DEFINING SUCCESS // Corporate Governance and Ethics

Winning with Integrity

Codes and Policies

Campbell is committed to win in the marketplace and in the workplace in compliance with the law and in accordance with the highest ethical standards. We will compete vigorously, but we will be honest, lawful, and fair in our dealings with our employees, customers, consumers, communities, and all others whose lives we touch. This bedrock principle drives all that we do and illuminates all that we aspire to achieve. Our employees know that they are expected to honor our company's commitment to integrity at all times, everywhere in the world.

Campbell's Winning With Integrity program provides the resources, tools, and guidance that enable our employees to understand and comply with our standards and expectations for business conduct. The program includes, among other things, an interactive website, extensive written materials, and a comprehensive, worldwide training program. Among the resources available on our website are Campbell's Code of Business Conduct and Ethics, our Corporate Compliance Manual, information about our Integrity Hotline and our compliance and ethics training program, and links to core corporate policies.

Principal Codes and Policies

Campbell's Code of Business Conduct and Ethics is the foundation document of the Winning With Integrity program. The Code outlines our company's basic standards and expectations, highlights important Campbell policies, and summarizes certain fundamental legal requirements that our employees must follow at work. It also provides guidance about other resources to which employees can turn if they have questions or concerns about a potential legal or ethical problem. The Code is available in multiple languages, and every Campbell employee receives a personal copy.

Individual corporate policy statements on specific compliance issues are issued by the CEO and updated as necessary. Other policies, manuals, and guidelines are issued by the respective business units and corporate functions. 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.

New or revised corporate policies and guidelines are issued every year. In FY2010, for example, Campbell revised and re-issued its global guidelines for responsible advertising to children and its guidelines for personal postings on social media by Campbell employees.

Examples of key corporate policy statements and guidelines relevant to CSR and sustainability include the following:

• Human Rights Principles
• Environmental Sustainability Policy
• Political Accountability Guidelines
• Global Guidelines for Responsible Advertising to Children
• Commitment Concerning Advertising to Children
• Code of Business Conduct and Ethics
• Supply Base Requirements and Expectations Manual

Education and Training

Campbell provides comprehensive training for every employee on “core” issues relating to ethics and compliance, and “risk-based” training that is tailored to individuals' roles in the company and the issues associated with their specific job responsibilities.

As part of the Winning With Integrity program, all employees are required to complete annual training focused on our Code of Business Conduct and Ethics. This training is available online or in person, and is offered in 13 languages. To maintain interest and engagement, we vary our core training courses by emphasizing different aspects of the Code every year. One course, for example, focuses on situations involving workplace harassment, discrimination, violence, and concerns about product quality. Another illustrates the application of the Code to issues relating to workplace privacy, confidentiality, conflicts of interests and gifts, financial integrity, and records retention. Our newest core training course, launching in FY2011, focuses on workplace violence, social networking, and creating an ethical corporate culture.

Campbell's Integrity Hotline

Campbell's Integrity Hotline is a service through which complaints and concerns can be reported to the Company or the Board on a confidential and/or anonymous basis. Access to the hotline is available through a secure Internet website and toll-free by telephone from all countries in which Campbell does business. To comply with special requirements of the European Union (EU) and in certain EU member states, we maintain a separate hotline service for employees in France, Belgium, and Germany. The availability of the Integrity Hotline and instructions for its use are widely publicized to our employees around the world. All reports to our hotlines are investigated.

Evolution of the Program

Our Winning With Integrity program is continuously assessed and adjusted to reflect developments in our business, such as entry into new markets and other strategic initiatives. Reflecting our commitment to building a diverse and inclusive workplace, new online training in diversity and inclusion was introduced in FY2009 and a new anti-harassment online training course is being introduced in 2011. With the growth of our new business operations in Russia and China, we also expanded training on the Foreign Corrupt Practices Act.

We also modify our training program, as well as our standards and procedures for compliance, in response to new legislative and regulatory requirements, enforcement trends, political and public policy concerns, and trends in the broader business and financial environments. For example, in light of the heightened government scrutiny and new legislation concerning food safety, we updated the Food Safety Law Chapter in the Corporate Compliance Manual and are providing additional training on food safety, labeling, and crisis management issues.