, must be reported accurately and honestly. Falsifcation of any company document or record is a serious offense and could result in termination of employment.
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Our Value in Action
Q: I work in Quality Assurance and we are running late in releasing a load to a customer. The pass/ fail for the test I am running is 2.0 g/ml and the test result came back at 2.1 g/ml. I know that this customer has received late deliveries at least three times in the last six months. If I reject this load, this may result in a fourth late delivery. What should I do?
A: Record the test result accurately. It is important for the company to maintain accurate books and records. Our customers and ingredient consumers are depending on us.
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
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Our Value in Action
Q: I went to my doctor for a routine visit. At the end of my appointment, the doctor asked me how Ingredion stock was doing and whether he should invest in Ingredion. I have known my doctor for many years. I think a modest investment in Ingredion could help him recover some of what he lost after the global fnancial crisis. Can I tell what I know about upcoming product launches or recommend Ingredion stock to him?
A: No. Details of upcoming product launches are material, nonpublic information that could provide your doctor with an unfair trading advantage. Sharing that information would be illegal and could result in prosecution.
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 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.
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Our Value in Action
Q: On LinkedIn, I noticed that a user posted a question on my profile about a potential acquisition. The news media had already discussed the acquisition, but no official announcement had been made. May I comment on the post?
A: No. Information about the potential acquisition is confidential company information. If the media chooses to speculate, then that is their choice. Your publicly commenting may result in legal consequences and reputational damage for the company. Even after the acquisition has been publicized by Ingredion, commenting can reveal undisclosed information. Refer any negative mentions of the company that you notice on social media to Corporate Communications. Do not attempt to respond on your own.
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Our Value in Action
Q: After a positive meeting with leadership, a senior leader sent out a tweet from his private Twitter account: “Good meeting. Good numbers = Happy Board.” Ingredion’s official earnings announcement was due to be released to all investors later in the week. However, the tweet was from his private account so there’s no problem, right?
A: Wrong. If the official earnings have not been announced, the leader’s Twitter followers may be considered to have access to insider information, which can have significant legal and reputational consequences for the company and the individual who issued the tweet. Report this type of finding to your local Human Resources or through the Ingredion Business Ethics Line.
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 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 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 its 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.
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Our Value in Action
Q: I am working on an M&A project with a crossfunctional team. At the end of a meeting, some of the team members continued discussing the status of the deal during the walk to a local restaurant. Is this a problem?
A: Yes. Information related to an M&A deal is confidential. Outside the meeting room, individuals who do not have a legitimate need to know may overhear confidential information. Take care not to disclose company confidential information in public places.
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Our Value in Action
Q: I can get a lot of things done by returning calls while waiting to board fights or trains. Is this a problem?
A: Be careful not to discuss nonpublic company information in public places where others may overhear you, such as taxis, elevators, at conferences, and particularly at trade shows. When it is necessary to conduct a telephone call in a public place, be mindful of your surroundings.
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