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Our Compliance And Integrity Program

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.

TRAINING-CONTACT-ACTION – MAKING COMPLIANCE AND INTEGRITY PART OF OUR CULTURE

We have dedicated business integrity staff and four regional business integrity officers around the world who work with senior management to implement our program. Our business integrity team helps ensure 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, business integrity 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 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. Toll-free numbers and dialing instructions can be found by selecting the country you are calling from on the Integrity WebLine page.

LISTENING, INVESTIGATING, ACTING

In 2018, our business integrity group received more than 2,600 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 business 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:
Business 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. These toll-free numbers and dialing instructions can be found by selecting the country you are calling from on the Integrity WebLine page.

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.