We Protect Cargill’s Information, Assets and Interests
We count on one another to act as stewards of the organization. To preserve the value of Cargill, we protect the information and assets entrusted to us and avoid situations that may let personal interests influence our business judgment.
Cargill Property and Resources
We protect Cargill’s property and resources. These include both our physical assets, such as our facilities, materials and equipment, as well as our communication systems, such as our computers, Internet service, telephones and email.
Employee Data Privacy
We may collect, hold or process personal information for employment purposes. We handle this information lawfully and properly, and protect it from disclosure. Review Cargill’s Data Privacy for Employment Information Policy for guidance.
Cargill Intellectual Assets
Among Cargill’s most valuable assets is our intellectual property. This includes copyrights, patents, trademarks and trade secrets. Unless you know information may be disclosed, assume it is confidential.
Never disclose confidential information to anyone outside the company unless you have explicit approval and it’s covered by a non-disclosure agreement, if appropriate. Even inside Cargill, do not share such information unless the person has a business need to know it.
If you create or invent things on the job, make sure you understand how to protect the intellectual property that results from your work. For instance, you may need to keep records, report on research and development or assist with obtaining patents on behalf of Cargill.
Review Cargill’s Copyright Policy, Trademark Policy and Confidential Information Policy for guidance.
Q & A
I have found that someone has left a file in our break room containing a detailed customer list. It was not marked confidential. What should I do?
Even though it is not marked as such, treat it as confidential and report what you found to your manager. A customer list is a typical kind of trade secret that would be useful to competitors if discovered. That’s valuable information and a disclosure could deplete its worth.
Insider Trading
Cargill strictly prohibits:
- Trading on “material nonpublic information” about third-party or partner companies with publicly traded securities (including debt securities)
- Communicating “material nonpublic information” to others in violation of the law
This conduct, commonly referred to as “insider trading,” is illegal in most places. It can result in severe penalties for both you and Cargill, even if you do not profit from the violation.
Information is “material” if it is likely a reasonable investor would consider it important in making an investment decision.
Q & A
I occasionally discuss work with my brother. Could I risk violating insider trading laws by telling him something that has not been made public?
Yes. Our Code prohibits sharing material, nonpublic information with anyone, such as your brother, since that person could then subsequently trade on that information, which is against the law. Consequences for insider trading can include significant criminal and financial penalties. So, you should not share such information.
Derivatives Transactions
Cargill enters into derivative transactions, including futures, swaps and options, throughout the world. We enter these transactions on organized exchanges and bilaterally with counterparties.
Personal trading in commodity derivatives in which Cargill trades or holds positions (known as “In-Scope Products”) raises conflicts of interest concerns. So, before trading in In-Scope products, you must disclose your intent to make these trades and obtain approval from your manager, group or function leader and from Derivatives and Commodities Compliance (DCC).
In addition, do not trade any other product that could create a conflict of interest with your Cargill responsibilities, without first disclosing the trade and receiving prior approval.
Consult with our Policy on Employee Trading for further guidance. Cargill’s Derivatives and Commodities Compliance (“DCC”) team also provides information and resources on derivatives and commodities trading on My Connects under Functions → Law → Ethics & Compliance → Derivatives & Commodities Compliance. Email questions or requests to derivatives-compliance@cargill.com.
Conflicts of Interest
We avoid situations where our personal interests could inappropriately influence our business judgment or even simply appear to do so. These situations are called “conflicts of interest,” because there is a conflict between personal and job-related interests.
Examples of situations in which a conflict could exist include:
- Outside employment, such as working for a competitor or competing with Cargill with a side business
- Personal relationships, such as hiring a family member as an employee or a vendor
- Business opportunities discovered on the job and used for your own gain instead of Cargill’s
- Gifts or entertainment that affect—or could appear to affect—your business judgement
- Reporting arrangements (either direct or indirect) with another employee with whom you have a personal (familial, romantic or intimate) relationship
It’s not always clear whether an activity creates a conflict of interest. Consult with your manager or the Ethics and Compliance Office if a conflict appears possible. We must disclose all potential conflicts of interest, even when we are unsure about whether they are conflicts, so that we can confirm if they are actual conflicts and how to best manage them.
Review Cargill’s Conflicts of Interest Policy for guidance.
Q & A
I am on a panel to choose a new supplier. My sister-in-law has invested in one of the suppliers and would stand to benefit if we selected that supplier. What should I do?
Disclose your sister-in-law’s investment as soon as possible to your manager or other appropriate personnel. You may need to recuse yourself from the panel over this decision. When in doubt about whether a conflict of interest exists, always disclose as soon as possible.