Sara Lee is made up of thousands of people, each with unique values and aspirations. One of the values we share is to act with integrity. We want to be proud of the work we do and the lives we lead. Integrity is at the heart of who we are. Integrity is at the heart of Sara Lee as well. Without integrity we would fail in the marketplace, with investors, and in our own eyes.




Each Sara Lee employee is responsible for acting with integrity. Business integrity is hard to define, but everybody knows it when they see it and everyone feels the consequences when it goes missing. Among other things, it means honesty, and obeying the law. It means treating those with whom we work with fairness and respect. And it means being accountable and taking personal responsibility for our actions and their consequences.

It also is the responsibility of each Sara Lee employee to comply with the Global Business Standards, and to take action or report to management when aware of criminal acts or violations of the Standards. This includes situations where a manager or colleague asks or otherwise induces an employee to violate the Global Business Standards. Employees who fail to comply with the Standards, including not reporting known unethical activities, will be subject to disciplinary action.

Individuals who report an ethical or legal concern in good faith will never be subject to retaliation for reporting. All allegations of retaliation will be investigated, and any employee responsible for retaliation will be subject to disciplinary action. Additionally, employees who knowingly submit false reports also will be subject to disciplinary action.




Managers are expected to exemplify the highest standards of ethical and responsible business conduct and to encourage discussion of the ethical and legal implications of business decisions. Managers have a responsibility to create and sustain a work environment in which employees, consultants and contract workers know that ethical and legal behavior is expected of them.

This responsibility includes ensuring that the Global Business Standards are communicated to all those working for the manager. Sara Lee’s performance management process provides a perfect example of an opportunity to communicate expectations. Managers also are responsible for ensuring that employees who need to know additional information in order to do their jobs, for example regarding the environment, safety, responsible sourcing, antitrust or international business practices, receive appropriate policies and training.

Managers must be diligent in looking for indications that unethical or illegal conduct is being considered or has occurred, and take appropriate and consistent action to address any situations that seem to be in confl ict with the law or the Global Business Standards. Managers are responsible and accountable for exercising appropriate oversight of employee behavior. Managers also need to be careful not to hire or delegate authority to any individual who they have reason to believe may engage in unlawful conduct or unethical activities.