We think and act like owners—where everyone takes personal responsibility to anticipate challenges, proactively search for opportunities, and make decisions that are in the best interest of the company.
We are responsible for ensuring that Ingredion’s business records are accurate and complete.
Ingredion’s public disclosures and filings are based on the accuracy and truthfulness of our books and records. Our company books and records must be complete, accurate, and reliable, and must follow Generally Accepted Accounting Principles. Each of us plays a role in ensuring that Ingredion’s business records are accurate and complete:
NEVER falsify, omit, misstate, alter, or conceal any information or otherwise misrepresent the facts on a company record.
NEVER encourage or allow anyone else to compromise the accuracy and integrity of our records.
NEVER keep hidden or unrecorded funds, accounts, or assets.
We are committed to managing our documents and other recorded information consistently and in accordance with relevant legal obligations and business needs. We must:
Information recorded in any medium, hard copy or electronic, in the company’s custody or control that relates to its business is considered a record.
A variety of information categories may be considered records. Some examples include financial statements, presentations, diagrams, illustrations, formulas, spreadsheets, payroll documents, time cards, attendance records, legal agreements, inventory records, invoices, purchase orders, contracts, market research tests, lab tests, quality control tests, data related to our products, travel and expense reports, inspection records, transportation, logs, hazardous material records, accident reports, and business plans.
I am new to my department. When I started my new position, I was told by a colleague that it was okay to delay accruing certain expenses until the next period. He said, “If we move them to next fiscal year, we are not doing anything wrong.” Is that true?
No. Deliberately delaying the accrual of expenses, regardless of the amount, would be a misleading, unacceptable, and possibly unlawful practice. Every business and financial transaction, however immaterial, must be reported accurately and honestly. Falsification of any company document or record is a serious offense and could result in termination of employment.
I work in Quality Assurance and we are running late in releasing a load to a customer. The pass/ fail for the test I am running is 2.0 g/ml and the test result came back at 2.1 g/ml. I know that this customer has received late deliveries at least three times in the last six months. If I reject this load, this may result in a fourth late delivery. What should I do?
A: Record the test result accurately. It is important for the company to maintain accurate books and records. Our customers and ingredient consumers are depending on us.
We do not use or share material, nonpublic information about Ingredion or any other company for the purpose of buying or selling Ingredion stock or the stock of such other company or in order to enable another person to do so.
While working for Ingredion, you may learn or have access to nonpublic information that could be considered important in making a decision whether to buy, hold or sell securities. This information is called “material nonpublic information” or “inside information” It is illegal to use material, non -public information to buy or sell securities. To prevent insider trading:
I went to my doctor for a routine visit. At the end of my appointment, the doctor asked me how Ingredion stock was doing and whether she should invest in Ingredion. I have known my doctor for many years.
I think a modest investment in Ingredion could help her recover some of what she lost after the last global financial crisis. Can I tell my doctor what I know about upcoming project, investment, or acquisitions or otherwise recommend Ingredion stock to her?
No. Details of upcoming project, investment, or acquisitions could be material, nonpublic information that could provide your doctor with an unfair trading advantage. Sharing that information could be illegal and could result in criminal or civil prosecution of both the doctor and you.
Tell her that since you are an Ingredion employee you cannot provide any inside or confidential information that is not public and that would encourage or discourage a person from buying and selling Ingredion stock. Refer your doctor to the Investor Relations section of our website or suggest he contact Investor Relations if he has specific questions.
If you have any questions about whether you are in possession of material, non-public information please contact a member of the Legal Department to discuss the situation.
Having an Owner’s Mindset means we embody a culture of personal accountability in everything we do, including our communications. We communicate truthfully, factually, and responsibly about Ingredion.
We are committed to engaging our customers and stakeholders through effective communication. Social media, such as social networking sites, blogs, photo- and video-sharing sites, forums, and chat rooms have provided us with new ways to engage and collaborate with others. We embrace these communication opportunities, and we are committed to using them responsibly. This means we:
On LinkedIn, I noticed that a user posted a question on my profile about a potential acquisition. The news media had already discussed the acquisition, but no official announcement had been made. May I comment on the post?
No. Information about the potential acquisition is confidential company information. If the media chooses to speculate, then that is their choice. Your publicly commenting may result in legal consequences and reputational damage for the company. Even after the acquisition has been publicized by Ingredion, commenting can reveal undisclosed information. Refer any negative mentions of the company that you notice on social media to Corporate Communications. Do not attempt to respond on your own.
After a positive meeting with leadership, a senior leader sent out a tweet from his private Twitter account: “Good meeting. Good numbers = Happy Board.” Ingredion’s official earnings announcement was due to be released to all investors later in the week. However, the tweet was from his private account so there’s no problem, right?
Wrong. If the official earnings have not been announced, the leader’s Twitter followers may be considered to have access to insider information, which can have significant legal and reputational consequences for the company and the individual who issued the tweet. Report this type of finding to your local Human Resources or through the Ingredion Business Ethics Line.
We protect the confidential information of our company and of our business partners.
Confidential information includes nonpublic information that, if improperly disclosed, could be useful to competitors or harmful to Ingredion, our suppliers, our customers, or other organizations or people. Confidential information might be relevant in an investor’s decision to buy, sell, or hold Ingredion securities or the securities of any of our business partners.
Confidential information is generally something of commercial value to Ingredion, for example, earnings forecasts, business plans, strategies, and significant restructurings or investments; potential mergers, acquisitions, or divestitures; pricing, sales information, research, new product development, formulas and product recipes; manufacturing processes; undisclosed marketing and promotional activity, significant management changes; draft or unpublished accounts; and events regarding Ingredion securities would all qualify as confidential information. We must recognize when something is confidential and take steps to keep that information secure, and not lost, damaged, or given away accidentally.
Disclosure of nonpublic, material information, whether intentional or inadvertent, may trigger certain public disclosure requirements for the company.
Employee information, including particularly sensitive personal information, such as health records, should also be kept confidential and only accessed by the Ingredion staff who need to know that information for the purpose of their role, for example to an employee’s manager.
While working at Ingredion, you may have access to confidential information of our customers, suppliers, business partners, or other organizations or people.
e must always take reasonable precautions to prevent its unauthorized disclosure. Protect confidential information:
I am working on an M&A project with a cross- functional team. At the end of a meeting, some of the team members continued discussing the status of the deal during the walk to a local restaurant. Is this a problem?
Yes. Information related to an M&A deal is confidential. Outside the meeting room, individuals who do not have a legitimate need to know may overhear confidential information. Take care not to disclose company confidential information in public places.
I can get a lot of things done by returning calls while waiting to board flights or trains. Is this a problem?
Be careful not to discuss nonpublic company information in public places where others may overhear you, such as taxis, elevators, at conferences, and particularly at trade shows. When it is necessary to conduct a telephone call in a public place, be mindful of your surroundings.