CODE OF CONDUCT

The Mondelēz International Code of Conduct ("Code") is a key part of our compliance and integrity program. It includes a set of employee policies that cover ethical and legal practices for nearly every aspect of our business. It focuses on the personal responsibility each employee has to conduct business legally and ethically. The Code is available online and has been translated into 32 languages and distributed around the world. Mondelēz International colleagues are trained on the Code on an annual basis and are required to read, understand, and comply with the Code.