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S E C T I O N H E A D E R
1
Code of Business Conduct and Ethics
2 0 1 6 E D I T I O N
I N D E X
A MESSAGE FROM ANDREAS FIBIG 03
LIVING THE CODE 04
Understanding and Complying with the Code 05
Reporting Concerns 05
RESPECTING EACH OTHER 06
Promoting Diversity and Inclusion 07
- Embracing Diversity
- Prohibiting Discrimination
Preventing Harassment 07
MAINTAINING A SAFE WORK ENVIRONMENT 09
Workplace Health and Safety 10
Substance Abuse 10
Workplace Violence 10
USING RESOURCES RESPONSIBLY 11
Protecting Our Property 12
Safeguarding Confidential & Proprietary Information 13
Protecting IFF Intellectual Property 16
Using IFF Communication & Information 17
Systems Responsibly
Allocating Company Time & Resources Appropriately 19
- Political & Community Activities
- Business Expenses & Accounts
AVOIDING CONFLICTS OF INTEREST 2 1
Conflicts of Interest 22
Gifts and Entertainment 23
ACTING ETHICALLY & FOLLOWING THE LAW 24
Our Conduct with Business Partners 25
Dealing with Competitors 26
- Antitrust and Unfair Trade Practices
- Competitor Information
Operating as a Public Company 27
- Insider Trading
- Communicating with the Outside
- Recordkeeping
BEING GLOBALLY COMPLIANT 30
Food, Drug and Chemical Control Laws 31
Government Inspections 31
Anti-Bribery and Corruption Laws 32
International Trade and Anti-Boycott Laws 34
Privacy Laws 34
SUPPORTING A BETTER WORLD 35
Being Socially Responsible 35
Respecting Our Environment 36
CONCLUSION 37
* NOTE TO EMPLOYEES
This Code is not a contract. It does not
convey any specific employment rights or
guarantee employment for any specific
period of time. The terms “Company” and
“IFF” in this Code mean International Flavors
& Fragrances Inc. and its subsidiaries and af-
filiates. There are references throughout this
Code to Company policies, standards and
guidelines (collectively “Company policies”).
In most instances, only the main points or a
summary of the Company policies appear in
this Code. For a complete copy of any Com-
pany policy, you should go to the “Policies and
Procedures“ section of IFFConnect or contact
the law or human resources department.
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At IFF, we are committed to achieving success as a global
leader in our industry. Our new purpose statement
articulates the magic and expertise we bring to the table:
“We are the catalyst for discoveries that spark the senses
and transform the everyday.” In my travels around the
world, I see our commitment to delivering on this promise
every day. We are equally committed to high standards of
ethics, honesty and integrity and demonstrating respect for
one another and those with whom we do business. Indeed,
as we model IFF’s ethics, we inspire others to do so.
As the world grows more complex, navigating its waters can
be challenging. This Code of Business Conduct and Ethics
serves as a compass outlining the general ethical standards
that each member of our organization is expected to follow.
While this Code does not address all ethical concerns that
may arise, it will provide the information you need to ask
the right questions and do the right thing. Please take the
time to read it carefully.
For over 125 years, IFF has been a company with its founda-
tions firmly rooted in honesty and integrity. I look forward
to continuing to build on that powerful legacy with you.
A Message from Andreas Fibig
ANDREAS F IB IG
C H A I R M A N O F T H E BOA R D A N D
C H I E F E X EC U T I V E O F F I C E R
“ We are the catalyst for discoveries that spark the senses and transform the everyday.”
W E L C O M E
L I V I N G T H E C O D E
We are creative, passionate, expert and empowered. We are proud of what our Company stands for and the solid, lasting and trusting relationships we’ve created with our customers, our colleagues and our business partners. We are inherently curious, never content with the norm, constantly pushing the boundaries to solve for today as well as striving to realize the promise of tomorrow.
Everything we do to drive growth and profitability must be done with the highest standards of ethics, honesty and integrity. Each action we take as we conduct our jobs must not only adhere to these high standards,
but must also comply with this Code of Business Conduct and Ethics (“Code”) and all laws that apply to the Company’s business affairs. Being a world- class flavor and fragrance company and increasing our profitability and operational excellence worldwide cannot, and will not, be done at the expense of our commitment to doing the right thing.
We strive to create an environment where employees love coming to work each day – a place that is committed, without exception, to inclusion, respect, accountability and doing what’s right.
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L I V I N G T H E C O D E
At IFF, each of us has an obligation to ensure that the Company
conducts business with integrity, honesty, and respect in full
compliance with this Code, Company policies, and applicable law.
If you become aware of or suspect a violation, you must report it.
IFF encourages the prompt reporting of any suspected or actual
violation so that a timely response and appropriate action may
be taken. You can report suspected or actual violations to your
supervisor, a human resources business partner, an attorney in
the law department or by calling the toll-free IFF Hotline or visiting
the IFF Hotline website. Certain matters, such as those relating
to workplace health and safety and environmental safety, may
also be brought to the attention of the global regulatory affairs
department (“GRA”).
The IFF Hotline offers employees the option to report a concern or
complaint on an anonymous basis. Regardless of how you choose
to report your concerns, the information you provide will be shared
only with individuals who have a need to know or who are neces-
sary to complete a thorough investigation.
Please be assured that you will not be subject to disciplinary
measures or retaliation for making any reports in good faith. If you
believe you have been subject to retaliation of any kind, you should
immediately contact a human resources business partner or an
attorney in the law department. For more information, please see
IFF’s guidelines on How to Report Concerns.
All IFF employees, at all locations, are responsible for reviewing,
knowing and complying with this Code and all applicable Company
policies. Violations of this Code, asking others to take actions that
violate this Code, or even failing to report a violation of the Code,
will result in disciplinary measures. The consequences will vary
depending upon the facts and circumstances and may result in
disciplinary action up to and including termination of your
employment with IFF.
While this Code captures many of the common situations that
employees may encounter, it does not address every situation.
There will always be circumstances that need to be addressed
more specifically or in which you simply are uncertain as to the
appropriate course to follow. In those instances, please refer to
the full copies of the relevant Company policies on IFFConnect
(available under “Policies and Procedures”) or contact the law
or human resources department.
Understanding and Complying with the Code
Reporting Concerns
Q U E S T I O N
I called the IFF Hotline to report some
comments from my manager that made
me uncomfortable. He was interviewed
as part of the investigation into my
complaint, and since then, has been
very critical of everything I do. Does my
manager’s behavior violate the Code?
A N S W E R
Maybe. IFF has a strict policy prohibiting
retaliation against any employee who
reports a concern in good faith. If your
manager is disciplining you because you
reported his behavior, he is engaging in
retaliation in violation of IFF policy. You
should report your manager’s behavior
to a human resources business partner
or an attorney in the law department.
What Would You Do?
R E S P E C T I N G E A C H O T H E R
IFF is committed to providing its employees with a work environment that is positive, creative and rewarding, and that promotes individual expression, innovation and achievement.
IFF further recognizes that each of us has the right to work in a professional atmosphere that promotes equal employment opportunities and is free from discrimina-tion, harassment or intimidation. Such a workplace can only be achieved and maintained if we act together and treat each other with respect and dignity and without bias or prejudice.
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Preventing Harassment
Similar to IFF’s policy against discrimination, the Company also
prohibits harassment based on race, color, ethnicity, sex, age,
religion, pregnancy, national origin, sexual orientation, disability,
veteran status or any other legally protected class or status, and
harassment of a sexual nature. Such behavior, as well as any form
of conduct that violates the right of IFF employees to work in a
harassment-free environment is unacceptable, unlawful and will
lead to disciplinary action.
Harassment takes many forms, and includes any activity that
creates an intimidating, hostile or offensive work environment, or
that has the purpose or effect of unreasonably interfering with an
individual’s work performance. Specific examples of harassment
include crude or offensive language, uninvited touching, sexually
suggestive pictures, indecent gestures, threats or inappropriate
jokes. The Company’s prohibitions against harassment apply to
actions of IFF employees, as well as suppliers, customers and other
business partners, and to activities in the workplace, as well as off-
site business settings. Any form of retaliation against
a person who reports harassment or aids in an investigation will
not be tolerated and will lead to disciplinary action.
R E S P E C T I N G E A C H O T H E R
EMBRACING DIVERSITY
At IFF, we welcome and embrace diversity. We appreciate the
power and expertise of different viewpoints. We are passionate
about embracing different cultures, languages and beliefs, and
in strengthening and empowering our diverse workforce and
business partners. Only by fostering a culture of inclusion and
making others feel welcome, appreciated and respected will the
Company be able to harness the creativity and experience of
its most valuable resource – its people – to find innovative and
competitive solutions for its customers and to continue to
succeed in an ever-changing global marketplace.
PROHIBITING DISCRIMINATION
IFF’s policy against discrimination supports our passion for diver-
sity in the workplace. It is IFF’s policy to provide equal employment
opportunities and to treat applicants and employees without
unlawful bias. Accordingly, IFF selects, hires, promotes, develops
and compensates employees based solely on their abilities, and
without regard to race, color, ethnicity, sex, age, religion, pregnancy,
national origin, sexual orientation, disability, veteran status or any
other protected class. We follow the laws that prohibit discrimina-
tion in employment practices wherever we do business.
Promoting Diversity and Inclusion
Q U E S T I O N
I am interviewing potential replacements
for my marketing manager, who is retiring.
The human resources department has
provided the resumes of several qualified
candidates, one of whom appears to be at
least 50 years old based on her graduation
date. Given her age, I am concerned she
will retire in a few years. Is it okay for me
to not consider her for the position?
A N S W E R
No, age is a protected class. If you choose
not to consider the candidate based upon
her age, you would be engaging in age
discrimination in violation of Company
policy and the law. The most qualified
applicants should be invited to interview
for any open position regardless of their
age or any other protected class.
What Would You Do?
R E S P E C T I N G E A C H O T H E R
Q U E S T I O N
My manager has a habit of telling
inappropriate jokes around the lunch
table. These jokes are never directed
at a specific employee, and most of the
people at the table don’t seem to be
bothered by them. Is this harassment?
A N S W E R
It depends. Not every inappropriate
joke or comment constitutes harassment.
However, at IFF, all employees have the
right to work in an environment free
from hostile, intimidating, or offensive
behavior. If you think you have been
subjected to such behavior, you
should contact a human resources
business partner, an attorney in the
law department or the IFF Hotline.
To sum it up: Together we can maintain a work environment where all employees are treated with respect and where differences, inclusion and diversity are valued. To achieve this, we must support the Company’s prohibitions against harassment and discrimination and be sensitive to discriminatory or harassing behavior and take action when we see it.
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What Would You Do?
If you are being subject to or witness harassing or discriminatory behavior, you must report such behavior to your supervisor, a human resources business partner, an attorney in the law department, or through the IFF Hotline. Speak up… you are empowered to be a part of the solution.
M A I N T A I N I N G A S A F E W O R K E N V I R O N M E N T
IFF is committed to the safety and security of our employees, business partners and other visitors to our facilities around the globe and expects that each employee does his or her part to maintain a safe, secure and healthy working environment.
This means all employees must comply with all applicable IFF health and safety policies, guidelines and procedures and with all applicable safety laws and regulations. We also have a duty to report any unsafe working conditions or activities of which we become aware so that IFF can do its part. Our safety and security depend on your vigilance and action.
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M A I N T A I N I N G A S A F E W O R K E N V I R O N M E N T
Workplace Health and Safety
When it comes to protecting the health and safety of our
employees, business partners and visitors to our facilities, there
are no short-cuts. Whether it involves cleaning up spilled water
on the plant floor, or reminding a co-worker to wear his or her
safety glasses, we all must be committed to a safe and secure
working environment for all employees. Each of us is responsible
for understanding and abiding by all applicable laws, regulations
and IFF policies designed to ensure safe working conditions
and to prevent injuries and accidents.
By being vigilant and aware of our surroundings, and by taking
action when appropriate, we all can play a role in making sure we
have a safe place to work. Remember, even the little things matter
when it comes to safety. If you become aware of any unsafe
condition or activity, contact your supervisor, a member of GRA
or the law or human resources department as soon as possible.
Substance Abuse
IFF maintains a work environment that fosters the health and
safety of its employees and protects the integrity of its business
practices. IFF will not tolerate the use, sale, possession or
distribution of illegal drugs on Company property, on Company
time or while operating Company-owned equipment or vehicles.
Any employee who improperly uses alcohol or illegal drugs of
any kind on Company property or works while under the
influence of illegal drugs or alcohol will be subject to disciplinary
action, including termination.
Workplace Violence
Acts of violence or threatening behavior by employees or by
any other person on Company property, or outside Company
property during Company activities or while engaging in IFF
business, are unacceptable and against IFF policy. This includes
physical aggression and verbal abuse as well as the possession
of any weapons (unless specifically permitted by Company policy).
Such acts and behavior are prohibited and must be reported
immediately to your supervisor or to a member of GRA or the
law department. If danger is imminent, contact the local police
or fire department immediately and follow any applicable site
or crisis policy.
A N S W E R
Report it. Each of us is required to
report workplace accidents and
injuries. Your plant’s desire to
achieve its safety goals should not
preclude any employee from
reporting a workplace injury or
facility damage and supervisors
must never encourage employees
to cover up a safety incident.
What Would You Do?
Q U E S T I O N
I accidentally damaged the plant’s
garage door while operating a forklift,
but I don’t want to report it because
it may negatively affect our plant’s
safety goal. What should I do?
U S I N G R E S O U R C E S R E S P O N S I B L Y
IFF’s property and assets are important tools that enable us to create and deliver the best and most innovative flavors and fragrances in the world. We must be passionate about protecting them and ensuring that they are used to advance the Company’s business objectives.
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U S I N G R E S O U R C E S R E S P O N S I B L Y
Protecting Our PropertyCompany property and assets are intended to be used
strictly for Company purposes. The misappropriation or
diversion of Company property or assets, as well as the
use of Company property or assets for personal, unethical
or illegal purposes or personal gain, or to benefit anyone
other than IFF, is prohibited.
Please note that all Company property and assets –
whether physical or intangible – must be returned at the
end of your employment with IFF.
CONFIDENTIAL AND
PROPRIETARY INFORMATION
formulas, business plans, sales,
marketing or product plans or
strategies, and other trade secrets
INTELLECTUAL PROPERTY
inventions, patents, trademarks,
processes, ideas and know-how
ELECTRONIC COMMUNICATION/
INFORMATION SYSTEMS & CONTENT
computer systems, software and
telephones supplied by IFF, and e-mail,
text, instant messaging, phone and
voicemails
PHYSICAL ASSETS
all Company premises, automobiles,
furniture, equipment, supplies and
product inventory
OUR EMPLOYEES’ TIME AT
WORK AND WORK PRODUCT
Examples of Company Property & Assets:
1
2
3
4
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U S I N G R E S O U R C E S R E S P O N S I B L Y
Safeguarding Confidential & Proprietary Information
At IFF, we are all in the business of discovery. Built on a legacy of innovative firsts, we know that to succeed, we must all be explorers. And this is why, within our organization and in partnership with our customers, we are constantly seeking what’s next, pushing each other to ask “what if” and to take smart risks – even in times of ambiguity – to create ground-breaking sensorial experiences.
Whether it’s being first-to-market with a revolutionary fragrance in response to a pressing consumer demand, cracking the code on a customer’s need for a break-through flavor, or rethinking supply chain processes that save customers time and support sustainability, we work together, leveraging a passionate team and a powerhouse of IP to deliver innovative “firsts” to our customers and the world over.
Protecting the confidentiality and integrity of our discoveries, unique formulas, manufacturing process-es and scientific data keeps IFF at the forefront of the flavors and fragrances industry. To retain IFF’s com-petitive advantage and ability to continuously deliver
superior products and services to our customers, it is critical that we work together to safeguard these unique and confidential assets, as well as our other confidential and proprietary information such as sales, business and pricing information.
You are obligated to protect and to take steps to prevent the unauthorized access or use of the Company’s confidential and proprietary information and that of our employees, customers, suppliers and other business partners.
Just as we cannot compromise our competitive advantage by disclosing the confidential and propri-etary information of IFF and our business partners, we cannot compromise our high standard of ethics, honesty and integrity by accepting or using the confidential and proprietary information of third parties, including our customers and competitors.
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U S I N G R E S O U R C E S R E S P O N S I B L Y
Proposed Changes in Senior
Management
Acquisition or Merger Plans
Any Other Information Not
Generally Available to the Public
Consumer Insights Data
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What is Confidentialand ProprietaryInformation?Any information about IFF, our employees, customers,
business partners or any other person that is not available
to the public and includes:
Formulas & Other Trade Secrets
Scientific & Technical Data
Business Plans & Outlooks
Customer Names, or the Products they Purchase
Processes, Drawings &
Designs
Financial & Operating
Information
Information Regarding
Research & Development
Marketing or Sales Programs, Plans
or Strategies
Operations & Training Manuals
Development Plans or Designs
Pricing Strategies
Identity, Grade or Source of
Raw Materials
Employee Data
Manufacturing Specifications,
Methods, Techniques &
Processes
Product Specifications
Product Launches
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U S I N G R E S O U R C E S R E S P O N S I B L Y
If you are unsure whether a particular piece of information is confidential, consider the following questions: – Is the information not known to the public?
– Could disclosure of the information harm or disadvantage
IFF or any employee or business partner of IFF?
– Could your work or the work of others be jeopardized
if the information is shared?
– Would disclosing or using the information violate any
law or regulation?
If your answer to any of the above questions is “yes,” then
you should consider the information confidential and treat it
accordingly. Determining whether information is confidential
or not can sometimes be tricky. If you have any doubts,
please contact an attorney in the law department.
WHEN AND HOW LONG DO YOUR OBLIGATIONS APPLY?
Your obligations with respect to confidential and proprietary
information, whether belonging to IFF, our employees, customers
or suppliers or even to a third-party such as a competitor of IFF,
apply at all times during your employment, including outside
of the workplace and working hours, and continue beyond your
employment with the Company.
COMMUNICATING THE “RIGHT WAY” TO MAINTAIN
CONFIDENTIALITY
Always be cautious and thoughtful when sharing confidential or
proprietary information, whether in writing – including e-mails –
or during private or group conversations. Be aware of your
surroundings when talking on a mobile phone or in a public
place (like an elevator, restaurant or public transportation) or at
a social gathering. Remember that your obligation to protect
confidential and proprietary information extends outside the
workplace and working hours and applies to conversations with
friends, colleagues at other companies and even to members
of your own family.
The bottom line is that disclosure of confidential information
should be limited within the Company strictly to employees
(or advisors) of IFF who require this information to perform their
duties for the Company. Similarly, the sharing of confidential
information outside the Company should take place strictly
if required for business purposes and steps have been taken,
such as the execution of a confidentiality agreement, to
prevent further dissemination or misuse of the information.
In all cases, disclosure must be in compliance with our
Confidential and Proprietary Information Policy, a copy of
which can be found on IFFConnect.
Q U E S T I O N
I’m in R&D and we have recently created
a new molecule. Only the IFF employees
who worked on the molecule are aware
of it. I’m having dinner with my best friend
tonight and I know I can trust him.
Can I tell him about it?
A N S W E R
No. You can’t talk to anyone outside IFF,
including your friends and family, about this
matter or any other confidential informa-
tion. In fact, you cannot even discuss this
confidential project with anyone within IFF
unless sharing the information is necessary
for the performance of your job duties or
the duties of the other person.
Q U E S T I O N
I’m an account manager for one of IFF’s
largest fragrance customers. The customer
recently asked if I could provide the formula
for a product the customer purchased.
Can I provide this information?
A N S W E R
Maybe, subject to the appropriate approv-
als and conditions. Formula and ingredient
disclosures may only be made with the
prior approval of a member of GRA or
the legal department according to strict
disclosure specifications and confidentiality
procedures. You should contact a member
of GRA if the customer is requesting dis-
closure for regulatory purposes. In all other
cases, please contact an attorney in the
law department.
What Would You Do?
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Protecting IFF Intellectual Property
All intellectual property invented, created or developed by
the Company or you during your employment with IFF are
Company assets and, as with all other IFF assets, may be used
only in connection with Company business and for the benefit
of the Company. This includes any inventions, formulas, processes,
products, programs, patents, trademarks, copyrights, trade
secrets, expertise, domain names, ideas, discoveries and
improvements conceived of or developed by you or any IFF
employee while working with or for the Company. No employee
can allow IFF’s intellectual property to be used or shared
outside the Company without appropriate legal protections
and documentation in place. Please contact a member of
IFF’s law department if you have any questions related to
intellectual property.
QUESTION
A chemist in our R&D group has just
resigned and plans to join a pharmaceutical
company. She told me that she is planning
on copying her files related to several unique
processes and molecules she created while at
IFF. It is unlikely IFF will ever actually use them.
Is it okay for her to take this information?
ANSWER
No. Everything an employee creates in his
or her capacity as an employee of IFF,
including processes and inventions, belongs
to the Company. They are to be used solely
in connection with Company business and
may not, under any circumstances, be taken
or utilized by an employee following his or
her departure.
What Would You Do?
QUESTION
We recently hired an employee from one
of our competitors. She mentioned that
she still had access to certain consumer
reports that she created while in her
previous position. These reports would
offer great insight into the local market.
Can we use these reports in preparing
our new marketing strategy?
ANSWER
No. Information created by the employee
in her prior position belongs to the
competitor. IFF does not condone or
allow any illegal activity to obtain or
disclose a competitor’s intellectual
property or other confidential information.
Infringing on a competitor’s property
rights can expose IFF and its employees
to potential legal liability.
U S I N G R E S O U R C E S R E S P O N S I B L Y
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Using IFF Communication & Information Systems Responsibly
IFF’s electronic communication and information systems,
including its computers, telephone and voicemail systems, e-mail
and general internet access, are made available to employees for
Company business purposes and to enable them to perform tasks
related to their jobs. Each of us is expected to use such resources
in an appropriate manner, consistent with all applicable IFF
policies, including our Electronic Communication Policy and
Social Media Policy. Inappropriate use of IFF communication
and information systems may result in disciplinary action.
EXAMPLES OF INAPPROPRIATE USE INCLUDE:
– Communications containing abusive, threatening,
profane, racist, pornographic or objectionable material
or that are defamatory
– Unauthorized copying or transmission of personal, sensitive,
or confidential information
– Accessing or viewing of networks, servers, drives, folders or files
to which access has not been authorized
– Solicitation of employees for any unauthorized purpose,
including political fundraising or religious activities
– Personal business activities
– Any activity that is illegal or unethical or otherwise violates
this Code or any Company policies
If you have access to IFF’s communication or information
systems, you are expected to take precautions to prohibit
unauthorized access to them. One such precaution is to
not share your systems passwords with others. You will be
responsible for all activities performed under your username
and password, so protect yourself and the Company by
keeping this information secure.
In order to keep IFF business information secure, you are
expected to use only IFF communication and information
systems to send, receive or store such information.
This means that non-IFF systems, including personal or
third party e-mail accounts, devices, computers, thumb
drives, telephones, smartphones or other wireless devices.
iPads, Blackberrys, instant messaging systems or non-
authorized cloud storage, may not be used (other than
through access2.iff.com) when engaging in IFF business.
U S I N G R E S O U R C E S R E S P O N S I B L Y
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U S I N G R E S O U R C E S R E S P O N S I B L Y
COMMUNICATING BY E-MAIL
Unlike a spoken conversation, e-mail creates a permanent record,
even if you believe you have deleted the information. Remember—
any e-mail you send may be printed by the recipient or forwarded
to others, even if you ask that the e-mail be kept confidential.
Treat an e-mail just like you would treat any other written business
communication. A good rule of thumb is to only include in an
e-mail what you wouldn’t mind seeing on the front page of
a newspaper.
DON’T EXPECT PRIVACY WHEN IT COMES TO
COMPANY SYSTEMS
All communications sent on, received through, or stored on any
Company system are Company property. Consequently, you
should have no expectation of privacy with respect to these
communications. This applies to both business and personal
communications and includes personal e-mails that you have
received, viewed or saved on a Company system, and even those
you think you deleted. All communications, as well as your use
of and activity (including internet browsing) on or through IFF
systems, may be accessed, monitored and recorded at any time,
without notice and without your permission, in accordance
with applicable law.
QUESTION
I need to work on an important presenta-
tion over the weekend, but I am going out
to dinner straight from the office and don’t
feel like lugging my laptop around town.
Can I send the latest draft to my personal
e-mail account or save it on a thumb drive
so I can work on it over the weekend?
ANSWER
No. Company equipment and systems
are equipped with appropriate security to
prevent a breach. Therefore, IFF data must
remain on IFF systems. IFF’s Electronic
Communication Policy strictly prohibits
employees from sending any IFF business
information to or through any non-IFF
system. This means that employees
must not send IFF information to their
personal e-mail.
What Would You Do?
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U S I N G R E S O U R C E S R E S P O N S I B L Y
Allocating Company Time &Resources Appropriately
POLITICAL & COMMUNITY ACTIVITIES
We encourage all of our employees to be involved in their
communities, and to be politically and socially active citizens.
However, we do not permit the use of our employees’ working
time or other Company resources or assets, including facilities,
phones, computers, copiers or office supplies, to further personal
political or community interests. This includes the posting or
distribution of notices or materials on IFF property and the
soliciting of other employees on Company time.
The decision to commit your free time or to contribute money or
other personal resources to political or community activities is
entirely up to you, and if you choose to engage in such activities,
your job will not be affected by your personal political views or
contributions. IFF will not, however, reimburse you for your
personal political activities or contributions.
When engaging in the political process, you must comply with
the laws and regulations governing political activity and contri-
butions, including those governing corporations. Note that IFF’s
Policy on Political Contributions strictly prohibits direct or indirect
contributions by the Company to any political office and the
reimbursement of any such contribution made by an employee.
Because these rules can be very complex, all political activity on
behalf of the Company, including the following, must receive prior
clearance from the Company’s General Counsel:
– Political contributions, no matter how small, if to be
made on behalf of the Company
– Lobbying activities (including meetings and
communications with government officials) in support
of or in opposition to issues that affect our business
– Indirect Company assistance such as furnishing goods,
services or equipment to politicians, candidates, parties
or committees, as well as purchasing tickets or
advertisements for political fund-raising events
U S I N G R E S O U R C E S R E S P O N S I B L Y
BUSINESS EXPENSES & ACCOUNTS
IFF has established accounts with various business partners
for the supply of goods and services to enable the Company
to conduct its business. Similarly, IFF has a comprehensive
Travel and Business Expense Policy, which provides for the
reimbursement of travel and entertainment expenses to
the extent that they are reasonable, necessary, and directly
related to business purposes. The purchase of items for
personal use through a Company account, or otherwise with
Company funds, and the intentional misreporting of expenses
will be treated as theft of Company assets. If you have a
question concerning a particular account, purchase or
expense, or the rules and procedures applicable to you,
please consult your manager.
QUESTION
My co-worker told me that he
occasionally adds a few personal
items to our department’s supply
order. Is this behavior acceptable?
ANSWER
No. It is never acceptable to purchase
items for personal use through a
Company account or with Company
funds. Improper use of Company
funds will result in disciplinary action
and, where warranted, legal action. If
you suspect that a coworker is misus-
ing Company funds, you must contact
a member of the human resources
department, an attorney in the law
department or contact the IFF Hotline
and make a report.
20
What Would You Do?
A V O I D I N G C O N F L I C T S O F I N T E R E S T
21
Each of us has a duty of loyalty to the company, which means that we must avoid situations that create, or appear to create, a conflict between our personal interests and IFF’s interests.
When confronted with conflict situations, you must always make decisions based on sound business reasoning and put the Company’s interest first. Conflict situations are often tricky. So, if you become aware of an actual or potential conflict, or have any doubts, bring it to the attention of the law department. Avoiding conflicts of interest in our business activities and decision-making is essential to our values of loyalty and integrity.
22
A V O I D I N G C O N F L I C T S O F I N T E R E S T
This is a complex area, and situations often need to be
examined on a case-by-case basis. If you become aware
of a conflict or potential conflict, contact your supervisor,
a human resources business partner or an attorney in
the law department for advice.
If you find yourself in a potential conflict situation, ask yourself
whether your personal interests interfere or may appear to
others to interfere with those of the Company? If the answer
is yes, then refrain from taking any action that conflicts or
may be perceived as conflicting with the Company’s interests.
Be aware that all waivers of conflicts or potential conflicts
must be approved by IFF’s General Counsel. For additional
guidance on potential conflicts, please refer to IFF’s
Conflict of Interest Policy.
Conflicts of Interest
All IFF employees are expected to give their undivided business
loyalty to the Company. This means that each of us must act
in the best interest of IFF while performing our jobs and take
care to avoid conflicts of interest. A conflict of interest can take
many forms but arises when your personal activities and
relationships interfere, or even appear to interfere, with your
ability to act in the best interest of IFF.
THE FOLLOWING ARE A FEW EXAMPLES OF COMMON
CONFLICTS OF INTEREST THAT SHOULD BE AVOIDED:
– Having a financial or ownership interest or other business relationship with a competitor, supplier or customer of IFF
– Conducting IFF business with a family member or any business in which a family member has a personal stake
– Working as a consultant for a competitor, supplier or customer of IFF
– Serving as an employee, officer or director of another company while employed by IFF
What Would You Do?
Q U E S T I O N
I would like to hire my cousin’s firm
to perform security services for the
Company’s buildings. I don’t think it’s
a big deal as long as he gives us the
best price and provides the same
quality of service as other providers.
Do I have to tell my manager that
I am related to the owner?
A N S W E R
Yes, because it is a potential conflict of
interest if your relative owns or works
for a vendor or service provider with
whom we do business. In a situa-
tion like this, you must receive prior
approval from your manager and from
IFF’s General Counsel.
23
A V O I D I N G C O N F L I C T S O F I N T E R E S T
Note that this requirement applies to all forms of gifts, including
free services, special favors, products, discounts, entertainment
and even free travel. In the case of business-related entertainment
activities, you are also accountable to ensure that your actions
and expenditures comply with IFF´s Travel and Business
Expense Policy.
As a global Company, IFF appreciates that there are cultural
practices that include gift-giving and entertainment in countries
where we do business. While we respect these practices, we must
be careful not to let them override our commitment to comply
with the legal and ethical requirements of each of these countries.
While understanding the difference between appropriate and inap-
propriate entertainment and gifts is not always easy, be guided
by this: if it doesn’t feel right, it probably isn’t. If public disclosure
of a gift or entertainment could cause embarrassment to IFF or
to you personally, it is unacceptable. If you are unsure about a
particular gift or entertainment activity, you should always contact
an attorney in the law department before taking any action.
Gifts and Entertainment
At IFF, we promote successful working relationships and goodwill
with our customers, suppliers and other business partners, as
they are vital to our success. The Company recognizes that
business entertainment such as dining out or attending events
can play an important role in strengthening working relationships
with our business partners. These activities must be reasonable,
conducted in connection with Company business and in the best
interest of IFF, and must not influence an employee’s business-
related decisions.
We also recognize that it is customary for some of our business
partners, and in certain cases, IFF employees, to occasionally give
gifts to those with whom they do business. Although the offering
or receipt of extravagant gifts or of cash or cash equivalents such
as gift cards is never acceptable, the offering or receipt of a gift
of minimal value may be permitted, provided that it is done openly
and lawfully in accordance with acceptable practices in our indus-
try in the country in which it is taking place. It is critical that the
offering or receiving of a gift does not, and would not be perceived
to, influence the nature or continuation of IFF’s relationship with
the business partner who is giving or receiving the gift.
If you give or receive a gift, or entertain or are entertained by
business partners, you must comply with the Company´s
Conflict of Interest Policy and the policies of IFF´s business
partners, as well as all laws and accepted industry practices.
Q U E S T I O N
We selected a new IT service provider and
upon signing a contract with the company,
the owner presented me with a very expen-
sive bottle of champagne. May I accept it?
A N S W E R
No. Accepting modest gifts from business
partners such as pens, calendars, fruit
baskets or other similar items is accept-
able. It is unacceptable for employees or
our business partners to give or receive
extravagant gifts, including expensive
wine or liquor, jewelry, electronics, cash
or gift cards. Always seek advice from an
attorney in the law department in advance
of taking any action that may conflict with
the Company’s interests.
Q U E S T I O N
One of our vendors invited me to attend
the World Cup and also offered to pay
for my airfare and hotel for three days.
Can I accept the invitation?
A N S W E R
No, you cannot. An all-expense paid trip
to the World Cup would be considered
extravagant and could easily be perceived
to be a gesture the vendor is making in
an attempt to influence its business
relationship with the Company.
What Would You Do?
Delivering superior innovation, expertise and creative products to our customers not only requires a commitment to our people, our business partners and our Company, but also to doing things the right way. Each of us must do our jobs with integrity – acting ethically and following the law.
24
A C T I N G E T H I C A L L Y & F O L L O W I N G T H E L A W
25
A C T I N G E T H I C A L L Y & F O L L O W I N G T H E L A W
Our Conduct with Business Partners
Making quality decisions in our business means that we must
consider the consequences of all of our actions and decisions.
We’re committed to free enterprise and competition based on
expertise and creativity and to complying with all legal and
ethical rules that govern our business.
IN ALL OF OUR BUSINESS DEALINGS WITH CUSTOMERS
AND SUPPLIERS, WE MUST:
– Avoid any unfair or deceptive practices and always present our
services and products in an honest and forthright manner
– Treat all customers and suppliers honestly, fairly and objectively
– Expect suppliers to compete fairly for our business and
select them based on merit
Similarly, we expect our vendors and other business partners to
act in compliance with all laws, rules and the same ethical princi-
ples under which IFF operates. These principles are set out in our
Vendor Code of Conduct, which is available on IFFConnect.
What Would You Do?
Q U E S T I O N
My department plans to hire an employee
from one of our competitors. Are there any
special rules that have to be followed?
A N S W E R
Yes. You must consult the law department
before hiring an individual from a compet-
itor. While it may be acceptable to hire the
employee, the individual may be under
a legal obligation not to work with a com-
petitor or reveal confidential information.
The law department will need to review
the specific circumstances before any
offer is made to the individual.
Q U E S T I O N
During a visit to an important customer,
I was handed a sample of an encapsulated
fragrance technology that a competitor
has developed but not yet put on the
market. The customer asked if I could
match the sample. Can I do this?
A N S W E R
No. If the sample is not commercially
available, we cannot accept it. IFF will
always respect the intellectual property
of our customers, competitors and any
third party. If there is ever any doubt as
to whether a sample may be analyzed,
contact a member of the law department
for guidance.
26
A C T I N G E T H I C A L L Y & F O L L O W I N G T H E L A W
Dealing with Competitors
ANTITRUST AND UNFAIR TRADE PRACTICES
IFF is committed to succeeding through fair and legal competition,
and strictly prohibits any activity that violates antitrust laws or
unlawfully restrains competition. Specifically, IFF prohibits agree-
ing to or engaging in activities with our competitors or others to
fix prices (including price components such as rebates, discounts,
freight allowances or other sales terms), to boycott suppliers or
limit production, or to divide markets, sales territories, product
lines or customers. Even informal discussions with our competi-
tors about these types of activities are prohibited.
Antitrust laws (also referred to as competition laws) are very
complex and vary from country to country. If you have questions
concerning communications or interactions with competitors,
you should seek advice from an attorney in the law department.
Be aware that the consequences of violating antitrust or
competition laws can be extremely serious for the Company
and you. Violations can lead to fines and imprisonment for
the individuals involved and to heavier fines and costly civil
lawsuits for the Company.
COMPETITOR INFORMATION
Just as IFF values and protects its own non-public information,
we respect the non-public information of other companies. IFF
does not allow and will not tolerate any illegal or unethical
activity to obtain or disclose competitor information—no matter
how useful the information may be. We may only collect, share
or use competitor information as long as it is done in a legal and
ethical manner. It is acceptable to obtain competitive intelligence
through publicly available information such as filings with govern-
ment agencies, public speeches of executives, news articles and
ethical inquiries. We may also accept competitor information from
a third party, as long as there is no reason to believe that the third
party obtained the information in an unethical way or is under a
contractual or legal obligation not to reveal such information.
What Would You Do?
Q U E S T I O N
At a trade association meeting last week,
one of our competitors started talking
to me informally about “staying away”
from one of her customers. She said the
conversation was “off the record.”
Was that okay?
A N S W E R
Absolutely not. While trade association
meetings perform a useful and legitimate
function for IFF and our competitors, they
should be approached with great care no
matter where they take place. Discussions
with our competitors, even those that may
be “off the record” in areas such as pricing,
terms of sale, territories or customers,
must be avoided. If a competitor tries to
discuss any of these subjects, you should
ask the person to stop immediately, and if
necessary, you should leave the meeting.
Q U E S T I O N
Is it ever acceptable for me to
discuss prices of our products with
our competitors?
A N S W E R
No. These types of discussions could
subject both you (personally) and IFF
to serious criminal or civil charges.
It’s simple: price fixing or agreeing to
fix prices is illegal.
27
A C T I N G E T H I C A L L Y & F O L L O W I N G T H E L A W
Operating as a Public Company
INSIDER TRADING
Buying or selling IFF securities (including stock, restricted stock
units, stock options or stock-settled appreciation rights) when
you know material non-public information about the Company
is not only unfair—it’s against the law and can result in severe civil
and criminal penalties for you and IFF. This rule applies to all
employees and relates to all material non-public or “inside”
information about IFF and other companies.
Trading in Company securities or in those of any other company
while in possession of material inside information about either
entity, is strictly prohibited; as is telling other people, including
family members and friends, about material inside information
regarding IFF or any other company. Anyone, including a family
member, who trades in securities while possessing material
inside information, may be violating the law and subjecting him
or herself to civil and criminal penalties.
WHAT IS MATERIAL INSIDE INFORMATION?
“Material inside information” is any information that has not
been made available to the public and that a reasonable person
would consider important in making a decision about whether
to buy or sell a security. This includes information about the
Company, as well as information about other companies
such as our business partners and competitors. Examples
of material inside information include:
– Earnings forecasts, estimates or results
– Acquisitions, divestitures or restructuring
– Management changes
– Upcoming product launches or product innovations
– Gain or loss of important business or contracts
For more detailed information about IFF’s prohibition against
insider trading, consult the Insider Trading Policy on IFFConnect
or contact an attorney in the law department.
SPECIAL RULES FOR INSIDERS
Due to the role they perform for the Company, or their access
to confidential IFF information, certain employees are subject to
pre-clearance requirements and other additional requirements
applicable to trading in IFF securities. If you are an “insider,” you
should consult the Company’s Insider Trading Policy on IFFCon-
nect or a member of the law department for further information.
Q U E S T I O N
I am assisting on an acquisition by IFF
of a company in the fragrance business.
Can I buy or sell securities of IFF or the
target company?
A N S W E R
No. Knowledge of the acquisition is
material inside information. If you buy or
sell while in possession of such informa-
tion, you would be violating the securities
laws and IFF policy.
Q U E S T I O N
Is it wrong to share inside information
with others even if I don’t use it to
benefit myself?
A N S W E R
Yes. In fact, you may be found to be
even more at fault because you are the
person starting the “chain” of wrongdoing.
Communicating material non-public
information to any other person, even
if you don’t realize any gain, may result in
you personally being held liable both
civilly and criminally.
What Would You Do?
A C T I N G E T H I C A L L Y & F O L L O W I N G T H E L A W
COMMUNICATING WITH THE OUTSIDE
As a publicly traded Company, IFF is governed by strict securities
laws relating to the public disclosure of information relating to
the company. To comply with these laws, and to ensure the
integrity of the information IFF communicates and the effective-
ness and consistency of IFF’s message, all public statements,
public speaking engagements and media interviews regarding
IFF or its business, whether “on the record” or “off the record,”
and whether with investors, stock analysts or the media, should
only be made by IFF executives who are authorized to speak
for the Company. If the media or any outsider contacts you for
information about IFF, explain that our policy does not allow
you to comment, and direct the person to a member of the
corporate communications department.
28
A C T I N G E T H I C A L L Y & F O L L O W I N G T H E L A W
29
Q U E S T I O N
I overheard someone in the finance
department ask a supplier to “hold”
invoices for a few weeks for supplies
we already received so that our year-
end numbers would look better.
This just doesn’t seem right to me.
What should I do?
A N S W E R
Your instinct is the right one. Holding
invoices to manipulate the numbers is
unacceptable and a violation of IFF policy.
Hiding or disguising liabilities, or keeping
off our balance sheets items that should
be there, is unethical, illegal, and will not be
tolerated. If you witness any such behavior,
you should immediately report it to your
supervisor, the law department or through
the IFF Hotline.
RECORDS MANAGEMENT AND DESTRUCTION
Company records must be maintained, retained and disposed of in
accordance with IFF’s Records Management Policy, which is avail-
able on IFFConnect. The policy applies not only to paper records
but also to records in digital, electronic or other forms, including
e-mails, voicemail, web pages, computer programs, databases
and other electronically stored documents and data, and specifies
the requirements for their maintenance, retention and orderly
destruction. Please refer to the policy for the retention period
applicable to a particular type of record.
LAWSUITS AND INVESTIGATIONS
Documents or records that are relevant to an actual, threatened
or reasonably foreseeable lawsuit, investigation, audit or admin-
istrative proceeding, or that you have been directed by the law
department to retain, must not be destroyed or altered. If you
are unsure about a particular document, retain the document
and consult an attorney in the law department for guidance.
Your compliance with this obligation is critical as the destruction
or alteration, even inadvertently, of a document that is relevant
to a lawsuit, audit or administrative proceeding or otherwise
subject to a legal hold could expose the Company and you to
civil and criminal liability.
What Would You Do?
RECORDKEEPING:
FINANCIAL, REGULATORY AND OTHER RECORDS
Complete and accurate books and records are essential to manag-
ing IFF’s business and maintaining the accuracy and integrity of
the Company’s financial reporting and disclosure. This in turn
reflects on the Company’s reputation and credibility and ensures
that the Company meets its legal and regulatory obligations.
“Books and records” do not refer to just financial accounts, but to
all records prepared, generated or maintained in the course of the
Company’s business, including invoices, purchase orders, agree-
ments, time sheets, payroll documents, travel and expense reports,
test results, safety and environmental reports and regulatory
filings. Similarly, the responsibility for ensuring their accuracy
and completeness does not rest on just the Company’s accounting
and financial personnel but on each of us. When you contribute
to the creation of business records, for example, by submitting
an expense report, a time sheet or supply orders, you are responsi-
ble for the honesty and accuracy of the information you submit.
You also are responsible for reporting any suspected violations of
the Company’s accounting and reporting policies and procedures,
which can be found on the finance department’s “Policies and
Procedures“ section of IFFConnect.
Any attempt to conceal or misstate information in Company books
or records is a serious offense and may result in disciplinary action
and criminal prosecution, leading to fines or even imprisonment.
The rule is clear: all records and reporting must be complete, fair,
accurate, timely and not misleading. No exceptions.
Q U E S T I O N
A former employee of IFF has sued
the Company, complaining that he was
discriminated against. My boss has
“strongly suggested” that to protect the
Company, I should conduct a search and
delete any e-mails with the employee’s
name in them. What should I do?
A N S W E R
Don’t conduct the search, and do not
delete or destroy anything! Contact the
law department immediately to report
your manager’s request.
30
At IFF, we pride ourselves on our creative expertise and our ability to deliver superior flavors and fragrances all over the world. However, our creativity, expertise and operational excellence can only be celebrated if it is achieved in compliance with the rules governing what we do and how we do it, wherever we do business. Compliance is not optional.
B E I N G G L O B A L L Y C O M P L I A N T
31
Government Inspections
IFF’s production and other facilities around the world may be
subject to inspections by environmental, food and drug, workplace
safety, labor, health, drug enforcement, agriculture, transportation,
immigration or other government representatives. In addition, our
financial and other records may be subject to audit by tax,
customs or other authorities. Such inspections and audits may
be pre-arranged or may occur without warning or prior notice.
In either case, IFF is committed to cooperating and to dealing
honestly and truthfully with the government officials conducting
such inspections and audits. The Company will not tolerate any
false or misleading statements being made in connection with an
inspection or audit, or generally with Company business.
If you receive an inquiry or request from a governmental authority
regarding a Company matter, you should immediately contact an
attorney in the law department or a member of GRA for guidance.
In the event of an inspection of a manufacturing or other facility,
follow the applicable local policy and contact the site manager.
B E I N G G L O B A L L Y C O M P L I A N T
Food, Drug and Chemical Control Laws
IFF conducts business in full compliance with all applicable laws,
rules and regulations wherever we do business. This includes
all food, cosmetic, drug and chemical control laws, many of
which can be complex. These laws govern:
– The labeling of IFF’s products or the consumer goods
incorporating our products
– The claims we make about our products
– How our products are manufactured
IFF’s global reputation and success depends on each of us
understanding and complying with the rules that govern our
business. If you have any questions about these rules, you
must seek immediate guidance from your supervisor or
a member of GRA or the law department.
Q U E S T I O N
I want to present a customer with a
fragrance that contains an ingredient that
has not yet been cleared internally for
fragrance use. The ingredient is already
cleared for flavor use. Can I present
this fragrance?
A N S W E R
No. The ingredient cannot be used until
the internal clearance process is complete
for the “end use” of the product. Regu-
lations that apply to fragrances do not
necessarily apply to flavors, and vice versa.
Your course of action: wait.
Q U E S T I O N
A supplier has advised me that its product
contains trace levels of a contaminant,
but the levels are extremely low and
present no safety concern. He also told
me that the supplier is taking steps to
eliminate the contaminant. Do I need to
tell my supervisor?
A N S W E R
Yes, immediately. Even the slightest hint
of an environmental, safety or quality
problem with one of our products or ingre-
dients must be reported as soon as it is
discovered. You should contact a member
of GRA or the law department right away.
What Would You Do?
32
B E I N G G L O B A L L Y C O M P L I A N T
Anti-Bribery and Corruption Laws
As a global Company, we are often required to interact with
officials of various governments around the world. Virtually every
country has special legal rules that apply to transactions with
governments, including anti-bribery and corruption laws that
prohibit the bribery of government officials. Anti-bribery and
corruption laws such as the U.S. Foreign Corrupt Practices Act
(“FCPA”) and the U.K. Bribery Act are extremely far reaching and
apply to all Company operations in all countries. These laws are
rigorous and complex and the sanctions for violating them can be
severe – including significant individual and corporate fines, and
even imprisonment. IFF has developed policies and procedures
for complying with such laws, which each of us must be familiar
with and abide by when dealing, directly or indirectly, with gov-
ernment officials in the performance of our jobs. Be aware that
IFF’s Anti-Bribery Policy applies to all employees of IFF worldwide
and mandates compliance with all anti-bribery and corruption
laws and with IFF’s global standards.
WHAT IS PROHIBITED?
IFF’s Anti-Bribery Policy generally prohibits the giving of
anything of value to a government official or any other person
in any country to influence that person’s decisions to help the
Company obtain or retain business or gain an unfair advantage.
This includes, for example, the giving of money, business or
employment opportunities, gifts and entertainment, travel,
special favors, or anything else of value, for the purpose of:
– Influencing a decision or to obtain or retain business
– Influencing the outcome of a government audit,
inspection or decision
– Facilitating an import through customs
– Obtaining a business or other license
WHO IS A GOVERNMENT OFFICIAL?
The following are examples of persons who may be considered
government officials:
– Any officer or employee of a foreign government,
regardless of rank
– Employees of government-owned or government-
controlled businesses
– Foreign politicians, political parties or candidates for office
– An agent or any family member of the above
33
B E I N G G L O B A L L Y C O M P L I A N T
WHAT ABOUT THIRD PARTIES ACTING ON IFF’S BEHALF?
Because IFF may be held liable for inappropriate payments made
by third parties, agents or consultants acting on our behalf, we
must take particular care when engaging third-party agents or
consultants to interact with government officials on behalf of IFF.
This includes performing appropriate due diligence, entering into
appropriate contracts, and requiring all such agents or consultants
to agree to abide by all anti-bribery laws and Company policies.
SOMETHING DOESN’T FEEL RIGHT
To avoid violating these complex and potentially harsh laws,
always consult with the law department if you become aware
of or are asked to make a payment that could be characterized
as a bribe or kickback, or if something simply “doesn’t feel
right.” For more information please refer to the Company’s
Anti-Bribery Policy or contact the law department.
Q U E S T I O N
A flavor product manufactured in China
has arrived at the port in Buenos Aires,
Argentina without the proper labeling.
The Argentine customs official told me
that he would release the shipment if
we pay him 4,000 pesos. We need this
product urgently to satisfy a customer
order. Can I make the payment?
A N S W E R
Absolutely not. By making the payment,
IFF Argentina (and you personally) would
be violating the Argentinean labeling laws
as well as anti-bribery laws. Note that
similar laws exist in many other countries
around the world so, irrespective of the
location, IFF employees should consult
with an attorney in the law department
whenever confronted with this type
of request.
Q U E S T I O N
In the course of the annual inspection of
an IFF plant in India for the renewal of its
operating license, the city official conduct-
ing the inspection has found several health
and safety violations. The local agent we
are using to help facilitate the inspection
and licensing process says that the inspec-
tor will overlook the violations and approve
the renewal, but it would require giving the
city employees a sizable donation. Can
we make this donation or have our agent
make it on IFF’s behalf?
A N S W E R
No. It is the Company’s policy not to give,
directly or through a third party, anything
of value to a government official or any oth-
er person in any country to influence that
person’s decisions to help the Company
obtain or retain business or gain an unfair
advantage. The Company’s Anti-Bribery
Policy also requires that appropriate back-
ground checks be conducted by the law
department in advance of appointing any
third-party agent to interact with govern-
ment officials on IFF’s behalf. You should
immediately contact the law department
to discuss the request.
What Would You Do?
Be aware that non-compliance could result in severe sanctions
against the Company and you, including fines and imprisonment,
and even an outright prohibition on the Company’s right to partici-
pate in import-export activities.
Privacy Laws
Personal data is information that can identify an individual,
including employees, contractors, business partners, customers
and anyone else with whom IFF does business. The Company
respects the confidentiality of personal data, whether on paper
or in electronic form, and requires that such information be
handled responsibly and in compliance with all applicable privacy
laws. If you have access to personal data in the performance of
your job, it is important that you collect, access, use, or share
such data only to the extent necessary and relevant to fulfill your
assigned job responsibilities and in accordance with Company
policies, local laws and regulations. Privacy laws vary in scope
and complexity, depending on where you are doing business.
If you have any questions regarding the privacy laws applicable
to you or concerning your responsibilities, contact an attorney
in the law department.
34
B E I N G G L O B A L L Y C O M P L I A N T
International Trade and Anti-Boycott Laws
As a global flavor and fragrance company, IFF delivers its expertise,
creativity and products throughout the world and across many
borders. As a result, the Company and our business activities are
subject to various international trade and customs regulations,
including laws governing imports and exports, and anti-boycott
laws. These include:
– Government-imposed export controls, trade restrictions,
trade embargoes, legal economic sanctions and boycotts,
which restrict the Company and its affiliates from engaging
in business activities in certain countries or with certain
individuals or entities
– Anti-boycott laws that prohibit companies from participating
in or cooperating with an international boycott that is not
approved or sanctioned by the U.S. government
IFF is committed to full compliance with these laws. If, in your role
at IFF, you are responsible for making decisions about where or to
whom we sell our products, or are otherwise involved in business
transactions across national borders on IFF’s or our customers’
behalf, you must familiarize yourself and comply with the laws
applicable to such activities.
International trade laws and anti-boycott laws are extremely
complicated. If you have any questions regarding these laws or
concerns that you may be engaging in prohibited business, or if
you receive a boycott-related request, you should refer to the Com-
pany’s International Business Transactions Policy for guidance or
contact a member of GRA or an attorney in the law department.
S U P P O R T I N G A B E T T E R W O R L D
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Being Socially Responsible
IFF has an extensive history of innovation, customer focus and consumer insights as well as a deeply ingrained sense of responsibility. We understand that the well-being of our employees and the continuing success of our customers and our own business depends on our passion for and commitment to a sustainable future.
Sustainability has long been part of the essence of how we do business at IFF. This principle and our commitment to the future has been formalized in our sustainability strategy and drives the innovation that results in social and environmen-tal improvements – from the raw materials that we source responsibly, to our eco-efficient manufacturing facilities, to carefully designed products that consider critical sustain-ability attributes. Our four-pillar strategy - sources, impact, products, people - is fully integrated and targets the most material opportunities to create sustainable flavors and fragrances for our customers and for consumers worldwide. For details of our past achievements, ongoing activities and future goals, refer to the Company’s latest Sustainability Report available on IFFConnect.
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What Would You Do?
S U P P O R T I N G A B E T T E R W O R L D
Respecting Our Environment
Having integrity in our business dealings and activities means
that we are dedicated to being an environmentally responsible
and sustainable corporate citizen. Caring about our employees,
our customers and our communities means that we must
have unwavering respect for the future of our planet and think,
every day, about how we can do our part to conserve our
valuable natural resources.
Whether complying with environmental laws and regulations
at all of our facilities, or recycling the plastic water bottles
we may drink from at lunch, each of us must comply with the
law to reduce waste and to help conserve energy, water and
other natural resources.
Q U E S T I O N
I think there is a problem with our
waste water treatment equipment, but
repairing it will interfere with production
and probably cost more money.
What should I do?
A N S W E R
Tell your supervisor, manager or envi-
ronmental health and safety coordinator
about the problem so that repairs can be
promptly scheduled. If your supervisor
fails to take appropriate action, report the
issue to a member of the human resourc-
es department or the law department or
through the IFF Hotline.
C O N C L U S I O N
A “no” answer to even one of these questions, would mean that the de-cision or action is unethical, inappro-priate, or could have serious negative consequences for both the Company and you and should not be taken.
This Code of Business Conduct and Ethics is an import-ant part of our future and guides the way we deal with each other, our business partners and the communities in which we conduct our business. It’s up to each of us to ensure that IFF continues to be successful by reinforcing our great culture, values and relationships, and never compromising our ethical principles and integrity.
Each of us must strive to make good decisions and to do the right thing. While in certain situations the right result is obvious and the decision can be made easily, in many situations the right result is less clear-cut or you may face time constraints or differing business pressures. When faced with a difficult situation, asking yourself these questions can help you make the right decision:
IFF is a passionate and creative organization focused on the future. I S I T L EG A L?
W O U L D I F E E L C O M F O R TA B L E I F I T
B EC A M E P U B L I C ?
D O E S I T R E F L EC TI F F ’ S VA LU E S ?
I S I T C O N S I ST E N T W I T H C O M PA N Y
P O L I C Y ?
1
3 4
2
If you are unsure about the answer to any of these questions, consult a member of the human resources department or the law department.
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