Ethics and Compliance

In an effort to create this ethically sound culture, we train all U.S.-based employees on our Code of Ethical Business Conduct. We provide this policy and third-party compliance reporting process for all employees globally. Our code serves as a guide for our employees, officers and directors in making business decisions.

The code covers many of the topics discussed in our corporate responsibility report, including fair employment practices, harassment, safety, diversity, environmental responsibility and product integrity.

Additionally, our code outlines our policies on conflicts of interest, gifts, illegal payments, illegal political contributions and disciplinary action.

All company policies at MegaMex Foods follow local and national laws in the United States and other locations in which we operate.

• When considering a company for merger or acquisition, we conduct due diligence and examine the suppliers of the prospective party, and we expect them to comply with our code.
• To ensure adherence to the code, in 2002 we established a compliance program that upholds accountability through reporting, tracking and investigation of possible violations of the code.
• The Audit Committee of our Board of Directors oversees the program, which includes a cross-functional Compliance Committee, training of new employees, and a hotline and website for employees to report incidents that may violate our code.

To ensure the value system at Hormel Foods is understood and implemented throughout the entire organization, we communicate our values platform to our employees in their native languages.

Should our employees observe anything that does not comply with our code of conduct and the values outlined in our platform, we provide a hotline number and website to facilitate anonymous employee feedback and address concerns. This hotline can be used to report a range of issues, including corruption and discrimination. To ensure accountability, the hotline and website are operated by an independent third-party organization.

A number of issues affect the food industry today. As relevant legislation evolves, MegaMex Foods & Hormel Foods participates in open, ongoing dialogue with elected officials and community members about our mission in order to ensure these issues are addressed. We want to make sure our message is conveyed with a clear understanding of the methods in which we conduct our business and the positive role our company plays in the larger scheme of the industry. This dialogue entails:

• Membership in trade organizations that conduct lobbying on behalf of the food industry. These organizations include the Grocery Manufacturers Association, North American Meat Institute, National Restaurant Association and National Turkey Federation.
• Monitoring legislative and regulatory issues and conducting lobbying activity when the company determines it is vital to its operations.
• Conducting one-on-one meetings and individual plant tours with members of Congress and regulatory agencies to help them better understand our company operations and policies.
• Engaging in public forums by participating in panels on a variety of industrywide issues.

Our participation in public policy and lobbying through the previously mentioned trade organizations and relationships focuses on significant issues such as:

• Food and Drug Administration proposed rules and regulations;
• Food safety improvements;
• Biotech food labeling rules;
• Incentive for research and development;
• Immigration reform;
• U.S. trade policy;
• U.S. Department of Agriculture proposed rules and regulations; and
• A balanced approach regarding subsidies, tariffs and mandates for biofuels.

Hormel Foods does not currently use corporate funds to make direct contributions to candidates, political parties, Political Action Committees (PACs), super PACs, political committees, 527 groups, ballot question committees, 501(c)(4) organizations, or to pay for independent expenditures.

To learn more about our lobbying efforts in 2017, visit the 2017 Hormel Foods Corporate Responsibility Report.

The MegaMex Foods Corporate Responsibility (CR) Steering Committee is comprised of company executives. The group’s role is to provide direction and approval for the company’s environmental, social and governance activities. The chair of the committee reports directly to our chief executive officer.

In addition, the Governance Committee of our Board of Directors has oversight of our sustainability, environmental and corporate social responsibility activities.