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RESULTS Bribery and Corruption Heinz has a strict policy against bribery and corruption, which are prohibited by the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act 2010, and similar laws and regulations in other jurisdictions. Heinz does not allow employees to make facilitating payments to government officials and Heinz will not provide entertainment and gifts or anything of value directly or indirectly to government officials so as to influence them in the performance or nonperformance of their duties or induce them to use their influence or secure any improper advantage to obtain or retain business for the Company. See the Company’s “Anti-Bribery” and “Gifts and Entertainment” Policies – CC.07 and CC.08. For example, I am discussing with a government official the marketing of Heinz’s products for the first time in that country. He is insisting that Heinz hire his brother’s consulting firm to help us. What should I do? Consider as a warning flag the official’s insistence on using his brother’s consulting firm. Use caution to confirm this is not a case involving bribery of a government official. Consult the Law Department immediately regarding activities which may violate the U.S. Foreign Corrupt Practices Act. Political Activity - Heinz respects the rights of individual employees to engage in political activity: however, Company funds, resources or time may not be utilized directly or indirectly by an employee for such political activity. Political Contributions - To the extent permitted under local laws and regulations, any Company funds, facilities, or services that are intended to support the democratic process in any country must be pre-cleared with senior management [and the Heinz Board of Directors]. Heinz Highlights All employees must follow Company guidelines relating to environmental management. Do not give money or anything of value to government officials to influence their decisions. Heinz ⏐Code of Conduct⏐2010 19
IN NT TEG GR RI ITY Requests for a waiver of a provision of the Code of Conduct must be submitted in writing to a Compliance Officer within a reasonable period in advance of the proposed conduct. Any such request for a waiver must be approved or disapproved by the Corporate Governance Committee, upon the review and written recommendation of the Executive Vice President and General Counsel. Waivers of certain parts of the Code of Conduct for executive officers and directors must be publicly disclosed promptly in accordance with the rules of the SEC and/or New York Stock Exchange listing standards. Depending on the circumstances, such disclosure could be harmful to the Company and to the officer or director involved, especially in the event of a failure to notify the Company in advance of the conduct or circumstances that might create the need for such a waiver. Material amendments to certain parts of these policies that govern conduct by the Chief Executive Officer and the Company’s senior financial officers will also have to be disclosed in accordance with the rules and regulations of the SEC or applicable listing standards. Heinz reserves the right to change at any time this Code, its policies, guidelines, and related procedures. Nothing in this Code of Conduct confers upon any employee any right with respect to continuation of his/her employment, nor does it constitute an employment agreement or interfere in any way with an employee’s right or the right of the Company to terminate the employee’s employment, with or without cause, and with or without notice. The foregoing sentence is subject to the terms of any written employment contract that the employee may have with the Company that is signed by both the employee and an authorized representative of the Company and subject further to the requirements of applicable law and the Company’s non-retaliation policy for good faith reporting of actual or suspected violations of law or Company policies, such as this Code. Heinz ⏐Code of Conduct⏐2010 20
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 12 and 13: VI IS SIO ON Company loans to, or g
Page 14 and 15: Records Management The Company’s
Page 16 and 17: Competitors Antitrust/Fair Competit

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