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CONDUCT INVOLVING OURSELVES AND OUR FELLOW EMPLOYEES As employees of Heinz, we strive everyday for excellence in the Company’s business, through ethical business practices, innovation, and service with distinction. We must be aware of the impact our conduct has on our business and on the lives of our consumers, customers, fellow employees, and the public. Consequently, we must each be committed to the following: Compliance with Laws Each of us must comply with all applicable laws, rules, and regulations in every jurisdiction in which we do business. See the Company’s “Conduct of Business – Ethical and Legal Standards” policy. – CC.01 These laws include, among others in the U. S., the antitrust laws, securities laws, including the Sarbanes-Oxley Act of 2002, and laws prohibiting insider trading, employment laws, environmental and safety, trade laws, the Food, Drug and Cosmetic Act, along with other applicable federal, state, and local laws, as well as similar laws and regulations of the various jurisdictions around the world where Heinz operates. Equal Employment Opportunity and Policy Prohibiting Sexual and Other Harassment Under the Company’s equal employment opportunity policy, the Company affords full equal employment opportunity to all qualified employees and applicants in conformity with all applicable laws and regulations. If you have any question about applicable legal requirements, you should consult the Law Department. See the Company’s “Equal Employment Opportunity” policy. All personnel decisions, including but not limited to those relating to recruitment, hiring, training, promotion, compensation, benefits, transfers, education, and tuition assistance, will continue to be made based solely upon an employee’s or applicant’s qualifications, skills, performance, and abilities and without regard to any condition or characteristic protected by applicable law. We will strive to enhance the systems, skills and environment that will equip and encourage fellow employees to foster a culture that embraces diversity and inclusion. Under the Company’s policy prohibiting sexual and other harassment, the Company is committed to maintaining a work environment that is free of harassment and will not tolerate harassment of Company employees by anyone, including any supervisor, co-worker, employee or non-employee, vendor, client, or customer of the Company. See the Company’s “Policy Prohibiting Sexual and Other Harassment.” – CC.06 Heinz ⏐Code of Conduct⏐2010 9
& CO C OL LL LA ABO ORA ATION TEAM BUILDING Harassment consists of unwelcome conduct, whether verbal, physical or visual, that is based on a person’s gender, race, age, religion, national origin, or any other status, characteristic, or condition protected by applicable law. Does sexual harassment always involve a manager and a subordinate? No, anyone whose behavior affects someone’s ability to do his or her job can be a harasser, including supervisors, co-workers, or even non-employees, such as vendors or contractors. Harassing conduct that affects any terms, conditions, or benefits of employment, interferes unreasonably with an individual’s work performance, or creates an intimidating, hostile, or offensive working environment, will not be tolerated. For example, sending pornographic images over the Heinz email system violates our sexual harassment and our communications policies. Employees have been and will continue to be disciplined, up to and including termination of employment, for such acts. Worker Health and Safety It is our policy to provide a safe and healthy workplace for all of our employees. As part of this commitment, Heinz expects all employees to perform their duties in a safe manner at all times. All Business Units and facilities are required to comply with all applicable laws regulating workplace safety and must implement the Heinz Safety Process as outlined in Heinz’s policies and procedures. See the Company’s “Corporate Safety Policy.” – RM.04 Privacy and Confidentiality At Heinz we will strive to comply with all laws which protect the privacy and confidentiality of employees’ personal, medical, and financial records and information. Such information will only be used or disclosed to the extent authorized by the employee or permitted or required under applicable law. Each employee recognizes that he or she should not expect privacy when using Company provided services and equipment subject to applicable local laws and regulations. The Company reserves the right to inspect its facilities and property, including computers, telephone records, lockers, email, internet usage, business documents, offices, and other workspaces, subject to applicable local laws and regulations. Heinz Highlights Each of us is required to comply with all applicable laws. All employees will be treated fairly and with respect. Heinz is committed to a work environment free of discrimination. Heinz will not tolerate harassment of our employees by anyone. Heinz is committed to providing a safe and healthy workplace. Heinz will protect employee privacy and our confidential information. Heinz ⏐Code of Conduct⏐2010 10
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