COMPLIANCE AND INTEGRITY PROGRAM

Our global Ethics & Compliance program helps guide our employees to adhere to all applicable laws and regulations while conducting business around the world. It also emphasizes conduct consistent with our commitment to act with integrity, as well as make ethical decisions for our business, our shareholders, our employees and our consumers, because their trust and confidence is critical to our success.

TRAINING-CONTACT-ACTION – MAKING COMPLIANCE AND INTEGRITY PART OF OUR CULTURE

We have a dedicated Compliance team around the world (including regional Compliance leads and subject matter experts) who work with senior management to implement our program. Our Compliance team helps ensure our employees know what is expected of them and how to make the right decisions, especially when faced with difficult or complex situations. Our live and online training programs are deployed to employees on a rotating basis to reinforce core policies. The objective of our training is to help employees understand legal and ethical business practices via periodic global eLearnings (approximately four annually) and other region/market-led training sessions. Our global learning and awareness platform includes:

• Code of Conduct
• Anti-bribery
• Anti-discrimination/harassment
• Fair competition
• Data privacy
• Conflicts of Interest & Gifts
• Sanctions Compliance
• Customs & trade Laws
• Anti-money laundering
• Insider trading

New hires are mandated to complete eLearning across these important topics, provided in local language.

Our global eLearnings target our broad employee base, while live sessions are targeted to risks specifically relevant to role and/or geography and also include part-time personnel. Code training is mandatory and deployed annually, while other mandatory compliance training programs generally follow a bi-annual cycle. Apart from formal training, we deploy global awareness campaigns on a quarterly basis to keep Compliance and ethical decision making fresh in our employee’s minds. These compliance awareness campaigns are intended to supplement our core trainings and respond to our evolving compliance risk landscape.

Audit & Risk Advisory regularly conducts audits of the application of MDLZ anti-corruption policies in our operations, on a rotating basis and in consideration of evolving risks in markets where we operate. Generally three to four audits covering anti-corruption policies and processes are conducted annually.

SPEAKING UP AND BEING HEARD

We expect and encourage employees to ask questions and raise concerns about business practices when they see something they think might be wrong. There may be times when employees are not comfortable speaking with their supervisors, Compliance, Legal or human resources contacts, or simply wish to remain anonymous. Consistent with applicable local law, we have a toll-free, and in some countries a collect call/reverse charge telephone HelpLine and an online version WebLine so our employees can confidentially and, if they wish, anonymously report instances of suspected wrongdoing or ask questions about compliance matters. Our HelpLine operates in more than 90 countries. Toll-free numbers and dialing instructions can be found by selecting the country you are calling from on the Integrity WebLine page.

LISTENING, INVESTIGATING, ACTING

In 2023, our business integrity group received more than 2,600 contacts from around the world through our "Speaking Up" channels. These contacts included questions about our compliance policies and program or matters that we referred to other departments for handling. We received reports of misconduct that required investigation. Some of these matters resulted in disciplinary action, including the separation of people from the company when appropriate.

REPORT TO MANAGEMENT AND THE BOARD

To make sure that senior management and the Board of Directors are aware of any potentially significant matters, our Compliance group reports investigations to members of our executive team and the Audit Committee of the Board of Directors.

EXTERNAL REPORTS OF WRONGDOING

Reports from people outside of the company of suspected wrongdoing may also be brought to our attention in four ways:

By mail:
Business Integrity Department
Mondelēz International, Inc.
905 West Fulton Market, Suite 200
Chicago, IL 60607
USA

By e-mail: Compliance@mdlz.com

Through our Integrity HelpLine: Our Integrity HelpLine is a toll-free and/or reverse charge service operated for Mondelēz International by a third-party. The HelpLine is accessible 24 hours a day, every day, and language interpreters are available. These toll-free numbers and dialing instructions can be found by selecting the country you are calling from on the Integrity WebLine page.

Through our Integrity WebLine: Our Integrity WebLine is an online version of the HelpLine. It is operated by a third-party for Mondelēz International and is accessible 24 hours a day. You can visit www.mdlzethics.com to access the Integrity WebLine.