Compliance and Integrity

Links for easy navigation to the sections below.

A Commitment to Operate in Legal Compliance and with Integrity 


Our global compliance and integrity program helps guide our employees to obey all applicable laws and regulations while conducting business around the world. It also emphasizes how important it is for us to act with integrity and make ethical decisions for our business, our shareholders, our employees and our consumers, because their trust and confidence is critical to our success. 


Code of Conduct 


The Mondelēz International Code of Conduct is a key part of our compliance and integrity program. It includes a set of employee policies that cover ethical and legal practices for nearly every aspect of our business. And it focuses on the personal responsibility each employee has to conduct business legally and ethically. The entire code has been translated into 32 languages and distributed around the world. This allows us to reach almost every employee.


Compliance and Integrity Program


Training-Contact-Action – Making Compliance and Integrity Part of Our Culture

We have dedicated compliance and integrity staff and five regional compliance officers around the world who work with senior management to implement our program. Our compliance and integrity team helps to make sure that our employees know what is expected of them and how to make the right decisions, especially when faced with difficult situations. Our live and online training programs help employees understand legal and ethical business practices. 

Speaking Up and Being Heard 

We expect employees to ask questions and raise concerns about business practices when they see something they think might be wrong. There may be times when employees are not comfortable speaking with their supervisors, compliance officers or human resources contacts, or simply wish to remain anonymous. Consistent with applicable local law, we have a toll-free and in some countries a collect call/reverse charge telephone HelpLine and an online version WebLine so that our employees can confidentially and, if they wish, anonymously report instances of suspected wrongdoing or ask questions about compliance matters. Our HelpLine operates in more than 90 countries.

Listening, Investigating, Acting

In 2013, our compliance and integrity group received more than 1,400 contacts from around the world through our "Speaking Up" channels. These contacts included questions about our compliance policies and program or matters that we referred to other departments for handling. We received reports of misconduct that required investigation. Some of these matters resulted in disciplinary action, including the separation of people from the company when appropriate. 

Report to Management and the Board 

To make sure that senior management and the Board of Directors are aware of any potentially significant matters, our compliance and integrity group reports investigations to members of our executive team and the Audit Committee of the Board of Directors. 

External Reports of Wrongdoing 

Reports from people outside of the company of suspected wrongdoing may also be brought to our attention in four ways: 

By mail: 
Compliance & Integrity Department
Mondelēz International, Inc.
Three Parkway North
Deerfield, IL 60015
USA

By e-mail: Compliance@mdlz.com

Through our Integrity HelpLine: Our Integrity HelpLine is a toll-free and/or reverse charge service operated for Mondelēz International by a third-party. The HelpLine is accessible 24 hours a day, every day, and language interpreters are available.  View a listing of toll-free numbers by country.

Through our Integrity WebLine: Our Integrity WebLine is an online version of the HelpLine.  It is operated by a third-party for Mondelēz International and is accessible 24 hours a day.  You can visit www.mdlzethics.com to access the Integrity WebLine. 


Human Rights


Everyone should be treated fairly and with dignity. It’s a basic human right. And we believe there is a role for everyone to play in preserving that right – from governments and non-governmental organizations to civil society and the private sector. At Mondelēz International, we focus on where we can make a difference in our business operations, with our direct suppliers and in the broader community.

We created the below statements that summarize our approach to human rights and the corporate social responsibility expectations we set for ourselves and our suppliers. We encourage you to read them to learn more about our approach and the ways we demonstrate our commitment to treating people fairly and with dignity.

Mondelēz International Statement on Human Rights

The subject of human rights encompasses a range of topics broad in scope and immense in gravity.  A tremendous amount of thought, sacrifice and passion has been brought to bear on the subject.  While governments and non-governmental organizations have a primary role in protecting human rights, corporations have an important role as well. In our view, our role should focus on where we can make a difference in our business operations, with our direct suppliers, and in the broader community.

Our core belief is that people should be treated fairly and with dignity, which we demonstrate in the following ways:

Our Own Operations.  Our corporate Code of Conduct sets out 10 rules that guide everything we do.  The third rule states that employees will “Treat People Fairly.”  We implement the code through detailed policies that provide guidelines for our employees in certain areas.  In addition, we have a robust Compliance and Integrity Program to help us train and monitor in these areas. To learn more, see our Corporate Responsibility Guidelines below.   

Our Direct Suppliers.  We want to work with suppliers whose own standards of conduct align with ours. To learn more, see our Corporate Responsibility Expectations for Direct Suppliers below.

The Broader Community.  Beyond careful oversight of our own operations and our influence over direct suppliers, we are working to address systemic issues.  For example, we have embraced certification schemes like Fairtrade, Rainforest Alliance and 4C for agricultural products like cocoa and coffee beans – and have continued to increase the volume of certified beans we purchase.  We also work and invest with many valued partners like, The Bill and Melinda Gates Foundation, Deutsche Gesellschaft für Technische Zusammenarbeit GmbH (GTZ), the International Cocoa Initiative, the World Cocoa Foundation, and our partners within our signature sustainability programs, Cocoa Life and Coffee Made Happy, on projects to help improve the lives of farmers and their families. 

We encourage you to read more about our commitment to sustainable resources and agriculture in the Well-Being area of our website. We are also involved in a number of charitable endeavors addressing malnutrition, hunger, and emergency responses to natural disasters.

We encourage you to review our Call to Well-Being pages for a more detailed summary of our activities.


Mondelēz International Corporate Responsibility Guidelines


Forced Labor.  Mondelēz International prohibits the use of forced labor in our operations, i.e., any work or service that a worker performs involuntarily, including under threat of physical harm or other penalty. 

Child Labor.  Mondelēz International prohibits the unlawful employment or exploitation of children in our workplace.  In accordance with the conventions of the International Labor Organization (ILO) and national laws, the minimum age for employment is the highest of the following ages: (i) 15 years of age, (ii) the local minimum employment age, or (iii) the mandatory schooling age. All temporary workers used by Mondelēz International and all third-party contractors who perform work on our premises are required to meet these minimum-age requirements.   

Diversity and Inclusion.  We prize a diverse and inclusive workplace and aim to promote cultural and individual differences.  Mondelēz International does not discriminate in employment or employee treatment based upon any of the following characteristics: race, color, religion, gender, age, ethnic or national origin, veteran status, disability, sexual orientation or preference, gender identity, marital status, citizenship status, genetic information, or any legally protected personal characteristic or status.

Harassment and Abuse.  Mondelēz International will not tolerate any form of harassment including harassment based on race, color, religion, gender, age, ethnic or national origin, veteran status, disability, sexual orientation or preference, gender identity, marital status, citizenship status, genetic information, or any legally protected personal characteristic or status.

Safety and Health.  We use internal and external expertise to provide a safe work environment.  Specifically, we: (i) provide safety training for all employees as required for their work; (ii) establish first aid and medical treatment procedures to provide employees with appropriate care; (iii) conduct careful investigations of accidents to avoid recurrence, and study the safety and health features of any new equipment, materials or process; and (iv) solicit employee involvement and support through safety committees or other avenues for employee input.  For more information, please see our webpage on Ensuring a Safe Work Environment.

Third-Party Representation. We aim to have constructive relationships with our employees and their unions. Mondelēz International respects the interests of its employees to join (or not join) a union. In those situations where our employees have third-party representation, we will work with employee representatives in a direct and straightforward manner. 

Employee Compensation and Development. Except for collective bargaining at union represented facilities, we compensate employees competitively within the labor market and industries in which we compete; provide superior levels of compensation for superior performance; and focus rewards on individual contributions and business results.  Further, we provide equal opportunity for advancement to all of our employees.

Business Integrity. We promote honesty and integrity in our business conduct by raising ethical awareness among our employees and providing direction and education on ethical issues. Further, we prohibit bribes, kickbacks, or any other illegal inducements in business or government relationships.

Environment and Sustainability. We work to continuously improve our environmental performance by setting and then working toward quantifiable goals that reduce the environmental impact of our activities.  For more information, please see our Environmental Footprint webpage.


Corporate Responsibility Expectations for Direct Suppliers


Each Mondelēz International employee must follow 10 key rules in our Code of Conduct.  Common to all of these rules is the imperative to “inspire trust” in all that we do.  Underpinning our code is a comprehensive compliance and integrity program designed to ensure that we run our business consistent with our values and applicable legal standards. 

We also work with thousands of suppliers, consultants and business partners around the world.  Ideally, we and they will have comparably high standards of conduct.  Of course, we cannot — and do not presume to — control how they run their businesses.  But we certainly take pragmatic steps to align what they do for us with our own standards of fair and honest dealings.

1. Supplier Selection and Risk Analysis. 

We begin with the selection process.  As we evaluate suppliers, we want to be familiar with their own codes of conduct and reputations, as well as their ability to deliver quality, service, and total value to Mondelēz International.

2. Corporate Responsibility in Supplier Contracts. 

Once we determine a good fit with a supplier or business partner, we develop a contract that not only provides the core commercial terms but specifically incorporates our corporate responsibility expectations (see below).  For example, we would include legally enforceable provisions on child labor and worker safety.  Over the next several years, we will work toward having these corporate responsibility expectations in all contracts with suppliers and business partners. 

3. Assessing Corporate Responsibility through PROGRESS. 

We are hardly alone in our approach as most major companies have supplier corporate responsibility requirements.  Yet most companies are both suppliers and customers, leading to a proliferation of codes of conduct and assessment requests.  We helped create a far simpler and better approach for society called Program for Responsible Sourcing (PROGRESS).  This industry initiative allows a supplier to provide common information to its customers so each customer can independently reach business decisions in accordance with its own corporate responsibility standards. 

We are currently rolling out PROGRESS to our suppliers and business partners.  This is an ambitious global effort that will take several years to complete.  When dealing with such an important issue as corporate responsibility, we have taken a long-term approach that we are confident puts us on the right path.


Corporate Responsibility Expectations (Supplier Contract Provisions)


In addition to complying with all laws and regulations, Supplier must comply with the following in connection with the goods and services provided to Mondelēz International: 

Forced Labor.  Supplier will not use any forced labor, which means any work or service performed involuntarily under threat of physical or other penalty.  Supplier shall respect the freedom of movement of its workers and not restrict their movement by controlling identity papers, holding money deposits, or taking any other action to prevent workers from terminating their employment.  If workers enter into employment agreements with Supplier, workers should do so voluntarily.  

Child Labor.  Supplier will not directly (or indirectly through the use of its subcontractors) employ any children under the age of 18 years unless legal, necessary, and appropriate and the following are met:

• Supplier will comply with the minimum employment age limit defined by national law or by International Labor Organization (“ILO”) Convention 138, whichever is higher. The ILO Convention 138 minimum employment age is the local mandatory schooling age, but not less than 15 years of age (14 in certain developing countries), subject to exceptions allowed by the ILO and national law. 

• Supplier will ensure that employees working in facilities that are manufacturing or packaging Mondelēz International finished products, serving as temporary employees to Mondelēz International, or present at Mondelēz International facilities, are at least 15 years of age (and no exceptions allowed by the ILO or national law will apply).  

• Supplier must demonstrate that their employment does not expose them to undue physical risks that can harm physical, mental, or emotional development 

Diversity and Inclusion.  Supplier will hire, compensate, promote, discipline, and provide other conditions of employment based solely on an individual’s performance and ability to do the job (except as required under collective bargaining agreements). Supplier will not discriminate based on a person’s race, color, religion, gender, age, ethnic or national origin, veteran status, disability, sexual orientation or preference, gender identity, marital status, citizenship status, genetic information, or any legally protected personal characteristic or status. 

Harassment and Abuse.  Supplier will provide a workplace free from harassment, which can take many forms, including sexual, verbal, physical or visual behavior that creates an offensive, hostile, or intimidating environment.  

Safety and Health. Supplier will (i) endeavor to provide safe working conditions, (ii) provide its employees with appropriate protection from exposure to hazardous materials, and (iii) provide its employees with access to potable water and clean sanitation facilities.   

Third-Party Representation. Supplier will respect the decision of its employees to join and support a union as well as their decision to refrain from doing so where legally permitted.

Working Hours and Compensation.  Within the bounds of normal seasonal and other fluctuations in business requirements, Supplier will (i) maintain a reasonable overall pattern of required working hours and days off for its employees so that total work hours per week do not regularly exceed industry norms; (ii) pay fair and timely compensation, including any required premium payments for overtime work; and (iii) advise new employees at the time of hiring if mandatory overtime is a condition of employment. 

Disciplinary Procedures. Supplier will not use corporal punishment or other forms of mental or physical coercion as a form of discipline.  

Business Integrity. Supplier will promote honesty and integrity in its business conduct by raising ethical awareness among its employees and providing direction and education on ethical issues.  Further, Supplier will not: pay or accept bribes, arrange or accept kickbacks, or participate in illegal inducements in business or government relationships.

Environment and Sustainability. Supplier will work to continuously improve its environmental performance by setting and then working toward quantifiable goals that reduce the environmental impact of its activities.


Supply Chain Transparency and Labor Practices


As awareness and advocacy efforts around human trafficking and slavery grow among governments, NGOs and investors, so do expectations for businesses to demonstrate what they are doing to address this issue within their supply chains. 

The Mondelēz International Statement on Human Rights guides our approach.  And, in line with the California Transparency in Supply Chains Act (SB 657), the links below provide more detail on our efforts to help make a difference in our operations and those of our suppliers.

Internal Accountability Standards  

We expect each employee to conduct business legally and ethically.  Mondelēz International has policies that prohibit child and forced labor as noted in our Code of Conduct.  We also audit our manufacturing facilities under the Program for Responsible Sourcing (PROGRESS). Failing to meet company standards on child and forced labor is a breach of corporate policy.  As such, violators are subject to disciplinary action, up to and including termination of employment.

Training 

Mondelēz International provides specialized training for procurement employees. This training helps them identify and mitigate labor-related sourcing risks and includes a section on human trafficking and slavery.

Certification by Direct Suppliers  

Our purchasing contracts require direct suppliers to comply with all laws and support Mondelēz International’s policies on child and forced labor. We have various tools to address non-compliance, which may include, but are not limited to, a corrective action plan.  If the supplier does not resolve the issues of concern in a timely and satisfactory manner, Mondelēz International reserves the right to take more drastic action, such as termination of the business arrangement. 

Verification and Supplier Compliance Audits 

Using announced third-party audits, we've begun to assess direct suppliers' compliance with our corporate responsibility expectations (including child and forced labor) through PROGRESS.

Going Beyond Our Direct Suppliers

In addition to assessing direct suppliers, we've been working with civil society, government and industry to tackle conditions at the farm level. Since its inception in 2002, we've supported the International Cocoa Initiative (ICI) to address child and forced labor issues on cocoa farms.  You can read about this and similar activities by visiting our Call to Wellbeing site. 

In October 2013 we published a new approach to tackling child labor in the cocoa supply chain. We have worked with experts in the field, including the world’s leading anti-slavery charity, Anti-Slavery International, to define this approach. More details are available on www.cocoalife.org.