Oetker Code of Business Conduct

“Code of Conduct”

Author: Group management of the Oetker Group

Bielefeld, February 10, 2011

version status date comment who

1.0 approved Feb 10, 2011 Signature Group management

Table of Contents

Preface .................................................................................................................................. 1

I. Scope of Application ....................................................................................................... 2

II. The basis: strict compliance with the laws ...................................................................... 2

III. Conduct in competition – antitrust law ......................................................................... 3

1. Dealings with Competitors .......................................................................................... 3

2. Dealings with Customers ............................................................................................ 4

3. No abuse of a dominant position in the market ........................................................... 4

4. Registration of corporate acquisitions and company divestitures ................................ 4

5. Early seeking of legal advice in antitrust issues .......................................................... 4

IV. No violations of anti-corruption laws ............................................................................ 5

1. Offering and granting of advantages ........................................................................... 5

2. Demanding or accepting advantages .......................................................................... 5

3. Conduct vis-à-vis office-holders .................................................................................. 6

V. Money laundering ........................................................................................................... 6

VI. Foreign trade provisions ............................................................................................. 7

VII. Protection of research and technical development ...................................................... 7

VIII. Separation of private and corporate interests .............................................................. 7

IX. Use of Company property ........................................................................................... 9

X. Secrecy/Protection of business secrets .......................................................................... 9

XI. Data protection and data security ..............................................................................10

XII. Documentation of business transactions ....................................................................10

XIII. Handling of files and recordings .................................................................................10

XIV. Dealings among Staff Members .................................................................................11

XV. Protection of the environment ....................................................................................11

XIV. Occupational safety ...................................................................................................12

XVII. Conduct vis-à-vis authorities ..................................................................................12

XVIII. Compliance with the Oetker Code of Conduct ........................................................13

1. Compliance organization ...........................................................................................13

2. Questions on the Code of Conduct, contact persons .................................................13

3. Complaints and indications ........................................................................................14

4. Consequences of violations .......................................................................................14

5. Revision of the Oetker Code of Conduct ....................................................................14

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I. Scope of Application

The Oetker Code of Conduct applies to all domestic and foreign companies of the Oetker

Group1 and is implemented by the individual Group companies (hereinafter referred to as the

“Company”). The principles of conduct codified in the Code of Conduct are binding for all

members of the supervisory boards, managing directors, executives and staff members of

the Oetker Group (hereinafter referred to as “Staff Members”2).

In addition to and irrespective of this Code of Conduct, the applicable laws shall certainly

apply to the conduct of all Staff Members. The Code of Conduct serves to make transparent

the fundamental legal requirements with which the Staff Members have to comply in their

activity for each Company of the Oetker Group to the latter and to make them aware hereof.

In addition to the general rules of this Code of Conduct, all rules and instructions that already

exist or will exist in the future in relation to special subdivisions shall continue to apply

without limitation and supplementary to this Code of Conduct. Staff Members must, for

instance, continue to fully comply with existing occupational safety, travel cost or purchasing

policies. If there exist any deviations in any particular case, the more stringent rule shall

apply.

Each Group Company may establish further rules of conduct, for instance, in order to

account for the particularities inherent in their particular field of business or country as long

as they are in line with the basic principles codified herein.

II. The basis: strict compliance with the laws

The Company respects applicable law and expects its Staff Members and business partners

to do likewise. A legal situation that is unfavorable in the point of view of any individual or the

Company may not be ignored. The Company observes applicable law, irrespective of

whether that is domestic, foreign or supranational laws, rules or any other provisions

(hereinafter referred to as “Laws”). All business matters shall be handled in the daily

business with customers, suppliers, Staff Members or government agencies in such a way

that they comply with all applicable Laws (such as labor law, tax law or customs law).

1 The “Oetker Group” refers to Dr. August Oetker KG and its subsidiaries.

2 The term “Staff Members” is hereinafter used for both male and female Staff Members. This applies

mutatis mutandis to other gender-specific designations.

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Any violation of imperative statutory provisions, e.g. of product liability law, antitrust law, data

protection law or environmental law, may lead to unforeseeable financial losses to the

Company and an impairment of its reputation. At the same time, the violation of the law might

result in damage claims against the general management, the responsible executives and

the Staff Members directly involved and finally, the competent authorities may institute

administrative proceedings, administrative offenses proceedings or even criminal

proceedings, depending on the facts.

The Company always acts through human beings. In safeguarding the legal system, the

interest of the Company and the interest of its Staff Members are completely identical.

Therefore, each Staff Member is obligated to comply with the Law applicable in his or her

scope of duties, and each executive must ensure compliance with this duty on the part of

their staff. For this reason, the executives must inform themselves and their staff on the Laws

applicable to their respective scope of duties.

It is strictly prohibited to cause third parties to perform illegal acts or to participate herein.

Executives shall be responsible that in their spheres of responsibility Laws will not be

violated by any conduct which could have been avoided by means of appropriate

supervision. They must make clear that violations of the Law are disapproved of and will

have disciplinary consequences. In this connection, the rules contained in this Code of

Conduct must expressly be brought to the attention of the Staff Members.

III. Conduct in competition – antitrust law

Antitrust Laws, also referred to as Law on competition, protect free competition. Violations of

Antitrust Law might lead to particularly high fines and damage risks both to the Company and

the responsible Staff Members.

1. Dealings with Competitors

Agreements and concerted actions between competitors that are intended to restrict

competition or have the effect of doing so are prohibited. The most important taboos under

Antitrust Law are agreements or concerted positions between competitors relating to: (1)

prices or price elements, (2) the division of markets, territories or customers, (3), boycotts,

(4) the control of the production process, the technical development or of investments, and

(5) those made or held in connection with calls for tenders. Even concerted actions, informal

talks or informal gentlemen’s agreements that are intended to restrict competition or have the

effect of doing so are prohibited. Staff Members must not even give the appearance of being

a part of such conspiracy.

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The mere exchange of commercially sensitive information with competitors is also prohibited,

in particular with reference to current or future prices or price elements, the time or amount of

price increases, discounts demanded by customers, distribution strategies, sales figures, the

state of annual talks, single customers, costs, new products, R&D, etc.

2. Dealings with Customers

Customers must remain free to fix their resale prices. Resale prices may not be agreed or

coordinated with customers, neither directly nor indirectly.

Nonbinding price recommendations are, however, allowed in principle. Price recommenda-

tions may, however, not be enforced through the exertion of pressure or the granting of

incentives.

The freedom of customers to export or import products of any Company of the Group of

Companies may not be restricted in a legally inadmissible manner. Export or import

restrictions may not be enforced through the exertion of pressure or the granting of

incentives.

3. No abuse of a dominant position in the market

If the Company holds a dominant position in any product market, increased antitrust

requirements apply. An abuse of market power may, for instance, exist in case of exclusive

distribution arrangements with customers, fidelity rebates or market share rebates, tie-in

transactions or refusals to supply without factual justification.

4. Registration of corporate acquisitions and company divestitures

As a rule, divestitures of businesses, corporate acquisitions or joint venture projects are

subject to merger control and thus need to be registered with the competent domestic and

foreign competition authorities prior to their execution. Within the scope of these permit

procedures, comprehensive information must be provided to the authorities. It must be

truthful and complete.

5. Obtaining legal advice in antitrust issues early

In all cases of doubt arising in the field of Antitrust Law, the respective executive, the legal

department or the Compliance Officer must be contacted at an early stage. The Company

will provide information on any details by means of separate rules of conduct and information

letters.

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IV. No violations of anti-corruption laws

In most countries, not only the corruption of office-holders and public administration

employees, but also commercial bribery is punishable both for the grantor and the acceptor

of the advantage. On the ground of numerous international anti-corruption conventions, rules

globally apply that are similarly stringent as those applied in Germany. In many countries,

such as Germany or the USA, corruption committed abroad is also punishable under

domestic law.

1. Offering and granting of advantages

In connection with their business activity, Staff Members may neither offer nor grant to

employees of business partners any unjustified personal advantages. Usual and appropriate

occasional gifts, advertising gifts of small value and invitations to business partners, which do

not aim at influencing business decisions in a dishonest manner, are exclusively admissible.

Gifts and invitations must be in accordance with courtesy and usual social practice and may

not be objectively suitable for an inappropriate influencing of business decisions according to

the circumstances of any individual case, the positions and personal circumstances of the

parties involved and the value of the gift. Any appearance of dishonesty or inappropriate

considerations must be strictly avoided.

Gifts or invitations may never be offered as incentives for conclusions of transactions or

additional orders. Even promising personal advantages (“incentives”) is punishable!

No gifts may be granted if a customer prohibits a granting of personal gifts to their staff.

Offering money or vouchers (e.g. gas vouchers or phone cards) is prohibited!

The following applies at all times: If a conduct as set out above is observed with any

competitor, this is no justification for own misconduct. In order to oppose such business

practices, the Staff Members should inform their supervisors and the legal department in

charge.

2. Demanding or accepting advantages

In connection with their official duties, Staff Members may not demand or accept any

unjustified advantages. The prohibition applies unrestrictedly to demanding advantages.

Usual and appropriate occasional gifts, advertising gifts of small value and invitations to

business partners, which do not aim at influencing business decisions in a dishonest manner,

are exclusively admissible.

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The following also applies in this connection: gifts and invitations must be in accordance with

courtesy and usual social practice and may not be objectively suitable for an inappropriate

influencing of business decisions according to the circumstances of any individual case, the

positions and personal circumstances of the parties involved and the value of the gift. Any

appearance of dishonesty or inappropriate considerations must be strictly avoided.

Demanding or accepting money or vouchers (e.g. gas vouchers or phone cards) is

prohibited.

3. Conduct vis-à-vis office-holders

In relation to domestic and foreign public servants, civil servants or government employees,

almost every offering or granting of advantages constitutes a criminal offense. In order to

protect public confidence in the fairness of public service, more stringent measures apply in

this respect.

Not only personal gifts in connection with illegal official acts (“bribery”) are punishable in

particular, but also personal gifts granted for the legal discharge of duty (“conferring a

benefit”). In order to definitely rule out criminal liability, personal gifts to public servants shall

be completely avoided.

The prohibitions of corruption are not restricted to public servants, but also apply to

individuals who, in the broadest sense, are entrusted with sovereign tasks.

The Company provides information on details relating to issues of the anti-corruption Laws

by means of separate rules of conduct and information letters.

V. Money laundering

No Staff Member, either alone or in collaboration with third parties, may take measures that

violate domestic or foreign regulations on money laundering. “Money laundering” means in

particular the introduction – e.g. by conversion or transfer – into the regular economic cycle

of money or other assets originating directly or indirectly from a criminal offense. In cases of

doubt about the permissibility of financial transactions, the Staff Members shall make

inquiries, for instance, if, in connection with a cross-border transaction, payments are to be

made on a third-country account. Accepting cash is prohibited, if it is not a customary

business practice.

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VI. Foreign trade provisions

The Company complies with all foreign trade provisions applicable in the respective countries

where it pursues its business activities, e.g. export control and customs provisions,

provisions pertaining to the suppression of terrorism or to the use of dual-use products.

Foreign trade provisions might prohibit or restrict the export, import or domestic trading of

goods, services or technologies as well as capital and payment transactions. The

prohibitions and restrictions may be due to the nature of the goods, the country of origin

and/or use or the person of the business partner.

VII. Protection of research and technical development

The Company protects its own advance in knowledge and respects the rights of third parties.

The results of our research and our technical development constitute valuable assets. Not

only decisions of significant economic importance are based thereon. The safety and the well

being of our Staff Members, customers and fellow citizens might depend hereon. Our R&D

staff and the technicians are thus obligated to elaborate, document and communicate the

results of their activities in accordance with valid scientific and technical standards.

Inventions, patents and other know-how secure the future and are thus of outstanding value.

Utmost care shall thus be taken over the corresponding legal protection of the inventions. No

Staff Member may pass on new findings or trade secrets in any form to any uninvolved Staff

Members or any third parties. Procedures, formulas and techniques must be treated as

strictly confidential under any circumstances unless they are in the public domain. All

agreements with third parties which deal with the granting of licenses or the transfer of know-

how must have been reviewed by the department in charge prior to their signing. Each Staff

Member must respect protected privileges of third parties and must refrain from their

unapproved use.

The protection of product names as well as any other industrial property rights is of vital

importance in many divisions of the Company. For this reason, a secured legal foundation

must be created for product names and industrial property rights prior to their use by the

Company by means of their registration within the country and abroad.

VIII. Separation of private and corporate interests

The personal interests of the Staff Members and the interests of the Company must be

strictly separated. Staff Members of the Company are obligated to make their business

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decisions in the best interest of the Company and unaffected by personal interests. A conflict

of interests exists if a corporate decision might conflict with any personal interests of an

occupational, financial or private nature. Sidelines for competitors, customers or suppliers or

the awarding of contracts to related parties or companies in which a Staff Member or a party

related to him or her has an interest serve, for instance, as examples for conflicts of interest.

Each Staff Member must separate his or her own personal interests from those of the

Company. Therefore, each personal interest which a Staff Member might have in connection

with the performance of his or her duties needs to be notified to his or her supervisor without

delay. This also applies, if the Staff Member is convinced that he or she might disregard own

interests and acts solely in the interest of the Company as even the mere impression that a

Staff Member might have considered own personal interests in a decision-making process

must absolutely be avoided. In cases of doubt, the supervisor shall delegate the matter to

another Staff Member.

As regards business relationships with third parties, objective criteria are all that counts.

Suppliers are chosen in accordance with appropriate criteria, such as price, quality, reliability,

technological standard, product suitability, existence of a long-standing and trouble-free

business relationship and existence of quality management. The conclusion of a contract

must not be influenced by personal relationships or interests. Business opportunities that are

due to the Company must not be used for own purposes. Personnel decisions must not be

influenced by private interests or relationships either.

No Staff Member may make use of internal knowledge on any projects of the Company –

such as the intended sale of parts of the Company, the acquisition of third-party companies,

the establishment of joint ventures or any other facts relevant to the Company – to his or her

advantage or to the advantage of a third party, either directly or by the involvement of a third

party. No Staff Member may disclose corresponding knowledge to any parties not involved in

the concrete project or to any third parties.

Any outside employment of a Staff Member may neither impair his or her main employment

nor lead the Staff Member into a conflict of interests. This applies in particular to positions

with companies that already do business or compete with the Oetker Group.

Interests of Staff Members or of any parties related to them in companies which do business

or compete with any Company of the Oetker Group must be notified in writing. Following the

notification of interest, the Company may take appropriate measures for a removal of a

possible conflict of interests. A duty to notify does not exist, if, due to the interest, there exists

no possibility to influence the management of the Company, for instance, in case of interests

in listed companies, which amount to less than 5% or in case of mere investments made to a

negligible extent.

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However, the Company welcomes a private involvement in clubs and societies, political

parties or any other social or political institutions as long as the voluntary involvement in such

organizations does not interfere with the performance of the Staff Members’ duties or

conflicts with justified interests of the Company. When expressing their personal opinions in

public, Staff Members must not give the impression that these opinions represent the views

of the Company.

Donations of the Company must exclusively be caused by the executive management und

must be made in compliance with the legal system. Staff Members may not donate any

monies, physical assets or services of the Company to political parties or candidates for or

within public offices.

IX. Use of Company property

Each Staff Member is obligated to use the property of the Company in a careful and

responsible manner und to use corporate property solely for admissible business purposes.

Corporate property must be protected from loss, theft or abuse. Unless for business

purposes, property of the Company may not be removed from the Company premises

without the supervisor’s permission for official purposes. Data stocks, programs or company

papers may not be copied or removed from the Company’s premises without approval.

When using equipment and resources of the Company (inter alia, telephone, computer,

internet and other information technology), the internal guidelines and other rules of the

Company must be observed. Any use for private purposes is only admissible to the extent

this is allowed by the guidelines and rules mentioned.

X. Secrecy/Protection of business secrets

The Staff Members are required to maintain secrecy with respect to all trade and business

secrets, other internal confidential matters of the Company as well as with respect to all

confidential information provided by or on our customers and other business partners. All

information is deemed confidential that is designated as such or with reference to which it is

to be assumed that it is not and shall not be in the public domain, for instance, as it could be

useful for competitors, or whose disclosure could be detrimental to the Company or its

business partners. Confidential information, inter alia, includes data relating to Staff

Members, customers or suppliers, plans for new products, production processes, financial

data, corporate acquisitions or divestitures. The duty to observe secrecy exists both for the

duration of the employment and beyond its termination.

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Confidential information must be protected from any unauthorized inspection by third parties.

Also in intercompany dealings it must be ensured that confidential information may only be

passed on to Staff Members who require such confidential information for the performance of

their duties.

XI. Data protection and data security

All Staff Members are obligated to treat personal data (e.g. name, address, telephone

number, date of birth of Staff Members, customers and others) as strictly confidential and

with utmost care and, in doing so, are obligated to comply with the data protection provisions

both in electronic data traffic and otherwise. Personal data may only be collected, stored,

processed or used in so far as is admissible, i.e. required for specified, explicit and legitimate

purposes. In cases of doubt the corporate Data Protection Officer is to be involved. Personal

data must be protected from unauthorized inspection or access. A high standard must be

guaranteed in the implementation of the technical protection from unauthorized access. The

respective national statutory provisions must be complied with.

XII. Documentation of business transactions

All business transactions must be documented completely and properly in accordance with

applicable statutory provisions, and beyond, in accordance with the provisions applicable at

Oetker. The generally accepted accounting principles must be complied with; accordingly,

data collections and other recordings must always be complete and correct and must be

carried out promptly and in a system-compliant manner. The preservation periods for

documents must be observed.

XIII. Handling of files and recordings

All documents and data carriers belonging to a workplace may not fall into the hands of

unauthorized persons und must be kept under lock and key in principle. Computers must be

protected in accordance with the safety provisions of the Company, for instance, by awarding

passwords and their frequent change. It must be ensured that no third party might access

data stocks even in case of a longer absence from work. Staff Members may solely make

copies of business records or files of the Company for official purposes.

Apart from cases of substitution and from the respective supervisor, there exists no right of

access to information that does not affect the respective Staff Member’s own activity. Each

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deliberate unofficial taking of notice of any communication addressed to third parties is thus

inadmissible.

Each Staff Member must always consider carefully what is to be communicated via

documents and in e-mails. Any correspondence containing improper statements or which

might give the appearance of inappropriate or illegal conduct must be avoided.

All recordings and files must be kept in such a way as to permit delegation to a colleague at

any time. Therefore, files must, inter alia, be complete, orderly and readily understandable.

XIV. Dealings among Staff Members

Each Staff Member must know that his or her conduct is also attributed to the Company and

thus characterizes the Company’s outward and inward reputation. The Company thus

expects each Staff Member to be friendly, objective and fair in his or her dealings with

colleagues.

No person is to be disadvantaged, favored, harassed or ostracized because of race or

ethnicity, gender, religion or ideology, disablement, age, sexual orientation or appearance. A

differential treatment for legally justified reasons remains unaffected.

Sexual harassment is prohibited. Each Staff Member is entitled to protection from acts of

harassment.

First and foremost, the dealings of all Staff Members must be done with confidence.

Communication is the basis of preparing decisions. Each Staff Member must be willing to

contribute the highest possible degree of own expertise as well as expertise of other

departments to a decision-making process. In addition to teamwork skills, one own’s initiative

belongs to successful project work.

XV. Protection of the environment

The Company endeavors to handle environmental resources as sparingly as possible, to

avoid hazards to humans and the environment and to continuously improve all procedures

and processes that serve to further reduce environmental pollution. All Staff Members are

committed to this target.

Each Staff Member is jointly responsible for the protection of humans and the environment in

his or her working environment. All Laws and regulations pertaining to environmental

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protection and plant safety must be strictly observed. Each supervisor is obligated to instruct,

supervise and support his or her staff in taking responsibility.

In dealing with primary or end products that might be harmful to the environment, e.g. their

transport, loading and unloading, storage or chemical conversion, environmental and

occupational safety must be preserved.

Waste disposal must be effected in accordance with statutory provisions. Where third parties

are involved for such purpose, it must be ensured and documented that they comply with the

relevant statutory provisions and other requirements of the Company as well.

In general, no commercial usage of air, water or soil may take place without a permit. The

construction and operation of production facilities as well as their change or expansion also

require a permit in principle. The unauthorized operation, each deliberate or merely accepted

exceeding of the limits set in a permit for the plant operation or the unauthorized discharge of

substances that are detrimental to the environment into the water exposes the responsible

parties to the risk of criminal prosecution. In addition, damage claims of third parties may

lead to a financial burden of the Company. Each unauthorized release of substances must

thus be avoided.

XIV. Work safety

Each Staff Member is obligated in his or her best interest, but also in the best interest of his

or her colleagues and the entire Company to apply all employment protection and work

safety provisions consistently. The existence of and compliance with appropriate procedures

and protective measures for the warranty of safety and health at work must be ensured.

Each supervisor is obligated to instruct, supervise and support his or her staff in taking

responsibility.

XVII. Conduct vis-à-vis authorities

The Company endeavors to cultivate a cooperative relationship with all competent authorities

that shall be characterized by openness.

In this respect, it may not be underestimated that it is the duty of several authorities to punish

violations of applicable Law. Such procedures are effected in accordance with certain rules.

These rules also include the right of the affected parties for legal assistance. The protection

of this right and the use of the “privilege of silence” are not deemed to be an admission of

guilt. Information shall only be provided and files shall only be presented after consultation of

the legal department in charge and/or an external legal adviser.

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In case of hearings, interrogations or searches by investigating agencies, it is up to the Staff

Members of the legal departments in charge to ensure protection of the rights of the affected

persons. All Staff Members who are responsible for the compilation and transmission of

corporate information to any agencies will provide this information completely, openly,

correctly, duly and in a readily understandable form.

XVIII. Compliance with the Oetker Code of Conduct

1. Compliance organization

Dr. August Oetker KG establishes a compliance organization for the Oetker Group which

shall ensure the implementation of this Code of Conduct. Two Compliance Officers are

appointed who shall be in charge of the Oetker Group and responsible for the further

development of the Oetker Code of Conduct and the organizational implementation. One

Compliance Officer will be appointed for each Company managing the divisions of the Oetker

Group and for further individual subsidiaries. In all other subsidiaries, a Staff Member shall

assume the function of Compliance Officer. The corporate audit department of the Group

shall verify the implementation and adherence to the Oetker Code of Conduct in regular

intervals.

2. Questions on the Code of Conduct, contact persons

This Code of Conduct can certainly not cover all conceivable situations. In cases of

uncertainty arising with respect to proper conduct, each Staff Member is expected to seek

advice before he or she takes a measure which might lead to a violation of applicable Law or

of internal guidelines. As a rule, violations of the Law can be avoided by preventive advice.

The respective supervisor, the departments in charge (e.g. the human resources department,

the works manager, the legal department, etc.), the Compliance Officer or the otherwise

designated contact person of the respective subsidiary or the Group Compliance Officers are

available. In general, Staff Members might contact their supervisors in case of any questions

that might arise in connection with the Code of Conduct through ordinary official channels as

the latter knows the sphere of responsibility best. Where questions arise with reference to a

specific field, the respective specialist departments will be able to provide assistance. Legal

questions might be addressed to the legal department in charge.

You may also turn to any of the Group Compliance Officers at any time who are available as

neutral and independent contact persons.

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3. Complaints and indications

If any Staff Member takes notice of a significant violation of any Laws or the rules set out in

this Code of Conduct, he or she has the opportunity to inform his or her supervisor as well as

the corporate audit department or the Compliance Officer or any other designated contact

persons of the respective Company.

In addition, all Staff Members have the opportunity, at any time, to report any indications of

misconduct (e.g. criminal offenses) or dubious or legally doubtful occurrences in their

working environment to the Group Compliance Officers. This also applies in particular to the

reporting of facts that violate this Code of Conduct.

It is warranted that all occurrences reported to the Compliance Officers are inspected and

settled properly (with the help of other specialist departments, where required). Violations of

this Code of Conduct are investigated by the corporate audit department. To the extent

required, action will be taken after a careful inspection of the facts.

If the person giving the information assumes that he or she might incur any personal

disadvantage due to the notification, notifications can also be made confidentially and

anonymously, that is, without giving the name.

The general partners of Dr. August Oetker KG warrant that no detriment or any other

disadvantage arise to Staff Members who make use of the hotline to the best of their

knowledge and in good faith.

4. Consequences of violations

A violation of the Oetker Code of Conduct, any other Oetker guidelines or of applicable Laws

may lead to disciplinary action, a termination of employment and other legal action.

5. Revision of the Oetker Code of Conduct

Legal provisions and rules of conduct might change. A regular revision of the Oetker Code of

Conduct is thus provided. All Staff Members are requested to participate in the further

development of the Code of Conduct.