Our company actively seeks opportunities to improve the quality of life in our communities, and to protect the environment that sustains us all.
The first and foremost obligation of responsible citizenship is to obey the laws of the countries and communities in which Sara Lee does business. Any case of noncompliance with applicable law may subject the employee to disciplinary action. The fact that in some countries certain standards of conduct are legally prohibited, but these prohibitions are not enforced in practice or their violation is not subject to public criticism or censure, will not excuse an illegal action by a Sara Lee employee.
Sara Lee is proud of its contribution to the economic and social development of the locations where it has operations. Sara Lee encourages employees to be actively involved in the improvement of the communities in which we live and work. The financial support provided by the Sara Lee Foundation and the company, and the voluntary charitable leadership offered by thousands of Sara Lee employees around the world, illustrate this commitment. No one in the company, however, may pressure another employee to contribute to or participate in a charitable organization.
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Sara Lee is committed to protecting the quality of the environment around the world through sustainable environmental practices. We will meet or exceed applicable environmental laws and regulations. Sara Lee strives to continuously improve our environmental performance through resource conservation, waste minimization, water and energy efficiency and effective use of raw materials. We will measure our environmental performance and work to promote environmentally friendly practices that respect the earth and our finite resources.
Employees are expected to comply with all applicable environmental laws, regulations, and Sara Lee policies, and to report any incidents or conditions that might result in an environmental violation or have an adverse environmental impact. Employees also are encouraged to identify opportunities for improving our environmental performance, including, for example, conservation and recycling.
Sara Lee is further committed to working with our suppliers and engaging in dialogue with members of our global community to make sound sustainable environmental progress. Our diligent adherence to this commitment will help us maintain our position as a corporate leader in generating value for our customers, for our shareholders and for society.
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| At Sara Lee, when we discuss sustainability,
we mean making sure that the
activities we engage in are carried out with
thoughtful and responsible attention not simply
to today’s world, but to the impacts of these
activities on future generations. One example
of this principle is our ambition of someday
achieving full sustainability in our coffee
sourcing. This is a long term, joint effort of
all involved in the coffee chain. Sara Lee buys
an increasing amount of certified sustainable
coffee every year and runs its own projects
in countries of origin to assist small coffee
farmers in becoming certified. We are a founding
member of the global Common Code for
the Coffee Community initiative to establish a
worldwide standard for the production, processing
and trading of mainstream green coffee. |
Sara Lee respects the right of each of its employees to participate in the political process and to engage in political activities of his or her choosing. While involved in their personal civic and political affairs, however, employees must at all times make clear that their views and actions are their own, and not those of Sara Lee. Employees may not use Sara Lee resources to support their personal choice of political parties, causes or candidates.
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| We recently faced two mosquito-spread epidemics
in India – Dengue Fever in Delhi and Chikungunya
in Kerala. We could have simply marketed
our mosquito coils more aggressively. But
instead we also worked with local agencies to
distribute our products for free and at reduced
prices to the poor in the affected regions. – India |
It is the policy of Sara Lee not to make financial or in kind political contributions, even when permitted by law. Lobbying activity on behalf of the interests of Sara Lee is permissible, but highly regulated by law. Employees who communicate with government employees and officials on issues that affect Sara Lee must contact the law department to ensure that such activities fully comply with the law and that Sara Lee’s lobbying efforts are coordinated.
Sara Lee will honor all applicable anticorruption laws, including local laws and the Foreign Corrupt Practices Act (FCPA). No employee or agent may bribe, promise to pay or authorize the payment of money or anything of value to government officials, parties or candidates for the purpose of infl uencing their acts or decisions.
Where appropriate, agents acting on behalf of Sara Lee should sign a written contract that includes a statement that the agent will not make payments prohibited by the FCPA or local law, and employees must be vigilant to ensure they abide by the law. Not all payments to government officials are illegal, but because of the complexity of these regulations, the law department and Sara Lee’s policy on FCPA compliance must be consulted in advance of any payment to a government official.
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| I was doing a check of packaged blueberry
bagels and noticed that they looked different—
like they had fewer blueberries than
usual. A co-worker told me not to worry
about it, but I took it up the chain and they
made the right call. It wasn’t really a big
deal, but I am still glad we didn’t ship them
out as first quality. – USA |
Sara Lee cooperates with every reasonable request from government agencies and authorities. Sara Lee is entitled to all of the safeguards provided by law to a person being investigated, including representation by legal counsel from the very beginning of an investigation. All requests from government agencies and authorities for information other than what is provided on a routine basis should therefore be reported to the law department immediately, and the law department’s guidance should be received before responding to any such request.
All information provided should be truthful and accurate. Never mislead any investigator, and never alter or destroy documents or records in response to an investigation.
Many laws govern the conduct of trade across borders. Among these are laws to:
- Make sure that transactions are not being used for money laundering.
- Ensure that companies do not cooperate in any way with unsanctioned boycotts.
- Restrict trade with certain countries.
When third parties conduct studies on our behalf or use Sara Lee funds to support their studies, Sara Lee will require that our sponsorship is disclosed in any publication or dissemination of such research.
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