Be Preferred
We earn the right to be customer-preferred by delivering mutual enduring value at every touchpoint of the customer experience.
We earn the right to be customer-preferred by delivering mutual enduring value at every touchpoint of the customer experience.
We believe in competing fairly. In our pursuit to deliver ingredient solutions that enable our customers to create consumer-preferred, winning products in their local marketplace, we never use illegal or unethical means to obtain a competitive advantage.
Competitive intelligence can be obtained fairly and ethically from publicly available sources, such as media reports, trade journals, annual reports, governmental filings, speeches of company executives, and from customers in the context of meeting competitive offers.
Competitive intelligence should never be obtained through misrepresentation, trespassing, theft, invasion of privacy, or obtaining information from co-workers about previous employers.
When dealing with competitors, never enter into any agreement—whether formal or informal, written or verbal—to set prices or other terms of sale; coordinate bids; allocate customers, sales territories, or product lines; or engage in any other activity that violates applicable antitrust or competition laws. We never discuss such topics with a competitor, even in an informal setting such as a trade show or customer event. If you have any concerns, contact your local Legal department.
We compete vigorously based on the quality of our products, aiming to meet or exceed our customers’ needs and delivering superior ingredient solutions that will help our customers succeed.
I have a good friend who works for a competitor. At a trade show, my friend proposed a strategy for each of us to increase sales by dividing territories. Should I go along with the plan?
No. Allocating customers or geographic territories between competitors could be a violation of the law. If a competitor ever initiates a discussion about allocating territories, stop the conversation immediately*. If you are at a trade show and this type of conversation starts, then end the conversation immediately. Report any attempt to discuss anti-competitive behavior immediately to the Legal department. *It is appropriate for you to stop the conversation and advise that “we cannot have this type of discussion, and if it is not stopped, I will leave now!”
We act in the best interest of Ingredion and do not allow our business decisions to be influenced, or appear to be influenced, by personal or family interests or friendships, or other connections we may have.
A conflict of interest arises any time a personal or private interest interferes with, or gives the appearance of interfering with, work being performed fairly and ethically without bias or undue influence. Some instances are obvious, such as having a close relative as a manager or serving as a director on the board of a competitor.
Conflicts can arise in many situations, and our Code cannot possibly address all of them. When in doubt, contact your manager, Legal, Corporate Compliance, Local Compliance Committee, Human Resources, or the Business Ethics Line before taking any action.
Remember, having a conflict of interest is not necessarily a violation of our Code of Conduct, but failing to disclose it is.
Conflicts of interest can negatively affect Ingredion’s reputation and business, and can have negative consequences for individuals as well. To help avoid the negative consequences of conflicts of interest:
Don works in corn procurement. He was recently transferred to a plant near his hometown and promoted to manager. His uncle’s own farmland nearby, and he has learned that they occasionally sell corn to Ingredion. Don is concerned that these transactions could create or appear to create a conflict of interest with his new role. Should Don disclose the potential conflict?
Yes. Don has a valid concern and should bring the situation to the attention of his manager, the Legal Department or local Compliance Committee. After disclosure, the company can review the situation and determine whether it in fact poses a conflict of interest.
We comply with all applicable laws regarding political activities and disclosure requirements.
Lobbying is an attempt to influence the actions, policies, or decisions of officials in their daily life. No employee, contractor, or agent may engage in any lobbying activities on behalf of Ingredion without prior written approval and coordination with the Government Affairs professional or legal counsel responsible for the country or region. Any approved lobbying activities must be in full compliance with applicable laws. If you are not sure whether your communications or interactions with a government official are considered lobbying, contact the Government Affairs professional or legal counsel responsible for the country or region.
Ingredion does not give political contributions to candidates, political party organizations, political committees, or political organizations in return for express or implied official acts.
Many countries in which Ingredion does business strictly regulate lobbying activities. Remember:
Interaction with Government Officials Policy
Ingredion respects the right of employees and others working with the company to participate in political activities on their own time, outside of work. Where personal political contributions are permitted by law, understand the following additional conditions related to your relationship with the company:
I have been asked to work on a local political campaign. May I do so?
Yes. Our company encourages participation in the political process. However, it is important that your political activities remain separate from the workplace, done on your own time and at your own expense. Therefore, you cannot use company resources, including work hours, company vehicles, use of the company’s computer network or telephones, or use of the company’s name or other assets, when working on personal political activities.
We comply with all trade regulations, agreements, and restrictions that apply to our business during exchange of goods between countries, including import customs declarations and export control laws.
If you are responsible for the movement of Ingredion products, or an offeror of non-commercial goods across borders, you must comply with applicable U.S. and any local laws outside the U.S. governing trade, regardless of where you are actually based or located. Remember:
To avoid paying customs duties in its home country, an international customer has asked that an employee in the U.S. sign an origin declaration or certificate of origin identifying that the company’s products originate in Mexico. I know the product was packaged in Mexico but am not aware of the manufacturing process and where the product was originally made. May I sign the document?
No, not without prior approval of the Corporate or United States/Canada Trade Compliance team or your local trade compliance contact. Origin declarations and certificates of origin are governed by local and international laws and they require a detailed analysis of the manufacturing process under an established set of rules. An incorrect statement may result in false declarations to customs authorities and subject the company to significant fines and penalties, even when Ingredion is not the importer or exporter.