code of conduct - ethicspoint symbol of our ideals and history 10 our commitment to the united...

Code of Conduct

Introduction 3

F.A.M.I.L.Y – Our DNA 5

F.A.M.I.L.Y – We are Hellmann 6

First, People First 6

All About The Customers, Always 6

Making It Work Better, Everyday 6

Innovation and Entrepreneurship 6

Live Sustainability 7

You and Me 7

About Hellmann 8

Fourth generation, family-owned 9

The geese 10

A symbol of our ideals and history 10

Our commitment to the United Nations

Global Compact (“UNGC”) 11

Introduction 12

Human rights and labor principles 13

Social responsibility 14

Environmental sustainability 15

Anti-corruption 16

Our code 18

Policy statement 19

Antitrust 20

Restrictions 22

Fair and equal employment 23

Conflicts of interest 25

Conflict of interest defined 26

Prohibition of use 27

Full disclosure and reporting 27

Confidentiality 28

Information security 30

Complaints and comments 32

Reporting 33

Non-retaliation 33

Changes to this code 33

2

Code of Conduct

Contents

Contents

Introduction

The Hellmann Code of Conduct makes com-

pliance with the highest standards of business

conduct mandatory for every Hellmann director,

officer, manager, employee, agent, subsidiary or

affiliate (collectively “Hellmann”). Adherence to

the principles in this Code of Conduct and the

compliance program, manuals and polices of

Hellmann is essential to the efforts to gain and

keep the confidence and support of our custo-

mers, service providers and employees. Most im-

portantly, compliance is a moral necessity.

The world in which Hellmann operates today

has become, and continues to grow, increa-

singly complex. These complexities create new

ethical challenges as we adapt ourselves and

our business to new and unfamiliar situations.

These are the reasons why Hellmann needs a

central set of guiding standards to act as a le-

gal and moral roadmap for the company and

its employees.

While each section below has a specific purpose,

together, they provide an integrated approach

and insight into our core values and the way in

which we globally conduct business. This Hell-

mann Code of Conduct and compliance program

reflects our commitment to do what is required,

legally and ethically. These principles are neces-

sary not only to meet the ever-changing require-

ments in the areas where we operate, but also to

efficiently and effectively manage the operations

of Hellmann.

We expect all of Hellmann to understand and

follow the requirements of the compliance pro-

gram, this Code of Conduct, our policies and

procedures and local and applicable laws. The

Hellmann compliance program and this Code of

Conduct provide guidance in recognizing and

dealing with ethical issues, providing mecha-

nisms to report unethical conduct and fostering

a culture of honesty and accountability.

4

Code of ConductIntroduction

The essence of Hellmann Worldwide Logis-

tics, is best embodied in our corporate DNA:

F.A.M.I.L.Y.

First, People First

All about the Customers, Always

Making it Work Better, Everyday

Innovation and Entrepreneurship

Live Sustainability

You and Me

Hellmann prides itself on having always been a

family-owned and run business, with each ge-

neration looking after its growth and reputation

in the marketplace for the next generation. Our

current owners, Jost and Klaus Hellmann, con-

tinue to be directly involved in the day to day

management of the company, instilling in every

employee the spirit of belonging and the need

to put others before themselves – in essence:

F.A.M.I.L.Y. Our corporate genes and family va-

lues continue to inspire the way everyone within

our global network thinks and acts – from coun-

try to country, branch to branch and employee

to employee, ensuring the longevity of the Hell-

mann philosophy for many years to come.

Our overall focus is on providing longevity and

sustainability as we develop partnerships with

our customers. Our flexibility, the fact that we

are privately held and our financial stability, dis-

tinguish us from our competitors. We personalize

our relationships enabling us to form partner-

ships. We are confident that you will also feel

our sincerity and commitment not only in this

partnership relationship but also as part of our

family.

Our goal today remains the same as it was when

Carl Heinrich Hellmann founded the company in

1871 – maintain customer satisfaction by crea-

ting customer value.

5

Code of Conduct

F.A.M.I.L.Y – Our DNA

Introduction

F.A.M.I.L.Y – We are Hellmann

Family defines not only who we are, but

also forms the basis of our Corporate DNA:

F.A.M.I.L.Y. Ultimately, we see our Corporate

DNA as being far more than mere words on

a piece of paper. Our corporate genes and

family values continue to inspire the way

everyone in our global network thinks and

acts - from country to country and from ge-

neration to generation. They also continue to

determine the integrity and mutual trust with

which we build both our business and our

partners‘ business.

First, People First

At Hellmann, we create and sustain a fun, sti-

mulating and empowering environment that

attracts, retains, and nurtures good people.

Through training, compensation and recog-

nition, we encourage our people to develop

their talents in an atmosphere of mutual res-

pect and trust. Our people are the essence of

our success: They determine our customers‘

perception of our organization. They directly

affect the customers‘ satisfaction and loyalty

– and we understand that!

All About The Customers, Always

We are continuously looking for ways to en-

hance our ability to add value to our services

so we can surpass our customers‘ needs and

expectations. We strive to deliver the experi-

ence our customers truly want, everywhere

around the world, by listening to them and

by taking time to know and understand them

better. We take great pride in being a custo-

mer oriented organization, making sure that

we have our customers in mind in every task

we perform.

Making It Work Better, Everyday

Through business processes and high quali-

ty standards, we increase our organizational

agility and operational efficiency. We look for

every opportunity to minimize costs through

improved productivity and excellent vendor re-

lations in order not only to add to our bottom

line but also to enhance our value proposition

to our customers.

Innovation and Entrepreneurship

At Hellmann, we foster creativity, innovation

and entrepreneurship throughout the compa-

ny, creating an environment where it is ok to

take risks. We encourage our people to think

out of the box and relentlessly promote service

customization to keep abreast of the continu-

ally changing needs and expectations of our

customers.

6


Live Sustainability

At Hellmann, we are serious about providing

services based on the principles of economic-

al, ecological and social sustainability to create

new opportunities for future generations. We are

sensitive and responsible to the people, commu-

nities and environments within the regions in

which we are active. Through these principles of

sustainable development, we ensure the future

of our family-owned business.

You and Me

Every day, “You and Me” take on new goals and

challenges, whether it is a shipment having to

reach its destination successfully, a particular

work process undergoing modification, or new

concepts being developed, “You and Me” make

it happen. “You and Me” stands for our commit-

ment to one another, enlightening us in times

when we really need each other‘s support, inspi-

ring us to lend a hand to others when necessary

and motivating us to work together. “You and

Me” relationships that last generations!

7


About Hellmann

Founded in 1871, our company started with

one man, Carl Heinrich Hellmann, using a horse-

drawn cart to deliver parcels in and around the

town of Osnabrueck, northern Germany. Four

generations later, Carl’s great-grandchildren,

Jost and Klaus, own and run the company with

an active network in 157 countries. Today we

operate a truly global organization while re-

membering our humble beginnings: We con-

tinue to value every customer and understand

that each project requires a unique solution. This

powerful combination of an individual approach

within an international framework ensures that

we deliver top-quality customized logistics solu-

tions, every time.

We constantly strive to develop better, more

efficient ways to do business, whether it is

by implementing cutting-edge technology, in-

creasing the number of services we provide,

or expanding our network of branches and

warehouses. This dynamic mind-set is reflected

in our slogan “Thinking Ahead, Moving For-

ward” and demonstrates a tradition of innova-

tion which is incorporated in every part of the

Hellmann Group.

Our adaptability has been and continues to be

possible because of the quality of our people. We

actively seek to hire capable and committed em-

ployees and to create a working environment in

which they can fully realize their potential while

delivering results which guarantee our success

and your satisfaction.

Our company’s transition from a one-man com-

pany to one of the world’s leading logistics pro-

viders is a result of all these factors. They are the

cornerstones of our business and are the reason

for past achievements, the foundation for future

success, and the values which make Hellmann

the right choice for you today.

9

Code of Conduct

Fourth generation, family owned

About Hellmann

A symbol of our ideals and history

Geese were chosen to be the Hellmann symbol

because the birds are featured on the family

crest. Our company is family-owned and run,

and we believe the geese represent the link bet-

ween the company and the values we bring to

the workplace. The geese are more than just a

symbol of our ideals and history; they also provi-

de us with some valuable lessons.

The shape of the flock is often seen as a thing of

beauty, but the famous “V” is actually a pheno-

menal display of science and cooperation, too.

The formation is ingeniously aerodynamic: as

the lead goose flaps its wings, it creates pockets

of air with lower resistance; each goose behind

flies through these pockets, saving precious

energy in the process. Repeated millions of times

over the course of the journey, this efficiency al-

lows the flock to fly further – so much further

that without each other it would be impossible

to reach the destination. No goose could com-

plete the migration alone, but working together,

they do it every year!

This act of cooperation is paired with an ability to

adapt to the minute changes in conditions. The

birds alter their position in the formation, cons-

tantly fine-tuning it to create the optimal sha-

pe for the specific altitude, wind direction and

speed. While the geese make these adjustments

through intuition, we at Hellmann develop and

implement information and communication sys-

tems which are designed to make cooperation

and efficiency just as instinctive.

We can learn even more from the way geese

interact on the ground. Geese display lasting

dedication by returning to the same place year

after year and by choosing one partner to stay

with forever. Like them, we believe in the idea

of loyalty and know the rewards that come from

long term relationships. That is why we actively

seek to build similarly beneficial and long-lasting

bonds with our staff and customers.

These beautiful birds have been the symbol of

Hellmann for decades now and with their iconic

status as one of Mother Nature’s most experi-

enced travelers, we feel like our feathered friends

have accompanied us on our own successful

journey from a one-man delivery service to a

global logistics provider.

And just as the geese understand the value of

working together and staying with the same

partner year after year, we know that when you

work with Hellmann you will benefit from doing

business with us time and time again.

10

Code of Conduct

The Geese

About Hellmann

Our commitment to theUnited Nations Global Compact (“UNGC”)

The United Nations Global Compact is a Cor-

porate Social Responsibility initiative which

seeks continuous improvement in the following

four areas: human rights, labor, environment

and anti-corruption – through a voluntary ag-

reement by companies with the United Nations,

to engage in actions that contribute to a con-

tinuous and ordered growth of this initiative.

Being a partner of the United Nations Global

Compact enables companies to: adopt a trans-

parent globally recognized policy, share industry

practices, and collaborate on solutions to com-

mon challenges encountered in business and

society. Hellmann is proud to be one of its co-

operating companies.

In the complex and dynamic modern era of

globalization, businesses will play a major role

in shaping and sustaining such globalization

through ethical management and by developing

services that meet economic, environmental, so-

cietal and cultural needs. To Hellmann, sustai-

nability means responsibly delivering long-term

value in financial, social, environmental and

ethical terms while showing profound respect

for the social, political and economic environ-

ments in which we operate. It is for these re-

asons that Hellmann shares and supports the

ideas and goals of the United Nations Global

Compact.

12

Code of Conduct

Introduction

Our commitment to the United Nations Global Compact (“UNGC”)

Hellmann firmly believes in adopting and

embracing respect of human rights (as articula-

ted in the United Nations Universal Declaration of

Human Rights) all around the world and therefo-

re, compliance with this policy and Code of Con-

duct is mandatory for every employee and office.

It is our company’s policy to act with integrity

and fairness and treat all employees and persons

with dignity, decency and respect by providing a

healthy, safe and secure work environment.

Our commitment to human rights ensures not

only that employees have a right to collective

bargaining (in accordance with all rules, laws

and regulations), but also that Hellmann coope-

rates and communicates regularly with local la-

bor boards, work councils, and associations. Hell-

mann views active violations, as well as passive

violations, of human rights to be intolerable and

a violation of this Code of Conduct that may lead

to the appropriate disciplinary actions.

We pride ourselves on our extremely productive

and motivated employees which we believe is a

direct result of our focus on providing a healthy

work-life balance. Correspondingly, Hellmann

prohibits any form of forced or compulsory la-

bor, or child labor (not only in our facilities, but

also those of our service providers). It is our

policy to employ only those individuals with a

minimum age of sixteen (16), despite the Inter-

national Labor Organization’s (ILO) minimum

age of fourteen (14).

We view the diversities and differences in our

workforce as one of our greatest assets that de-

serve the respect of all.

13

Code of Conduct

Human rights and labor principles


Our pledge of social responsibility includes

not just our employees but our partners as well,

and is manifested in two distinct ways. The first

is demonstrated in our active efforts to impro-

ve the standard of life of all of our employees

through education, understanding and respect.

To fulfill this goal we maintain a happy and fair

working environment, and we have established

numerous programs, including in-house trai-

ning, flexible working-hours for parents and the

sponsorship of charity events, to allow all of our

staff to enjoy the satisfaction of realizing their

potential at Hellmann.

However, we believe that our duty extends bey-

ond this, as such the SA 8000 Standard is the

basis of our social responsibility for our worldwi-

de network. This internationally recognized stan-

dard reasserts our own fundamental belief in the

observance of human rights, the prevention of all

forms of discrimination, the elimination of child

labor and the promotion of religious freedom.

14

Code of Conduct

Social responsibility


As a fourth-generation family-owned business,

we certainly understand the concept of building

a proud and lasting legacy for future genera-

tions. We see environmental sustainability as an

extension of this ideal and believe that environ-

mental responsibility is not so much a choice, but

a necessity. We continue to strive for increasin-

gly environmentally-friendly practices across the

Hellmann network so that we can provide for the

generations to come and do our part to ensure

that there are sufficient resources to safeguard

their health, prosperity and quality of life.

We know that the challenges of sustainability

can only be overcome by altering attitudes about

how we use our planet’s natural resources and

then showing determination and imagination

in implementing the necessary changes in our

business practices. This might seem impossible

to accomplish without compromising on quality

of service but we are fortunate that our com-

pany prides itself on finding creative new solu-

tions to combat potential problems. Today, we

harness our tradition of innovation to maintain

and enhance our excellent range of products and

services while actively seeking ever-better ways

to improve our environmental legacy.

For a globally active company such as Hellmann

Worldwide Logistics, the development of eco-

nomic interests is inherently connected to our

responsibility for the environment and the idea

of sustainable development has long been our

focus. At Hellmann, we are committed to wor-

king within a structured system of environmen-

tal management using task-oriented methods,

continuous self-monitoring and regular external

auditing.

For all of our activities we have goals in place to

achieve sustainable development. Some of our

tasks include:

� waste reduction and recycling

� reduction of greenhouse gas emissions

in all vehicles

� energy saving and electricity reduction

in the workplace

� ISO 14001 certification

� elimination of environmentally

harmful chemicals

� green space maximization for exterior areas

� sponsorship of ecological and environ-

mentally-friendly programs

We recognize that there is still much to be done

and we are committed to ensuring that all of our

business activities and services continue to be

economically, environmentally and socially res-

ponsible.

15

Code of Conduct

Environmental sustainability


Anti-corruption

As Hellmann continues to expand and conduct

business globally, it is imperative that all Hell-

mann employees act in accordance with Anti-

Corruption laws around the world. In addition

to many local laws in existence, the two most

prominent bodies of law in this area are the

United States Foreign Corrupt Practices Act

(FCPA) and the U.K. Anti-Bribery Act (The

Act), both of which are applicable to the man-

ner in which Hellmann conducts business around

the world. This also applies to our subsidiaries,

affiliates, partners, vendors, subcontractors and

employees (“Hellmann Personnel”).

17

Code of ConductAnti-corruption

The Hellmann Code of Conduct prohibits Hell-

mann Personnel from using, accepting or offe-

ring bribes, kickbacks or fraud as a means to

conduct business or to influence or compromise

either your conduct or the recipient’s. Any Hell-

mann Personnel receiving, accepting, facilitating,

offering or condoning a bribe, kickback, or other

unlawful payment, or attempting to initiate the-

se types of activities (or any other activity that

will compromise or tarnish Hellmann’s reputati-

on) will be subject to the appropriate disciplinary

actions. Further details or specific guidance can

be found in the company’s Global Anti-Corrupti-

on and Antitrust Compliance Manual.

18

Code of Conduct

Our code

Anti-corruption

No person may offer, give, or promise to give

any money, or anything else of material value,

or authorize such payment, consideration or gift

to: any domestic or foreign government emplo-

yee, official, representative or agent; or to any

governmental department, agency, or instru-

mentality of any domestic or foreign govern-

ment; or to any domestic or foreign political par-

ty, candidate or other political official for the

purpose of influencing any act or decision of

such person or inducing such person to take or

forebear from taking any action in violation of

his or her lawful duty, or inducing such person to

use his or her influence with the government to

affect or influence any governmental decision re-

lating to obtaining or retaining business. Special

care should be taken to “know your customer.”

A “government official” includes employees of

companies owned in whole or in part by the

government (e.g. many companies in China are

government owned in whole or in part).

19

Code of Conduct

Policy statement

Anti-corruption

Antitrust

It is our policy to comply fully with the antitrust

laws that apply to our operations throughout

the world. The underlying principle behind the-

se laws is that a person who purchases goods

or services in the marketplace should be able to

select from a variety of choices at competitive

prices unrestricted by artificial restraints, such as

price fixing, illegal monopolies and cartels, boy-

cotts and tie-ins. Hellmann also believes in, and

is firmly committed to, these principles of free

and competitive enterprise. Certain violations of

the antitrust laws are punishable as criminal of-

fenses which may include substantial monetary

fines and penalties. It is for these reasons that

antitrust compliance is extremely important to

the Hellmann Group and all of our personnel.

21

Code of ConductAntitrust

As antitrust and competition laws are very

complex, the below summary (which can be

found in greater detail in the Hellmann Glo-

bal Anti-Corruption and Antitrust Compli-

ance Manual) highlights various situations of

which to be wary:

� All Hellmann Personnel are prohibited

from discussing with any competitor: past,

present or future prices, pricing policies,

lease rates, bids, discounts, promotions,

profits, costs, margins, new products or

processes not previously disclosed public-

ly, terms or conditions of sale, warranties,

choice of customers, territorial markets,

production capacities or plans.

� All Hellmann Personnel are prohibited

from discussing or agreeing with any

competitor as to what prices Hellmann or

our competitor will charge a customer or

customers, nor about other terms or con-

ditions of sale for our services or theirs,

nor discuss or agree upon an allocation of

customers or service territories.

� Competitive prices may be obtained only

from sources other than competitors, such

as published lists and mutual customers.

It is advisable to mark directly on these

materials from whom they were received,

and when.

� If at any trade association meeting you

become aware of any formal or informal

discussion regarding the following topics,

you should immediately leave the mee-

ting and bring the matter to the atten-

tion of your Regional Compliance Officer.

Such topics include:

– Rates

– Discounts

– Exclusion of members

– Terms and conditions of sale-or

standardization among competitors

of what terms and conditions to

offer a customer or potential customers

– Geographic market or product market

allocations/priorities

– Bidding on specific contracts

or customers

– Refusal to admit or deal with

a customer

22

Code of Conduct

Restrictions

Antitrust

Fair and equal employment

Hellmann is committed to providing and pro-

moting equal opportunity for all employees and

applicants. To this end, Hellmann has always and

continues to fully comply with the spirit, as well as

the letter, of all applicable local, state, provincial,

federal and country laws and regulations imple-

menting the objectives of equal and fair employ-

ment opportunities for all persons. Hellmann does

not discriminate nor does it tolerate any discrimi-

nation (or any other form of unfair treatment) in

employment opportunities or practices on the ba-

sis of race, ancestry, color, religion, gender, sexual

orientation, marital status, national origin, age,

disability, citizenship, veteran status, military ser-

vice obligation, or any other characteristics (all of

which are considered “Prohibited Factors”) that

would be in violation of human rights.

Our policies and personnel practices are intended

to ensure that all employees are treated equally

and that recruiting, hiring, and advancement are

accomplished without regard or consideration to

the Prohibited Factors; that decisions on employ-

ment are made so as to further the principle of

equal employment opportunity; and that all per-

sonnel actions involving a condition or privilege

of employment are administered without regard

to the Prohibited Factors that may either be pro-

tected by law or could be considered a violation

of human rights.

24

Code of ConductFair and equal employment

Conflicts of interest

All employees of Hellmann should ensure that

your private activities and interests do not inter-

fere with your responsibilities or the interests of

Hellmann. Many situations may arise where your

personal interest conflicts, either actually or in

appearance, with the interests of Hellmann or

your loyalty to Hellmann.

Conflict of interest defined

A conflict of interest exists in the case of any

proposed or actual business dealings between

Hellmann and a third party or entity with which

a Hellmann employee has a direct or indirect fa-

mily, social, business or employment relationship

or financial interest in such dealings. A conflict of

interest also exists when a Hellmann employee’s

private activities or involvement could reasonab-

ly be expected to interfere in any way with his/

her objectivity or judgment in protecting and

promoting the best interests of Hellmann, or

when a Hellmann employee, or the employee’s

associate, friend, relative or family members re-

ceive or provide improper benefits as a result of

the employee’s position with Hellmann. In all in-

stances you should not enter into situations that

could result in even the appearance of a conflict

of interest.

26

Code of ConductConflicts of interest

27

Code of ConductConflicts of interest

Prohibition of use

In addition, you may not take personally, oppor-

tunities that are discovered through the use of

Hellmann property, information or your position

with Hellmann. Also, you may not use Hellmann

property, information or your position for perso-

nal gain, other than through proper employment

activities, nor are employees allowed to compete

with Hellmann. Your obligation is to advance the

company’s legitimate interests when the oppor-

tunity arises. Sometimes the evolving nature of

our business changes a previously acceptable

situation into a potential conflict of interest. In

these situations you may be required to disconti-

nue an activity which was previously acceptable.

Full disclosure and reporting

All employees shall exercise good faith in all

transactions relating to their duties to Hellmann

and shall not use their positions in any manner

that is contrary to the best interests of Hellmann

or to promote their own business interests or

those of family, friends or business partners. If

you feel that a situation has posed, will pose or

is already an existing conflict of interest, each

employee shall (i) promptly and fully disclose all

known and potential conflicts of interest to a cor-

porate officer or senior management, the facts

surrounding the transaction or arrangement to

which a known or potential conflict of interest

relates; (ii) refrain from participating in, or acting

on, the decision on any matter in which a conflict

of interest, or the appearance of a conflict of in-

terest, is present with respect to such employee

or the employee’s position within Hellmann; and

(iii) remove himself or herself from any meeting

or deliberations on the matter.

Confidentiality

Our customers, suppliers, vendors and ser-

vice providers must be able to interact with us

with the knowledge that the content of their

communications and records will be kept confi-

dential and private when appropriate. We must

ensure that confidential and proprietary infor-

mation is protected and that information that

Hellmann discloses is accurate. Each Hellmann

employee must therefore maintain the confi-

dentiality of information entrusted to you by

Hellmann and its customers, except where dis-

closure is authorized or legally mandated. You

may not use confidential information in viola-

tion of the terms under which it was disclosed

for any reason and you may not allow any third

party to obtain such information in violation of

such terms. Improper acquisition, possession or

use of confidential information is improper and

can, under certain circumstances, be illegal. If

you know, or have reason to believe, that con-

fidential information was wrongfully obtained

from the owner of the information or was ob-

tained from a third party who was under a con-

fidentiality obligation to the owner you cannot

use such information.

As each employee is required to guard and

protect the company’s confidential information,

employees may not divulge, disclose, furnish,

communicate, duplicate or make accessible

any confidential information to any person or

business entity, nor can employees, under any

circumstances, remove confidential informati-

on from Hellmann premises or from Hellmann

equipment unless authorized by Hellmann. Em-

ployees are bound by this obligation both du-

ring and after employment with Hellmann as all

confidential information shall remain the exclu-

sive property of Hellmann. If your employment

with Hellmann ends for any reason, employees

shall immediately return to Hellmann all con-

fidential information and all copies thereof

including, but not limited to, all files, records,

documents, spreadsheets, PowerPoint files or

presentations, rates, sop’s, contracts, specifica-

tions, equipment and similar items relating to

the business.

29

Code of ConductConfidentiality

Information security

Hellmann is a modern and innovative com-

pany operating globally to deliver individual and

high quality products and services to its custo-

mers. In this environment, business processes

are highly dependent on information that is pro-

cessed by information technology. Information

and IT systems are essential assets of Hellmann

and vital resources to our customers and em-

ployees and are also critical to the products and

services that we provide. It is important to secure

these assets to ensure a proper business operati-

on, thereby leveraging the benefits of the usage

of modern information technology to enable us

to achieve higher customer satisfaction.

Information security applies to all employees lo-

cated at Hellmann business units, locations and

associated companies all over the world. It co-

vers all forms of written or electronically trans-

mitted, stored and processed information.

Hellmann is establishing an Information Secu-

rity Management System (ISMS) to effectively

control the information security level. The ISMS

is intended to be aligned with the international

standard for information security management

DIN ISO/IEC 27001.

31

Code of ConductInformation security

Complaints and comments

Reporting

Hellmann strongly encourages the prompt re-

porting of all violations, whether potential or

actual, of this Code of Conduct. All employees

are encouraged to first approach his/her super-

visor, manager, department manager/supervisor

or human resources (which may be sought si-

multaneous or at any point). If for any reason,

employees feel uncomfortable or are unable to

approach any of the aforementioned persons,

employees should then seek out senior manage-

ment. Further, all employees may report any vi-

olations or incidents on Hellmann’s compliance

website located at www.hellmann.ethicspoint.

com. Should you wish, all reports will be treated,

to the best of our ability, anonymously and con-

fidentially.

Non-retaliation

Hellmann has a strict policy against retaliating

against any employee who, in good faith, reports

incidents that he/she believes to be violations

of this Code of Conduct or of any other Hell-

mann policy. Nor will any employee be retaliated

against for participating in the investigation of

any alleged violation of either this Code of Con-

duct or a Hellmann policy. Hellmann considers

retaliation to be a serious violation of this Code

of Conduct and urges you to report any incidents

of retaliation immediately, as you would any vio-

lation of either this code, law or Hellmann policy.

Hellmann will investigate and resolve reports

of retaliation in the same manner as reports of

other violations of this code, law or Hellmann

policy. If, however, the investigation results in a

finding that an employee knowingly falsely ac-

cused another individual of a violation of this

code, law or Hellmann policy, the accusing em-

ployee will be subject to disciplinary action, up to

and including termination of employment.

Changes to this code

This document supersedes and replaces all other

previous Codes of Conduct to the extent that

they are inconsistent. Only the Hellmann Com-

pliance Department may waive, alter, amend or

update this Code of Conduct. Hellmann reserves

the right to make changes, modifications or alte-

rations to this code, with our without notice, in

the company’s sole and exclusive discretion.

33

Code of ConductComplaints and comments

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