CODE OF ETHICS POLICY
The successful operation and reputation of Seaboard Corporation and its consolidated subsidiaries (collectively, the “Company”) depend upon the professional work performance and the ethical conduct of its directors, officers and employees. The Company’s reputation for integrity and excellence requires careful compliance with the spirit and letter of all laws and regulations, as well as a commitment to the highest standards of personal and professional conduct.
This organization was built by people with sound character and a long history of good commercial practices. There is an attitude of trust and respect between the Company and its customers, employees, business partners, suppliers, and shareholders. That trust and the Company’s reputation must be preserved and protected. Directors, officers and employees have a duty to support the goals and objectives of the Company, and to act in a way that will always merit the continued confidence of those who have placed a reliance on the Company.
Accordingly, the Company adopts the following Code of Ethics:
|Honest and Ethical Conduct
Directors, officers and employees shall exhibit and promote the highest standards of honest and ethical conduct by:
· Encouraging and rewarding professional integrity thereby eliminating coercion, fear of reprisal, or alienation from the Company itself, which can act as barriers and inhibit responsible and ethical behavior.
· Avoiding, prohibiting and eliminating any conflict of interest or appearance of a conflict of interest between the Company and what could result in personal gain for a director, officer or employee of the Company, as defined in the attached Conflict of Interest policy.
· Following a process for employees of the Company to inform senior management of practices which deviate from honest and ethical behavior.
· Demonstrating their personal support for such policies and procedures.
· Acting in the best interests of the Company in order to preserve the Company’s reputation as a professional company operating with integrity and good character.
|Financial Records and Periodic Reports
Directors, officers and employees shall, to the extent applicable within the scope of their job functions, ensure that:
· Business transactions are properly authorized and completely and accurately recorded on the Company’s books and records in accordance with Generally Accepted Accounting Principles (GAAP) and established Company financial policy.
· The retention or proper disposal of Company records shall be in accordance with established Company policies and applicable legal and regulatory requirements.
· Reports and documents the Company files with, or submits to, the Securities and Exchange Commission, or other mandated public communications and disclosures, contain full, fair, accurate, timely and understandable information.
Directors, officers and employees shall not enter into any agreement, understanding or arrangement with any competitor about prices, territory restrictions, refusals to sell, allocation of business, or collaborative bidding, or engage in any other type of anti-competitive practice in violation of applicable laws or regulations.
|Compliance with Applicable Laws, Rules and Regulations
Directors, officers and employees shall comply with applicable laws and regulations in the course of all conduct on behalf of the Company, including the United States Foreign Corrupt Practices Act (FCPA) of 1977.
In addition to the general policies above, the Company adopts the following additional conduct-related policies as part of the Code of Ethics:
· Conflict of Interest and Confidentiality
· Seaboard Corporation Code of Conduct and Ethics for Senior Financial Officers
· Trading Seaboard Securities
· Office of Foreign Asset Control (OFAC) Policy
· U.S. Foreign Corrupt Practices Act (FCPA) Policy
These policies are attached. As a condition of employment, each employee of the Company must be familiar with these policies and agree to abide by their provisions. Violations of the content or spirit of this Code of Ethics and its related provisions are unacceptable and may lead to disciplinary action up to and including termination of employment or separation of ongoing business relationship with the Company.
If anyone has knowledge of a violation of this Code, such person should report the matter to one or more of the following: the person’s immediate supervisor or the Company’s General Counsel. Alternatively, the matter may be reported online by visiting www.seaboard.ethicspoint.com; by calling the Company’s dedicated toll-free number, 866-676-8886, for calls originating from the United States; or by calling the applicable phone number associated with the specific country, as set forth at the aforementioned website, for international calls. Matters may also be emailed to SBD_Ethics@seaboardcorp.com. The Company will not allow any retaliation against an employee who acts in good faith in reporting any such violation or suspected violation.
This Code of Ethics covers a wide range of business practices. It does not address every issue that may arise, but provides general guidance about the Company’s expectations of proper conduct and basic ethical and legal responsibilities. All consolidated subsidiaries of Seaboard Corporation shall adopt this Code of Ethics or a similar policy containing only such changes as are approved by Seaboard Corporation’s General Counsel. Any questions as to the meaning of any provisions of this Code of Ethics policy, or whether intended conduct is a violation of this policy, should be addressed to the Company’s General Counsel.