Download the Heinz Global Code of Conduct (PDF)

More documents

Recommendations

Info

VI IS SIO ON Company loans to, or guarantees of obligations of, Directors and executive officers are prohibited. Loans to all other employees are also prohibited, other than pre-approved relocation loans in connection with the relocation of management employees. The Company will avoid work situations that create a direct supervisory/reporting relationship between relatives and will avoid where possible an indirect supervisory/reporting relationship between relatives. See the Company’s “Conflict of Interest Policy.” – CC.02 The Board and/or the Corporate Governance Committee, as appropriate, will address any conflict of interest question involving a Director, the Chief Executive Officer, or a member of the Office of the Chairman. The Chief Executive Officer will address any conflict of interest issue involving any other officer of the Company. Use of Company Assets All employees are responsible for the proper use of Company assets, such as information, materials, supplies, Company time during the work day, intellectual property (including our valuable brands), facilities, software, inventory, equipment and other assets owned or leased by the Company or that are otherwise in the Company’s possession. Employees must take all reasonable steps to ensure the Company’s assets are protected from theft, destruction, or other loss. For example, Maxwell, a Heinz employee, had a small real estate business “on the side.” On occasion he would spend an hour or two during work hours talking with clients to close a deal. He also used the Company copy machine and fax equipment in connection with real estate transactions. This was an inappropriate use of Company assets, which may ultimately cost Maxwell his job at Heinz. The personal use of Company assets without Company approval is prohibited. All employees must protect Company assets. Any employee theft, fraud, embezzlement, or misappropriation of Company assets is a serious issue for which termination of employment is the likely disciplinary action. Company Books and Records and Financial Integrity Our financial and other policies are driven by the principle of maintaining the highest level of financial integrity at all times. To this end, employees must strive to: Comply with this Code and the Company’s financial and non-financial policies. Ensure full, fair, timely, accurate, and understandable disclosure in the Company’s filings with the SEC. Provide the Company’s Directors, employees, consultants, and advisors involved in the preparation of the Company’s disclosures to the public with information that is accurate, complete, objective, relevant, timely, and understandable. Act in good faith, responsibly, and with due care, competence, and diligence, without misrepresenting material facts or allowing your independent judgment to be influenced by others. Record or participate in the recording of entries in Heinz’s books and records accurately, to the best of your knowledge. Comply with the Company’s disclosure controls and procedures and internal controls and procedures for financial reporting. Comply with the notification requirements for financial reporting issues as set forth in the Financial Policy “Notification of Financial Reporting Issues.” – FAR.19 Heinz ⏐Code of Conduct⏐2010 13
IN NNOVATION The Audit Committee has adopted a policy for the receipt, retention, and treatment of complaints and concerns regarding accounting, internal control, and auditing matters, a copy of which is available on Heinzweb. See the Receipt, Retention and Treatment of Complaints and Concerns Regarding Accounting, Internal Accounting Controls and Auditing Matters – CG.09. Under this policy you must report any concerns, grievances, or complaints covered by this policy to the Executive Vice President and General Counsel of the Company, the Vice President Enterprise Reputation and Risk Management (ER²M) and Ethics and Compliance, any attorney in the Company’s Law Department, the Senior Vice President - Corporate Audit, or any auditor in the Corporate Audit Department. Alternatively, you may call the Ethics and Compliance Hotline, noted at Page 8 above. At your request, the Company will treat your report with confidentiality to the fullest extent possible, as explained more fully in the Policy. You may also make your report anonymously. You will not be punished, penalized or subject to retaliation for reports you make in good faith. For example, if on the last day of the fiscal quarter, your supervisor tells you to record as a sale some items that have not yet been received by the customer, and won’t be for a day or so, you have a responsibility to speak up and advise a Heinz internal auditor or Compliance Officer of this requested violation of Heinz revenue recognition policies. The Audit Committee has adopted this rule in order to “escalate” serious potential financial issues to the highest levels in the Company so that we can protect our financial reporting process and continue to provide transparent reporting to our shareholders. Confidentiality Employees must maintain the confidentiality of information entrusted to them by the Company or our customers and suppliers, except when disclosure is authorized or legally mandated. For example, after the first round of negotiations with a vendor over a new supply agreement, Maria, a Heinz employee, found some Heinz documents labeled “Confidential” in the conference room. She picked them up and turned them over to the Heinz manager running the negotiations. Was this the right thing to do? Yes, Maria was right to protect the confidential Company information by picking up the documents rather than leave them in the conference room for others not associated with the negotiations to view. Security All Heinz facilities are committed to offering secure workplaces and providing for the safety of employees and the Company’s products. The Company has established policies and procedures to safeguard the security of its products, facilities, and employees. See the Company’s “Facility and Food Security” policy. – RM.02 Crisis Management and Leadership Heinz has implemented plans at our locations and facilities for handling crises such as accidents, natural disasters, or criminal acts. Heinz provides training to our managers and other personnel to help prevent crises from occurring and to deal with crises when they do occur. Heinz ⏐Code of Conduct⏐2010 14
Page 2 and 3: MISSION STATEMENT AND VALUES ......
Page 4 and 5: It is, and has always been, the pol
Page 6 and 7: High standards of behavior are expe
Page 8 and 9: CONDUCT INVOLVING OURSELVES AND OUR
Page 10 and 11: CONDUCT INVOLVING OUR CONSUMERS AND
Page 14 and 15: Records Management The Company’s
Page 16 and 17: Competitors Antitrust/Fair Competit
Page 18 and 19: RESULTS Bribery and Corruption Hein

Download the Heinz Global Code of Conduct (PDF)

Create successful ePaper yourself

Delete template?

Save as template?