FAQ's

Introduction

Ethical companies are built and sustained by ethical people. Mars, Incorporated (Mars) has a long history of outstanding performance in the marketplace, and has achieved this the right way, with integrity. Mars is committed to complying with the law and doing the right thing in the markets in which it operates.

The Five Principles of Mars require that we act ethically at all times. Ethics and Compliance at Mars: Our Guide to the Principles at Work (the Guide) is designed to provide clarity about the Company’s expectations and to reinforce the need to maintain a consistent culture of ethics, candor, transparency and respect for human rights.

Each of us play a critical role in protecting the reputation and integrity of Mars. It is through our Associates that we ensure that we are operating with ethics and integrity. If you see something that is inconsistent with the Five Principles of Mars or The Guide, we want you to say something. The Responsibility Principle requires us to have the courage to call attention to any Associate or business partner not behaving according to our values. It is our obligation to report misconduct when we see it. Doing so may be difficult, but it is the right thing to do.

Although there are multiple ways to escalate an issue, your line manager is often your first resource if you have a question or want to report a concern. If for any reason talking to a line manager is not a viable option, there are other resources available to you including: the Ombudsman, P&O, S&F, Internal Audit, Security, Legal Department, or Corporate Affairs.

If these other channels are not viable, you can always report a concern about a violation of the law or Mars Ethics and Compliance Guide and related polices to the Ethics and Compliance Helpline.

Know that if you report a concern, your concern will be taken seriously. Mars seeks to preserve confidentiality regarding any allegations of violations of laws or of Mars polices to the extent such confidentiality does not conflict with efforts to review, investigate, and otherwise address the issue, to take remedial or other action in response to the allegation, and/or to prevent further inappropriate behavior.

Mars will not tolerate retaliation. Mars wants to ensure our Associates understand any form of retaliation, punishment or retribution against anyone for raising or helping to address an ethics or compliance concern in good faith is not tolerated.

Please see below for Frequently Asked Questions:

About Mars Ethics & Compliance

What is the Ethics & Compliance Helpline?

The Ethics and Compliance helpline is an internal resource for Mars Associates and should be used for issues related to violations of laws or of the Mars Ethics and Compliance Guide and related policies. The Helpline is not intended to replace existing policies or procedures or methods of resolving internal complaints or concerns. Rather, it is intended to provide an additional reporting tool to Associates when the existing procedures are not available, are not considered appropriate or effective, or the Associate desires anonymity.

What types of issues or concerns should I escalate to Ethics & Compliance?

The E&C Helpline should be used to report issues related to ethics and compliance or a violation of laws or of the Guide, including:

• Fraud, theft, and misuse involving Company assets
• Financial books and records and internal controls
• Potential conflicts of interest
• Improper exchange of gifts, hospitality, or entertainment to business partners or to government officials
• Use of confidential information for personal gain, including insider trading activity
• Responsible sourcing, including potential human rights, child labor, or environmental violations
• Inappropriate activity with competitors or trade associations that interferes with fair competition
• Potential instances of bribery or corruption involving Mars Associates or our business partners
• Anti-Money Laundering laws, trade laws and sanctions violations by Mars or our business partners
• Data privacy concerns
• Information security and the protection of Company information

The Helpline is available if an Associate has previously raised an issue or concern to a line manager or through the encouraged communication channel and feels that it has not been adequately addressed, or feels uncomfortable raising the issue to a line manager or through another channel. This includes issues already reported to:

My P&O or Associate Relations

• Safety in the workplace
• Respect in the workplace, including any form of harassment, discrimination, or violation of human rights

The Site Quality Manager, S&RA, or Legal

• Consumer safety or quality

The Marketing Code Ambassador or senior marketing leader of the business unit

• Responsible marketing and advertising
• Inappropriate communications made on behalf of the Company, including via social media

Currently, if you are in a European Union (EU) country, you can only report to the hotline on the following matters: anti-bribery, auditing and accounting, banking and financial issues. These restrictions exist because there are restrictions in some EU countries on what may be reported, and these laws change frequently. However, if you would like to share concerns related to issues beyond the five issue types above, please contact your line manager, Legal or the Chief Compliance Officer directly at chiefcomplianceofficer@effem.com.

How does the Ethics & Compliance Helpline differ from the Ombudsman?

Ethics & Compliance conducts formal investigations; the Ombudsman can facilitate informal inquiries.

The Ethics & Compliance Helpline is intended to capture allegations related to violations of Mars’ Ethics and Compliance Guide or of applicable laws. Information provided through the Ethics & Compliance helpline may be retained, shared, and used for legal and investigative purposes.

What about confidentiality?

Mars seeks to preserve confidentiality regarding any allegations of violations of laws or of Mars policies to the extent such confidentiality does not conflict with efforts to review, investigate, and otherwise address the issue, to take remedial or other action in response to the allegation, and/or to prevent further inappropriate behavior.

Can I remain anonymous when contacting the Ethics & Compliance Helpline?

Although you can contact the Ethics & Compliance Helpline anonymously, please note that doing so could present challenges when trying to address your issue. In most cases, the best way to fully evaluate and address reported allegations is to have as much information as possible, including an understanding of all circumstances and individuals involved.

If you remain too uncomfortable to share your name with us, we will do what we can, in the circumstances, to provide support. When contacting Ethics & Compliance through the Ethics & Compliance Helpline, we are able to provide a ‘Report Key’ that enables us to both maintain confidentiality and stay in touch – read more below to find out how it works.

What’s the best way to reach Ethics & Compliance outside of the helpline?

Via email at ChiefComplianceOfficer@effem.com.

About NAVEX and EthicsPoint

Who are NAVEX?

NAVEX is an independent, confidential compliance program service and technology provider. Today NAVEX works with more than 13,000 customers around the globe, including 95 of the Fortune 100. NAVEX is committed to doing the right things right and believe they have the ability to help every organisation to do the same. NAVEX’s mission is to help organisations protect their people, reputation and bottom line.

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist management and employees to work together in addressing workplace issues, all while cultivating a positive work environment. The system is typically used to report concerns relating to issues like suspected fraud, abuse and other misconduct. Mars and the Ethics & Compliance team are leveraging the EthicsPoint system to support any Associate who wishes to raise Guide-related and legal concerns with Ethics and Compliance.

Why does Mars Ethics & Compliance need a system like EthicsPoint?

• In adopting EthicsPoint, Mars Ethics & Compliance aims to provide another channel for Associates to raise allegations or issues related to violations of laws or of the Guide. By creating more open channels of communication, we can further support a positive work environment and maximize productivity.
• An effective reporting system will allow us to better provide insight to our leadership regarding any systemic trends and persistent issues that from time to time may arise at Mars, and augment our other efforts to foster a culture of integrity and ethical decision-making, guided by The Five Principles and Associate Concept.

What is the difference between EthicsPoint Website and the Ethics Point phone line?

Essentially, when connecting with the Helpline via phone, the information you provide will be entered into the EthicsPoint system by a Specialist from NAVEX. If you prefer to make your submission via the web portal, you would be accessing EthicsPoint directly.

Reporting – General

Why should I report what I know?

We all deserve to work in an organization that acts in an ethical manner and in accordance with The Five Principles, as well as letting the proper people know if this is not happening. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

Where do these submissions go? Who can access them?

Submissions are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these submissions available to the Ethics & Compliance team, who evaluates the information and identifies the appropriate person(s) to look further into the matter. Relevant information will be shared with those who need to know in order to substantiate and address the issue.

About reporting Ethics and Compliance violations

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Mars promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the Company and all Associates, including you. You only have to consider what has happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So, if you know of any incidents of misconduct or ethical violations, consider it your responsibility to yourself and to your fellow Associates to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

Submit your concern. The Ethics and Compliance Helpline and EthicsPoint can help you prepare and file your submission so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The Ethics & Compliance Helpline and EthicsPoint system are designed so that implicated parties are not notified or granted access to submissions in which they have been named.

What if I remember something important about the incident after I submit my issue? Or what if the company has further questions for me concerning my report/submission?

When you contact the Ethics & Compliance Helpline either through the web site or by telephone, you receive a unique username and are asked to choose a password (Report Key). You can return to the Helpline either online or by telephone and access the original submission to add more detail or to answer questions posed by Ethics & Compliance, as well as add further information that will help resolve open issues. We strongly suggest that you return to the Helpline in the time specified to answer questions from the Ethics & Compliance team. You and Mars now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports/submissions as secure as the first one?

All Ethics & Compliance Helpline submissions and related correspondence are held in the same strict confidence as the initial submission, continuing under the umbrella of anonymity if you chose to be anonymous.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC connects with, and won’t this log identify me as having made a report?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website or you may use the telephone option to report a concern.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous if you choose anonymity when submitting the report. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system is designed to protect your anonymity when selected. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free helpline confidential?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and a Specialist will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

Can I still submit a concern if I don’t have access to the Internet?

You can file a submission from any computer that can access the Internet. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free helpline, which is available 24 hours a day, 365 days a year.