®
POST HOLDI NGS,
I NC.
GLOBAL STANDARDS OF BUSINESS CONDUCT
FOR OFFICERS AND EMPLOYEES
GLOBAL STANDARDS OF BUSINESS CONDUCT
1
INTRODUCTION
These Standards of Business Conduct apply to all officers and employees of the
Company. In many instances, these Standards summarize policies and practices
contained in the Company’s legal compliance policies. Collectively these documents
provide information on the Company’s expectations concerning everyday business
practices and conduct.
TABLE OF CONTENTS
2
I F C
INTRODUCTION
1
TO ALL EMPLOYEES
3
EMPLOYEE RESPONSIBILITIES
3
MANAGEMENT RESPONSIBILITIES
3
WAIVERS
3
COMPLIANCE WITH L AWS
4
CONFLICT OF INTEREST
6
COMPANY PROPERT Y AND FACILITIES
7
COMPANY POLITICAL INVOLVEMENT
7
SECURITIES L AWS
8
ANTITRUST AND COMPETITION
8
ACCOUNTING BOOKS AND RECORDS
9
ENVIRONMENTAL COMPLIANCE
11
COMPUTER , E-MAIL AND INTERNET POLICIES
12
EMPLOYMENT POLICIES
13
PRODUCT QUALIT Y
15
TR ANSACTING INTERNATIONAL BUSINESS
16 REPORTING CONCERNS , PROBLEMS OR VIOL ATIONS
16 NO RETALIATION
GLOBAL STANDARDS OF BUSINESS CONDUCT
DEAR FELLOW EMPLOYEE,
Post Holdings, Inc. and its subsidiaries worldwide (“Company”) are
committed to doing business ethically and to fully complying with all
applicable laws and regulations. We believe this not only because it will
help us avoid legal problems, but because it is the right thing to do.
These Standards of Business Conduct (“Standards”) apply to all officers
and employees of the Company. The Standards are intended to inform you
of certain legal and ethical obligations relevant to your position with the
Company. The Standards govern our business relationships inside and
outside of the Company. The Company’s legal compliance policies, which
are available to you electronically or in hard copy, provide further details
about these Standards.
As individual employees, we should not only abide by the Standards set
forth in these guidelines, but we should take the steps necessary to
ensure that the Company is in compliance with them. In particular, each
supervisor and manager is responsible for ensuring his or her employees
understand and comply with these Standards. No employee can justify an
illegal or unethical act – even if he or she believes that doing so will benefit
the Company. No officer, executive or manager has the authority to violate
any law or to direct another employee or any other person to violate any
law on behalf of the Company.
If you have questions about any of the Company’s business practices,
you are encouraged to contact the Chief Compliance Officer or a member
of the legal department. You may also report your good faith concerns
according to the steps described in these Standards.
Sincerely,
R O B E R T V . V I TA L E
Chief Executive Officer
GLOBAL STANDARDS OF BUSINESS CONDUCT
1
YOU ARE EXPE CTED TO C OMPLY WITH
BOTH T H E L E T T E R A N D S PI R I T OF
THE SE STANDARD S.
2
GLOBAL STANDARDS OF BUSINESS CONDUCT
EMPLOYEE RESPONSIBILITIES
You are expected to comply with both the letter and spirit of these Standards, Company
policies and procedures, and the laws and regulations that govern our business. You
should be alert to any situations that could violate these Standards or other policies.
You should report suspected violations, issues or concerns according the steps
described in Reporting Concerns, Problems, or Violations section in the Standards.
If you are unsure how to perform your duties in accordance with these Standards, you
are expected to seek advice or clarification. When in doubt, ask for help. You can
contact your supervisor, the legal department or the Chief Compliance Officer.
MANAGEMENT RESPONSIBILITIES
If you are an officer, manager or supervisor, you have a special responsibility to set an
example by exhibiting high standards of behavior. You must also:
•m
ake sure employees for whom
• ensure that each employee for
you are responsible understand
whom you are responsible knows
that ethical business conduct and
and understands these Standards
compliance with Company policies
and relevant policies and
and procedures and applicable,
procedures and how to apply them;
laws and regulations is of
• demonstrate in words and deeds
paramount importance to the
your commitment to these
Company; and
Standards and relevant policies
and procedures;
• encourage employees for whom
you are responsible to seek advice
or help without fear of punishment
or reprisal;
• make
yourself approachable and
available to all employees for
whom you are responsible.
WAIVERS
Only the Board of Directors or one of its committees may waive compliance with
these Standards. Waivers, if any, may be granted only in writing and after careful
consideration of the nature and severity of the infraction and the context in which it
occurred.
COMPLIANCE WITH LAWS
It is the Company’s policy to comply fully with all applicable laws, rules and
regulations, both within and outside the country in which you work as well as all other
countries in which the Company operates. These Standards highlight some of the laws
that regularly affect the Company’s operations. Questions regarding the applicability or
interpretation of any law or regulation should be referred to the legal department.
Violations of applicable laws, rules and regulations may subject you to individual
criminal or civil liability, as well as disciplinary action by your local employer, up to
and including termination of employment in accordance with applicable laws.
GLOBAL STANDARDS OF BUSINESS CONDUCT
3
CONFLICT OF INTEREST
A conflict of interest occurs when outside activities or personal interests interfere or
appear to interfere with your ability to objectively perform your job or act in the best
interests of the Company. You must not knowingly place yourself in a position that
would create a conflict of interest or have the appearance of being in conflict with the
interest of the Company. The following standards relate to some of the most sensitive
areas of concern and are just examples. An actual or perceived conflict of interest could
take many forms. Situations that might constitute conflicts of interest should be
reviewed (in advance, if practical) with your supervisor and with the Chief Compliance
Officer or the General Counsel.
1 . ACCE
PTING G IFTS AN D E NTE RTAIN M E NT
Accepting any gift of more than nominal value or entertainment that is more than a
routine social event can appear to be an attempt to improperly influence your
decisions with respect to customers, vendors, consultants or the like. You should
observe the following standards when deciding whether or not to accept gifts.
G IFTS
ou may not accept gifts such as merchandise or products, as well as personal
Y
services or favors, unless they have a value of less than $100, or the local currency
equivalent, and is lawful under all applicable laws. No gift should ever influence or
appear to influence your business judgment. This dollar limit is intended to allow
you to accept gifts of a nominal value and foster ongoing relationships with
customers, suppliers and consultants. Gifts of any amount may never be solicited. A
gift of cash or securities may never be accepted. In some international business
transactions, it is customary and lawful for business leaders in a host country to give
gifts to Company employees. These gifts may be of more than nominal value and
under certain circumstances, returning the gifts or paying for them may be an
affront to the giver. If you receive a gift in such a situation, you must report the gift
promptly to your supervisor. In the event gifts cannot be returned and offering to
pay for them would adversely affect continuing business relationships, you must
promptly notify your supervisor and follow the instructions given to you with
respect to the gift. In some cases, the Company, at its sole discretion, may retain the
gift, rather than you. Please be advised that in some instances, gifts may constitute
taxable income to you in accordance with applicable law.
NTE RTAIN M E NT
E
Normal business entertainment such as lunch, dinner, theater, a sporting event, and
the like, is appropriate if of a reasonable nature. The purpose of accepting such
business courtesies must be to hold bona fide business discussions or to foster better
business relations. You should review (in advance, if practical) all such entertainment
with your supervisor, and confirm that meal and entertainment budgets are consistent
with all applicable laws and both the Company and the giver’s policies. As with other
gifts, you should never allow entertainment to influence your sound business
judgment.
4
GLOBAL STANDARDS OF BUSINESS CONDUCT
TR AVE L AN D LODG ING
You may not accept payment for, or gift of, free transportation, lodging or other
travel expenses unless you are traveling as part of a group hosted by a customer,
vendor or consultant or their representatives, the trip is business-related and not
excessive or lavish, and the gift or payment is accurately reported and approved in
advance by your supervisor. All such travel and lodging must be permitted under
all applicable laws, not given to improperly influence your sound business judgment
and must be consistent with both the Company and giver’s policies. If the outside
party reimburses you for transportation, lodging or other expenses that was paid by
the Company, the reimbursement payment should be given to the Company.
2. O
UTSIDE ACTIVITIE S
You may not engage in a “free-lance” or “moonlighting” activity that will:
• materially encroach on the time or
attention you should devote to your
duties;
• imply
sponsorship or support by
the Company of the outside
employment or organization; or
• adversely affect the quality of your
work performed;
•a
dversely affect the good name of
the Company.
• compete with the Company’s
activities;
You may not use Company time, facilities, resources, or supplies for such work.
3 . P ROVIDING G IFTS
A business gift of nominal value may be given by you only when the gift is in
accordance with generally accepted standards of business conduct in the location of
the recipient. Prior to making a gift of nominal value, you should ensure that you
understand the applicable legal requirements, the Company’s policies and that the
receipt would not violate the policies of the recipient’s employer by accepting the
gift. You should obtain your supervisor’s approval prior to providing a gift.
4 . I NTE RE STS IN OTH E R BUSIN E SSE S
Unless approved in advance by the Chief Compliance Officer (or the Audit
Committee in the case of a corporate officer), you may not directly or indirectly have
a financial interest (whether as an investor, lender, employee or other service
provider) in a competitor, or in a customer or supplier of the Company. The
ownership of a significant amount of stock or other securities in a publicly traded
company that is a competitor, customer or supplier is prohibited.
GLOBAL STANDARDS OF BUSINESS CONDUCT
5
COMPANY PROPERT Y AND FACILITIES
1. U
SE OF PROPE RT Y AN D FACILITIE S
Company property, facilities or physical resources may be used only for Company
business and for the purposes authorized by management and may not be used for
solicitation or distribution activities which are not related to an employee’s services
to the Company, except for charitable activities that have been approved in advance
by management.
2. T
H E FT AN D VAN DALISM
You should report to management any attempt to steal or vandalize Company
property, including documents, equipment, or intellectual property, personal
property of other employees, cash or any other items of value.
3 . M AINTAINING CON FIDE NTIALIT Y
Our business operates in many different and in extremely competitive markets.
Proprietary information and trade secrets must be safeguarded in the same way
that all other important Company assets are protected. You must protect from
inappropriate disclosure information concerning pricing, products and services
that are being developed, and other such trade any prospective Company acquisition
or divestiture. All files, records and reports acquired or created in the course of
employment are the property of the Company. Originals or copies of such
documents may be removed from the Company’s offices for the sole purpose of
performing your duties for the Company and must be returned at any time upon
request.
4. L
OANS
The Company does not make personal loans to officers or employees. This
prohibition does not apply to loans through the Company’s Saving Investment Plan
or other Company-sponsored 401(k)plans or advance payments made in accordance
with relocation or meeting and travel policies.
5 . I NVE NTIONS
The Company is legally entitled to all rights in ideas, inventions and works of
authorship relating to its business that are made by you during the scope of your
employment with the Company or while using the Company’s resources.
6
GLOBAL STANDARDS OF BUSINESS CONDUCT
COMPANY POLITICAL INVOLVEMENT
The Company does not maintain a political action committee. In addition, various
states/provinces prohibit contributions to candidates for state, provincial or local office,
and it is the Company’s policy to comply fully with applicable laws. As a result, no
Company contributions are permitted to a state, provincial or local candidate without
the prior approval of the Board of Directors or its designee.
SECURITIES LAW
The Company complies with all applicable securities laws, and the rules of the New
York Stock Exchange, where its securities are listed. The Company expects its
employees to do the same.
1. T
R ADING IN COM PANY SECU RITIE S
You may not trade in or recommend Company stock based on inside information.
“Insider trading” is the purchase or sale of a publicly traded security while in
possession of important non-public information about the issuer of the security.
Such information includes, for example, non-public information on Company
earnings, significant gains or losses of business, or the hiring, firing or resignation
of a director or officer of the Company. Insider trading and “tipping,” communicating
inside information to anyone who might use it to purchase or sell securities, are
prohibited by the securities laws. When in doubt, information obtained as an
employee of the Company should be presumed to be important and
not public.
Officers of the Company are also prohibited from trading in
Company stock during any period in which participants in the
Company’s retirement plans could not engage in a similar type
of transaction.
If you have questions pertaining to the sale or purchase of a
security under circumstances that might involve confidential
information, the timing of a purchase or sale of securities, or any
other aspect of applicable securities laws, you should consult with
the legal department.
2. D
ISCLOSU RE
The Company is committed to providing full, fair, accurate, timely and understandable disclosures in filings with the SEC and any other public communications. Only
authorized officers of the Company are permitted to respond to inquiries from the
media, financial community, investors and others. You should promptly refer all
such inquires the Chief Financial Officer.
GLOBAL STANDARDS OF BUSINESS CONDUCT
7
ANTITRUST AND COMPETITION
You must comply fully with applicable unfair trade, antitrust and competition laws.
Without approval of the Company’s legal department, you may not enter into any
understanding or agreement, express or implied, with any competitor of the Company
regarding prices, terms or conditions of sale, an allocation of markets, customers or
territories or a refusal to deal with, or participation in a boycott of, any customer or supplier.
If you make pricing decisions, you must understand and abide by the price
discrimination restrictions imposed by the applicable antitrust laws. If you are
involved in pricing decisions and are not sure of your legal responsibilities, contact the
legal department.
You must review with the legal department any activities or agreements that might
raise antitrust and competition issues. You should consult with the legal department
before proposing or entering into any agreements or understandings that:
•o
bligate a supplier or customer to
conduct business with us before we
will purchase or sell to them;
• r estrict a customer’s choices in
using or reselling Company
products or services;
• r equire a customer to purchase
Company products or services as a
condition to purchasing another
Company product or service;
• restrict
any party’s freedom to
conduct business with or produce
or provide any product or service
with any other party; and/or
• r estrict the freedom of a licensee or
licensor of any patent, copyright, or
licensing arrangement.
If a competitor approaches you about any of these matters, you should promptly contact
the legal department.
ACCOUNTING BOOKS AND RECORDS
The Company maintains accounting and internal control systems designed to provide
reasonable assurance that Company assets are safeguarded against loss and Company
financial records are reliable for preparing financial statements. No fraudulent or false
entries should be made for any reason in the books, records, or accounts of the Company.
The Company conducts, or causes to be conducted, internal and independent audits of
its financial statements, accounting practices and employee benefit plans. The Audit
Committee oversees management’s compliance with all applicable accounting
standards and financial reporting laws.
If you have supervisory duties, you should establish and implement appropriate
internal accounting controls over all areas of your responsibility to ensure the
safeguarding of the assets of the Company and the accuracy of its financial records and
reports. The Company has adopted controls in accordance with internal needs and the
requirements of applicable laws and regulations. These established accounting
practices and procedures must be followed to assure the complete and accurate
8
GLOBAL STANDARDS OF BUSINESS CONDUCT
recording of all transactions. You are expected to adhere to these procedures within
your area of responsibility.
Any accounting adjustments that materially depart from GAAP must be approved by
the Audit Committee and reported to the Company’s independent auditors. In addition,
all material off-balance-sheet transactions, arrangements and obligations, contingent or
otherwise, and other relationships of the Company with unconsolidated entities or other
persons that may have material current or future effects on the financial condition,
changes in financial condition, results of operations, liquidity, capital expenditures,
capital resources or significant components of revenues or expenses of the Company
must be disclosed to the Audit Committee and the Company’s independent auditors.
You may not interfere with or seek to improperly influence, directly or indirectly, the
auditing of the Company’s financial records. Violation of these provisions may result in
disciplinary action by your local employer, up to and including termination in
accordance with applicable laws, and may also subject the violator to substantial civil
and criminal liability.
If you become aware of any improper transaction or accounting practice, you should
report the matter immediately to your supervisor or to the chief accounting officer. You
may also file a complaint through the telephone number or website established for this
purpose and discussed in these Standards. There will be no retaliation against
employees who disclose in good faith questionable accounting or auditing matters.
THE C OMPANY IS C OMMITTED TO
C OMPLIANCE WITH A L L A PPL ICA B L E
L AWS A N D R E GU L AT IONS RELATING TO THE
PROTE CTION OF THE ENVIRONMENT.
ENVIRONMENTAL COMPLIANCE
The Company is committed to compliance with all applicable laws and regulations
relating to the protection of the environment. For example, senior plant management
at the Company’s production facilities must be aware of laws and regulations
impacting air and water (sewer) discharges and the storage, disposal and release of
waste and hazardous substances at their facility. Failure to comply with such laws and
regulations, even if unintentional, could result in significant penalties for the Company
and employees. Accordingly, if you suspect noncompliance with or violation of these
laws and regulations, the circumstances should be reported immediately to your
supervisor, plant manager of the facility in question or as provided in the Reporting
Concerns, Problems, or Violations section.
GLOBAL STANDARDS OF BUSINESS CONDUCT
9
YOU MUST BE C OU RT E OUS
TO OTHER USERS OF THE C OMPUTER
SYSTEM AND ALWAYS C ONDUCT YOURSELF
IN A PR OF E S S IONA L M A N N E R .
10
GLOBAL STANDARDS OF BUSINESS CONDUCT
COMPUTER, E-MAIL AND INTERNET
POLICIES
You are responsible for using the Company’s computer system, including, without
limitation, its electronic mail (email) system and the Internet properly and in
accordance with Company policies for proper business purposes. You should direct any
questions about these policies to your immediate supervisor or the Chief Compliance
Officer. You should be aware of, among other matters, the following:
1. T
H E COM PUTE R SYSTE M IS COM PANY PROPE RT Y
The computers provided by the Company for Company work are the property of the
Company and have been provided for use in conducting Company business. All
communications and information transmitted by, received from, created or stored in
its computer system (whether through word processing programs, e-mail, the
Internet or otherwise) are Company records and property of the Company.
Unauthorized use or distribution of such information would violate Company policy
and could also be unlawful.
2. P
ROFE SSIONAL USE OF COM PUTE R SYSTE M REQU IRE D
You must be courteous to other users of the computer system and always conduct
yourself in a professional manner. The Company’s policies on equal employment
opportunity and harassment prevention (sexual or otherwise) apply fully to the
Company’s computer system, and any violation of those policies utilizing the
Company’s computer system may be grounds for discipline by your local
employer, up to and including discharge, in accordance with applicable law.
3 . ILLEGAL , OFFE NSIVE AN D INAPPROPRIATE MATE RIAL
Company policies prohibit using the Company’s computer system to send, receive,
view, download or print messages or files that are illegal, sexually explicit, abusive,
defamatory, offensive or profane.
4. S
OLICITATIONS
The Company’s computer system should not be used to solicit for religious or
political causes, commercial enterprises, outside organizations, or other activities
not related to your services to the Company or to a Company-sponsored event.
5. C
OPYRIG HTS AN D TR ADE MARKS
The Company’s computer system may not be used to send (upload) or receive
(download) copyrighted materials, trade secrets, proprietary financial information,
or similar materials without authorization of the owner of such materials.
6. D
OCU M E NT RETE NTION
The space available for the storage of company documents, both on paper and
electronic, is limited and expensive. Therefore, periodic discarding of documents
which the Company is no longer required to maintain, in accordance with
applicable laws, is necessary. On the other hand, there are legal requirements that
certain records be retained for specific periods of time. Before disposing of
GLOBAL STANDARDS OF BUSINESS CONDUCT
11
documents, you should consult the applicable Records Management Policy. If you
are unsure about the need to keep particular documents, you should consult with
your supervisor, so that a judgment can be made as to the likelihood that the
documents will be needed.
Whenever it becomes apparent that documents of any type will be required in
connection with a pending, threatened or anticipated lawsuit, government
investigation or audit, all possibly relevant documents, whether in hard copy or
electronic format, should be preserved and ordinary disposal or alteration of
documents pertaining to the subjects of the litigation or investigation should
immediately suspended. If you are uncertain whether documents under your
control should be preserved because they might relate to a lawsuit or investigation,
you should contact the legal department.
EMPLOYMENT POLICIES
The Company is committed to fostering a work environment in which all
individuals are treated with respect and dignity. The Company requires a businesslike atmosphere that promotes equal employment opportunities according to
applicable law and prohibits discriminatory practices, including unlawful
12
GLOBAL STANDARDS OF BUSINESS CONDUCT
harassment. All relationships among persons in the workplace must be businesslike
and free of unlawful bias, prejudice or harassment. It is the policy of the Company to
ensure that employees, officers and directors treat one another and clients, visitors,
contractors and third parties with respect and consideration. It is further the policy of
the Company to comply with all applicable local, state/provincial and federal statues
concerning equal employment opportunity and the prevention of discrimination and
harassment.
It is the Company’s policy to comply with all applicable wage and hour laws and other
statutes regulating the employer-employee relationship and the workplace
environment. To the extent the Company interacts with labor unions, it may be illegal
for the Company or any of its employees or agents to pay to or receive anything of
value from any labor organization.
You may not interfere with or retaliate against another employee who seeks to invoke
his or her rights under the laws governing labor and employee relations. Retaliation or
reprisal against persons who initiate reports or cooperate or assist in the investigation
of a complaint is prohibited by this policy and will not be tolerated. Persons engaging
in retaliatory conduct are subject to disciplinary action, by their local employer up to
and including discharge. Prohibited retaliatory conduct applies to all aspects of
employment including hiring, discharge, pay, job assignments, promotions, layoffs,
training, benefits or other terms and conditions of employment. If you have any
questions about the laws or company policies governing labor and employee relations
matters, you should consult the applicable policies or contact the human resources
department, the Chief Compliance Officer or the legal department.
In addition, we are committed to providing a safe workplace for all employees. Several
laws and regulations impose responsibility on the Company to safeguard against
safety and health hazards. For that reason, and to protect the safety of themselves and
others, you and other persons who are present at Company facilities are required to
follow carefully all safety instructions and procedures that the company adopts. If you
become aware of any unsafe working conditions or any conditions that would violate
laws or regulations related to working conditions, you should immediately report
them to the applicable facility manager or such manager’s representative. Questions
about possible health and safety hazards at any Company facility should be directed
immediately to your supervisor.
PRODUCT QUALIT Y
Our success depends on the ability to consistently produce quality
products for our customers. Each division must maintain quality and
product safety standards that are in compliance with applicable laws
and regulations. In particular, each production facility must adhere to
good manufacturing practices. You must conduct your activities for
the Company in a manner designed to maintain the integrity and
quality of the Company’s products.
GLOBAL STANDARDS OF BUSINESS CONDUCT
13
THE C OMPANY IS C OMMITTED
T O C OM PLY I NG WITH THE
R E QU I R E M E N TS OF EACH C OUNTRY
WHERE IT C ONDUCTS BUSINE S S.
14
GLOBAL STANDARDS OF BUSINESS CONDUCT
TRANSACTING INTERNATIONAL
BUSINESS
The Standards apply to both domestic and international business transactions, and the
Company is committed to complying with the requirements of each country where it
conducts business. All employees engaging in international business activities must be
familiar and comply with the foreign and U.S. laws applicable to such international
business activities or seek the assistance of the Legal Department. Examples of
requirements that apply worldwide include:
1 . P AYM E NT FOR GOODS AN D SE RVICE S
Payment for goods and services provided to the Company outside the United States
must be paid for by Company check, draft or other approved documentary transfer
payable to the person or company legally entitled to receive payment. Written
contracts must be used to purchase goods and services except where purchases are
routine in nature and arise out of the Company’s ordinary course of business. No
payment may be made to a party in a country other than that in which the party
resides, maintains a place of business or has delivered goods or services for which
payment is made, except where it is clear that payment made in that country will
not violate local laws such as income, tax or currency control laws.
2. F
ORE IG N CORRU PT PR ACTICE S ACT (TH E “ FCPA”)/CORRU PTION
OF FORE IG N PU BLIC OFFICIAL S ACT
The Company may conduct business with governments and wholly or partially
government-owned enterprises. This means you may interact with government
agencies, officials and/or public international agencies. In every interaction, you
should apply the highest ethical standards and comply with applicable laws, rules
and regulations, including requirements associated with government transactions.
You should never directly or indirectly pay, or offer to pay, any foreign government
official (which includes any officer, employee or consultant of a government, or
government department or agency, officer or employee of a state-owned enterprise,
political party or official, candidate for political office, officer or employee of a public
international organization, such as the World Health Organization or World Bank,
or the spouse or immediate family member of any of the persons mentioned above
“government official”) to induce the official to misuse his or her official position in
order to benefit you or the Company. Doing so may not only violate the Foreign
Corrupt Practices Act, the U.K. Bribery Act and the Corruption of Foreign Public
Officials Act, but would also violate Company policy.
In addition, payments to foreign political parties or candidates may not only violate
the Foreign Corrupt Practices Act but also certain election laws, and should not be
made without the express written approval of the legal department.
3 . C USTOM L AWS
All employees involved in the exporting and importing of goods must be familiar with
and comply with applicable laws or seek the assistance of Company legal counsel. Such
customs laws and regulations typically require appropriate customs documentation,
“country of origin” marking and proper classification and value declarations.
GLOBAL STANDARDS OF BUSINESS CONDUCT
15
4. F
INANCIAL BOOKS AN D RECORDS
The FCPA requires the Company to maintain accurate and complete financial
books and records. No Company funds or assets can be used for any unlawful,
improper or unethical purpose. No undisclosed, unrecorded or secret funds or
assets can be established and no false or artificial entries can be made in the
Company financial books and records for any purpose.
REPORTING CONCERNS, PROBLEMS
OR VIOLATIONS
If you experienced or know of behavior that you believe violates the law or Company
policy, you should report such information promptly, in accordance with applicable
procedures, and if not addressed in a separate policy using the following procedures:
A. Contact
your immediate manager or supervisor or local employee representatives.
B. If you are not comfortable reporting to your local manager or supervisor, or are not
satisfied with the response, depending on the nature of your concern, you may also
report it as indicated in your country specific data privacy or whistleblower notices,
or by making an online report at reportlineweb.com/postfoods. This hotline and
website are 24/7 resources administered by a third-party, not the Company. Because
the manner in which reports can be made varies from country to country, the
hotline will give you further instructions on how and to whom to report your
particular concern. If it turns out that you are reporting about a matter that must
be handled locally according to local requirements, you will be directed back to
local management.
C. If you prefer and are located in the United States, Australia or Canada, you may
also report concerns by contacting the Chief Compliance Officer or by writing
to: C
hief Compliance Officer
Post Holdings, Inc.,
2503 S. Hanley Road,
St. Louis, MO, 63144
I f you are located in Europe, please review your local data privacy notice for directions
on which types of reports can be directed to the Chief Compliance Officer.
Whether calling or writing, please be as specific as possible about the situation and
location you are describing. Because it allows for a more effective investigation and
resolution of a report, we encourage you to give your name and other pertinent
information when making a report, rather than reporting anonymously. However, if the
situation warrants or requires it, you may also make a report anonymously. In this case,
you should give a sufficiently detailed description of the factual basis for the allegations
to allow an appropriate investigation. Confidentiality and anonymity will be protected to
the maximum extent possible, subject to applicable law, regulation or legal proceedings.
NO RETALIATION
You will not be retaliated against because of a good faith report or because you
cooperate with an investigation.
16
GLOBAL STANDARDS OF BUSINESS CONDUCT
Date effective: August 5, 2014
Last update: August 5, 2014
®
Corporate Headquarters
2503 S. Hanley Road
St. Louis, MO 63144
1 (314) 644-7600
GLOBAL STANDARDS OF BUSINESS CONDUCT
3