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why

Ethical business practices are essential to the long-term success of a company. Strong business ethics set the tone for the culture of an organization and provide guidance for employees in making decisions that are beneficial to themselves and to the organization. At Campbell, we understand that having a foundation of ethical business practices creates positive impacts on the company and allows us to attract and retain the type of talented employees who share our values. Setting this foundation also reduces many risks that companies today face, including being fined for poor behavior or experiencing damage to their reputation, one of a company’s most valuable assets that can be difficult to rebuild. At Campbell, we pride ourselves on the reputation we have built and in providing our employees with an ethical workplace where they are proud to work.

how

Campbell’s compliance and ethics program, known as Winning With Integrity, reflects our conviction that conducting business in compliance with the law and the highest standards of business ethics is essential to our success. As reflected in our Code of Business Conduct and Ethics (The Code), the foundation document of our program, employees share responsibility for ensuring that the Winning With Integrity principles are fulfilled every day, through each and every action taken — whether in the marketplace, the workplace or the community. The Winning With Integrity program equips our employees with the resources, tools and guidance to help build a better Campbell.

The Code outlines our company’s basic standards and expectations, highlights important policies and summarizes certain fundamental legal requirements that our employees must follow. Each new employee receives a copy of the Code, which is available in multiple languages. In FY2013, we updated the entire Code and included new sections on expense reporting and personal and familial workplace relationships. The updated version was approved by the CEO and the Board of Directors, announced and distributed to employees in their language of choice and posted on the company’s internal and external websites.

In FY2014, we integrated our acquisitions, Plum and Kelsen into the Winning With Integrity program and did the same with Garden Fresh Gourmet in FY2016.

Campbell’s legal department is responsible for maintaining and administering the Winning With Integrity program. The Vice President — Corporate Compliance/Deputy General Counsel has overall responsibility for the direction and administration of the program and has direct access to the Chair of the Audit Committee of the Board of Directors for all compliance-related matters. A full report on the program is presented to the Audit Committee on an annual basis in November.

what

Ethics Education and Training

Each year, Campbell provides comprehensive online and in-person training for employees on core ethics and compliance issues and risk-based training tailored to the issues associated with employees’ specific job responsibilities. As part of the Winning With Integrity program, all employees are required to complete annual training on our Code of Business Conduct and Ethics. This training, offered in multiple languages, is available online for most employees, but also offered in DVD format for employees in our manufacturing facilities.

Corporate policies and guidelines, such as our Anti-Bribery Policy, Guidelines and Commitment Concerning Advertising to Children, Environmental Sustainability Policy and Human Rights Principles, are reviewed and revised, as necessary, each year. New policies are periodically issued and disseminated as circumstances warrant. A central Index of Standards and Procedures for Compliance, maintained by the legal department, provides a comprehensive inventory of the policies, procedures and guidelines in use at the corporate level and within the individual businesses and functions. Similarly, a companion Index of Mechanisms for Monitoring and Auditing Compliance is maintained by the legal department to confirm responsibility for ascertaining that the policies and procedures are being followed. Both of these indices are reviewed and updated on an annual basis, including review by the Audit Committee of the Board of Directors.

Integrity Hotline

Campbell’s Integrity Hotline enables complaints, concerns and questions to be raised with the company or the Board of Directors on a confidential and/or anonymous basis. Hotline access is available through a secure Internet website and toll-free from all countries where Campbell has operations. The availability of this Hotline is widely publicized, and all reports are thoroughly investigated.