Ethics & Compliance

Employee Code of Conduct

The Kraft Heinz Company and our employees are expected to conduct business in an ethical manner, guided by our Vision, Values, and an unwavering commitment to integrity and transparency. All employees, officers, and directors are required to abide by the company’s global Code of Conduct, which addresses each aspect of our business including anti-corruption, anti-competitive behavior, data protection, and human rights. The global Code of Conduct sets high standards for conducting business in a legal and ethical manner and serves as the foundation of our corporate policies and procedures. To ensure compliance with the global Code of Conduct, Kraft Heinz regularly provides training, communications, and guidance to our employees around the world. Further, employees are required to annually certify that they have read and will follow the global Code of Conduct. The document is available in 14 languages and can be accessed here: Kraft Heinz global Employee Code of Conduct.

Ethics and Compliance Training

To ensure compliance with the global Code of Conduct, Kraft Heinz regularly provides training, communications, and guidance to all global employees. Employees are required to annually certify that they have read and will follow the Code of Conduct and complete compulsory trainings on issues such as anti-corruption, conflict of interest, dignity and respect, whistleblowing, IT security, and due diligence matters. All training is monitored and tracked by the Ethics and Compliance (E&C) team. To reinforce our commitment to our Value, We do the right thing, we designate critical E&C courses as Threshold Training and set their completion rate as an E&C bonus qualifier for each zone. This means that each zone — North America, International, and Corporate — must achieve at least 90 percent completion of all threshold training courses by the end of the year to reach their full bonus potential. If a zone does not meet or exceed their threshold training completion target, the total amount of bonus available for that Zone reduces by 10 percent.

Reporting a Concern

To help employees report potential misconduct, the Company provides several reporting methods, including through managers, Human Resources, Legal and the Ethics & Compliance team. In addition, we have a confidential Ethics & Compliance Helpline for reporting ethics or compliance concerns. The Helpline has multilingual staff available 24 hours a day. It is accessible globally by a toll-free phone call or online at KraftHeinzEthics.com. We do not tolerate retaliation against employees who reports potential misconduct in good faith.

Supplier Guiding Principles

Kraft Heinz has developed a set of Global Principles applicable to its supply chain partners referred to as the Supplier Guiding Principles. In 2021, Kraft Heinz launched our updated Supplier Guiding Principles in accordance with our commitment for improved efficacy and due diligence with our valued suppliers around sustainable business practices. The Supplier Guiding Principles apply to all suppliers (including external manufacturers), and we have plans to include joint venture partners in the near future. Read more about our Supplier Guiding Principles.

Political Contributions and Lobbying Activity

As part of the Company’s ongoing engagement in the communities where our employees live and work, we engage in the political process to help shape public policies that impact our business around the world. Our goal is to ensure issues that impact our value chain, including employees, suppliers, customers, consumers, and shareholders are fairly represented at all levels of government. For more information on our political contributions and lobbying activity, please visit https://www.kraftheinzcompany.com/contributions.html. Kraft Heinz engages responsibly in the political process in the communities where our employees live and work. Our goal is to ensure public officials representing our people, products and manufacturing facilities understand the issues that impact our business. We adhere to the local laws and regulations governing interactions with government officials, and participate in the political process through issue advocacy and political contributions. In North America, Kraft Heinz has put in place effective compliance procedures for, and oversight of, lobbying activities, corporate contributions and The Kraft Heinz Political Action Committee (Kraft Heinz PAC) expenditures. The Kraft Heinz Code of Conduct requires all employees to maintain honest, forthright, and transparent relationships with government officials.

Public Disclosure

Kraft Heinz believes that an important aspect of engaging in the political process is transparency and disclosure. Kraft Heinz files information as required by federal and state campaign finance and disclosure laws. The Kraft Heinz PAC reports its contributions to the Federal Election Commission (FEC), the details of which are publicly available on the FEC website. All Kraft Heinz PAC and Company political contributions since 2012 are listed on our website. This includes contributions to ballot initiatives and 501(c) (4) organizations where funds may be utilized for political purposes. This information is updated semi-annually. In addition, Kraft Heinz partners with outside counsel to conduct an annual internal audit of all lobbying practices and reporting.

Lobbying Activity

Kraft Heinz prepares and files reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives quarterly, which detail lobbying activities and expenditures. These reports are available here. The Company also files lobbying reports with many U.S. state and municipal governments as required by law. These reports are publicly available through the websites of the jurisdictions where they are filed.

Trade Association Membership

Kraft Heinz believes that trade association membership and participation provides a number of benefits to our business and employees, including the ability to remain engaged on relevant issues and as a forum for sharing ideas and information. The Company’s involvement with trade associations does not include engaging in political activity. Kraft Heinz instructs trade associations that our dues must only be used on issues of importance to our business and none may be provided to support or oppose political candidates. You can find language sent to trade associations here.

Center for Political Accountability

Kraft Heinz has proudly received a top tier score (87.1/100) on the “CPA-Zicklin Index,” a rating developed by the Center for Political Accountability in conjunction with the Carol and Lawrence Zicklin Center for Business Ethics Research at The Wharton School, University of Pennsylvania. The full report can be found here.