LIVINGOUR VALUESThe Ingredion Incorporated Code of Conduct

Question or Concern? Visit the Business Ethics Line at INGRethics.com
INTRODUCTION

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1A MESSAGE
FROM THE CEO

Our company values are our beacon. They guide our everyday actions
at work and help us ensure we deliver on our core purpose. Our unique
combination of values and purpose differentiates us from every othercompany – it’s who we are. As such, we are all expected to live by ourvalues, and this Code of Conduct document helps us understand thefiner points of doing this.
While this guide is comprehensive, it cannot address every situation you
may encounter at Ingredion. It’s important to read through the document
and understand not only the words, but the intent behind the words.
This will help guide you in situations not explicitly covered here.
When in doubt about the nature of any action covered here, speak up.
Ask your manager or HR representative, or simply contact the Ingredion
Business Ethics Line. We assume that any report of a possible ethics
breach is made in the best interests of the company, and we do nottolerate retaliation of any kind for someone reporting a possible breach.
I thank you for all you do every day to adhere to our Code of Conduct
by living our values. When we follow this beacon, we are doing the rightthing for the company and for our future growth together.
Sincerely,
James P. Zallie
President and Chief Executive Officer

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2OUR VALUESOUR PURPOSE

Care FirstWe actively work to safeguard and enable the wellbeingof our people, the quality of our products, and our reputation
for trust and integrity.

Be Preferred

We earn the right to be customer-preferred by delivering
mutual enduring value at every touchpoint of the customer
experience.

Everyone Belongs

We embrace diversity and proactively foster an inclusive work
environment where each person is valued and feels inspired
to contribute their best.

Innovate Boldly

We courageously strive for breakthrough innovations
driven by our relentless curiosity, bold thinking, speedof decision-making, and agile execution.

Owner’s Mindset

We think and act like owners—where everyone takes personal
responsibility to anticipate challenges, proactively searchfor opportunities, and make decisions that are in the bestinterest of the company.

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OWNER’S MINDSETOUR STANDARDS

3CONTENTS

Living our Values: An Introduction to Ingredion’s Code of Conduct
Why We Have a Code
Who Is Covered Under the Code
What You Need to Do
Reporting Concerns
Non-Retaliation Policy

Care First

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Quality and Food Safety
Environment, Health, Safety, and Security
Human Rights
Sustainability
Privacy and Protection of Personal Information
Anti-Bribery and Corruption

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10
11
12
13
14

Be Preferred

16Competing Fairly
Gifts and Entertainment
Conflicts of Interest
Political Activity and Contributions
International Trade Compliance

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20
21

Everyone Belongs

22

Diversity and Inclusion
Harassment and Discrimination
Anti-Violence, Threats, and Intimidation

23
24
25

Innovate Boldly

26Intellectual Property and Company Assets
Email, Internet, and Information Systems

27
28

Owner’s Mindset

29

Accuracy of Books and Records
Insider Trading
External Communication and Social Media
Confidential Information

30
31
32
33

We consistently demonstrate integrity and high ethical standards
Our Code of Conduct
Compliance with Policies, Laws, and Regulations
Business Integrity, Ethics, and Compliance Program

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35
35
35

Contacts

INTRODUCTION

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4LIVING OUR VALUES:An Introduction toIngredion’s Code of Conduct

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Question or Concern? Visit the Business Ethics Line at INGRethics.com

Why We Have a Code

What You Need to Do

At Ingredion, we believe that our values define who
we are as an organization and how we do business.
Our values strengthen our organization and shape ourculture. We are committed to living our values: doing
the right thing the right way, every day.

If you are not sure if a particular action is the rightthing to do, ask yourself:

Our Code explains the company’s expectations fordoing business ethically and consistently according
to our values, our policies, and the law.

Who Is Covered Under the Code
Our Code applies to everyone at Ingredion and its
affiliates around the world, including employees,
contract workers, agents, company officers, anddirectors. In some cases, the Code applies to third
parties and others working on the company’s behalf.

• Is it legal?
• Is it consistent with our Code of Conduct?

• set a positive example of ethical businessconduct;• Does it follow our policies?

• promote the Code and the company’s values;• Does it benefit the company as a whole,
not just personal interests?

• help their team members comply with the letterand spirit of the Code;• Would you be comfortable if the action
were made public?

• create an open culture that encourages people
to speak up; andIf you answered yes to all of these questions, then theaction is probably okay. If you answered no to anyof these or if you are not sure, stop and get advice:• discuss the issue with your manager;• discuss the issue with another manager;• contact the Human Resources, Legal, or Regionalor Corporate Compliance department; or• use the Business Ethics Line, to report concerns
or ask questions (anonymously if you wish) inyour language.

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While we are all responsible for following the Code,managers have a special responsibility to ensurethat Ingredion’s Code of Conduct is followed.
Managers must:

EVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSET• escalate any breach of this Code to the local
Compliance team or Legal team, rather thandealing with the issue personally.
Behavior inconsistent with the company’s ethicalexpectations and the Code of Conduct can result inserious consequences for Ingredion and for anyone
covered under the Code. For the company, it could
mean fines, investigations, and reputational damage.
For individuals, it could lead to disciplinary or legal actionand even termination of employment. Everyone covered
under the Code is expected to comply with it and to fully
cooperate with investigations conducted by the company.

OUR STANDARDS

6

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Reporting Concerns

Non-Retaliation PolicyYour voice matters. Each of us is responsible forbuilding and protecting Ingredion’s culture of integrity.
A suspected violation of this Code of Conduct,
company policy, or violation of law could be a serious
matter. We expect everyone to speak up about any
potential violations.

Ingredion does not tolerate retaliation for asking
questions or raising good-faith concerns of possible
violations of the Code of Conduct. Concerns are taken
very seriously and we review all reports and investigate
possible violations, including failure to speak up. For
more information about Ingredion’s commitment
to non-retaliation, refer to the Speaking Up/NonRetaliation policy. Unless we are required to makedisclosures by law, all reports and investigations are
kept confidential.

The company does not tolerate retaliation against
those who speak up in good faith or participate
in investigations.
If you have a question about this Code or if you
are concerned about a potential violation, you havea number of options:• discuss the issue with your manager;• discuss the issue with another manager;• contact the Human Resources, Legal, or Regionalor Corporate Compliance department; and• use the Business Ethics Line, to report concerns
or ask questions (anonymously, if you wish) inyour language.
Go to INGRethics.com to contact the Business Ethics
Line via the internet or to look up toll-free numbers
by country on Ingredion’s InSite intranet site. The site
is available 24 hours a day, 7 days a week.

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Care FirstWe actively work to safeguard and enable the wellbeing of our people,
the quality of our products, and our reputation for trust and integrity.
IN THIS SECTION:
Quality and Food Safety
Environment, Health, Safety, and Security
Human Rights
Sustainability
Privacy and Protection of Personal Information
Anti-Bribery and Corruption

Question or Concern? Visit the Business Ethics Line at INGRethics.com

CARE FIRST

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Quality and Food Safety
We provide products and services that fulfill our customers’
requirements and meet applicable governmental requirements.

Living our Values
We are committed to providing safe and high-quality products,
services, and solutions, and need to be constantly up-to-date about
customers’ desires and needs. We actively look to obtain and thenlisten to customer feedback.
If our job duties involve any aspect of developing, handling,
packaging, or storing Ingredion products, we must:• know the applicable quality standards, policies, andprocedures that apply to the products at the applicablemanufacturing location;• follow good manufacturing practices and testing protocols; and• comply with all applicable Ingredion manufacturing safety
policies, and all applicable laws and regulations, such as thoserelating to safety and quality.

INTRODUCTION

CARE FIRSTBE PREFERREDEVERYONE BELONGSOur Values in Action
Q: As an operator, you discover that there
is a possibility that small metal pieces
might contaminate a product, which isintended to be food grade. You believethat our procedures for screening
processes are such that it is unlikely that
product contaminated with metal would
be delivered to a customer, however,
you know that some of the company’s
customers do not have adequate means
to screen for metal if contaminatedproduct were delivered. Do you shut
down the equipment causing the possible
contamination, even if it means a slightdecrease in production?
A: Yes. We never compromise quality or foodsafety, and immediately report (throughthe appropriate channels) any concerns
about product safety or quality. Rememberthat this reporting will be confidential
information about Ingredion. Contact yourlocal Quality Management representative
to discuss your concerns regarding productsafety and quality.

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9CARE FIRST

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Environment, Health, Safety, and Security
We strive to protect the environment and are committed to providing our employeeswith a safe and secure workplace. We strive for zero injuries and strive to be a global
leader in workplace safety.

Living our Values
Environmental stewardship, workplace safety, and security are integral partsof our culture. Our commitment includes:• acting in compliance with the environmental laws and regulations in the
countries in which we operate;• following the environmental and safety policies, practices, and procedures
applicable to our workplaces;• taking a proactive approach to environmental challenges by continuously
seeking ways to protect natural resources, reduce our environmental impact,
go beyond compliance, and create efficiencies while upholding product safety
and quality standards;• promoting dialog and innovation to improve workplace safety;• reporting and correcting unsafe or unhealthy conditions or behaviors, as wellas incidents that may lead to spills, releases, or environmental non-compliance;• not using or possessing illegal drugs or controlled substances or working under
the influence of drugs or alcohol in the workplace or while we are engaged
in any job-related activity.

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10CARE FIRST

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Human Rights
We respect the rights of workers throughout our supply chain, including contractors
and suppliers.

Living our Values
We recognize the rights of our employees and those with whom we do business tobe treated with dignity and respect, and in accordance with applicable laws. We expect
our business partners to do the same. We will not tolerate the exploitation of children
or the use of forced labor or human trafficking. Our respect for human rights means:• upholding the United Nations Guiding Principles on Business and Human Rights;• performing appropriate due diligence on potential business partners;• following our procurement policies when selecting new suppliers;• respecting employees’ rights to organize and bargain collectively;• paying fairly in the market and meeting or exceeding all legal requirements related
to employee pay and benefits.
Ingredion’s supplier partners must ensure that their workforces are free from child laborand any forms of forced labor, including slave, indentured, bonded, prison labor, or any
form of human trafficking.

Our Values in Action
Q: O ur due diligence on a supplier’s farm reveals that the farmer is paying less thanthe legal minimum wage. What should we do?
A: C ontact the head of Corporate Sustainability. This farmer must pay the workers
at least the minimum wage for each hour worked.

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CARE FIRST

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Sustainability
We strive to be an exemplary corporate citizen andcommunity member and we work to make a positive,
lasting impact on the communities where we workand live.
We operate with care and respect for the planet, ouremployees, and the communities in which we operate.
We believe in creating a better, more sustainablebusiness while delivering shared value to ourstakeholders. And we believe in conducting business
today in a way that protects our ability to continue
to do business in the future.

Living our Values
We are committed to promoting sustainable practices
throughout our organization and adhering to highmoral and ethical standards wherever we do business.
From our high safety standards to our investments
in operational excellence,
to our efforts in environmental conservation, and ourcommunity stewardship activities,
we believe that operating in a sustainable manner
benefits more than our business; it benefits thecommunities where we operate.

Our Values in Action
Agricultural Sustainability:
Ingredion believes in supporting the long-termsustainability of the agricultural and farming
operations that provide us with raw materials.
To that end, we seek to:• promote safety in the production, storage, handling,
and delivery of crops among the farmers who supply
our raw materials;• recognizing that water is a significant, key raw material
in our processes and may compete with other needs
in water-scarce regions;• encourage the efficient use of natural resources infarming and related activities to minimize potential
environmental impact, reduce impact to water, andsupport the viability of agriculture and biodiversity
for generations to come;• setting goals to reduce the water and CO2 intensities
across our operations;• support the use of approved biotechnology (which
may differ from country to country), and understandconsumer preferences with respect to geneticallymodified organisms;• utilizing the United Nations Development Programme
Sustainable Development Goals as a benchmark tobetter align our sustainability efforts with the greater
needs of society;• oppose the use of child and forced labor acting inaccordance with local laws and globally accepted
standards;• designing and operating environmentally-soundsupply chains as appropriate and working with our
suppliers to educate and improve sustainability acrossour supply chain;• promote the responsible treatment of migrant workers
doing business with our agricultural suppliers;• practice fair and ethical trading practices to promote
the economic well-being of the communities in which
we do business; and• support reduction of pesticide use and promote
integrated pest management.

INTRODUCTION

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Water Stewardship and Climate-Related Risk:
Ingredion recognizes the rights of all people to cleanwater, and as good stewards of the environment,
we strive to reduce the impacts of our operations
on the climate by:

EVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSET• aligning our global operations with universally
recognized principles on the environment as asignatory to the Global Compact;• procuring sustainably sourced materials in areas
where we have the ability to influence our suppliers;• educating our communities on the importanceof water conservation;• advancing our commitment to continuous
improvement through the exploration of innovative
solutions to reduce the environmental impact of ouroperations, including water conservation and energy
efficiency endeavors.

OUR STANDARDS

12CARE FIRST

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Privacy and Protection of Personal Information
Our Values in Action

We safeguard personal information entrusted to the company.

What is personal information?
Personal information (“PI”) is any data that could potentially identify a specific individual.
PI must be protected until its secure disposal. Examples of PI include contact information,such as residential addresses, phone numbers, or email addresses; government assigned
identification numbers; financial information such as banking details, salaries, and othercompensation information; and employment data, including birth dates.

Living our Values

Q: I believe that one of my colleagues is selling employee
email addresses to a marketing company. What should
I do?
A: Employee email address lists are confidential andmay not be disclosed in this way. Provide all theinformation you have on this issue to your manager,
HR representative, Corporate Compliance, or a memberof the Legal Department.

Personal information entrusted to us can belong to our employees, customers, or outsideorganizations. Keeping personal information secure is critically important to our employees,
our business, and our reputation. Some Ingredion employees work with PI (including
particularly sensitive personal information, such as health information) as a part of their jobs.
If you work with PI, follow the company’s applicable policies regarding the access, transfer,and use of this information. Remember:• follow local data protection and privacy laws;• only access, collect, and use personal information that is necessary for your job and thatyou are authorized to see for legitimate business reasons;• do not keep personal information for longer than required for the business purpose;• disclose personal information only to authorized persons who have a legitimate businessreason to know the information and who are obligated to protect it;• securely store, transmit, and destroy personal information in accordance with applicablepolicies and laws; and• promptly report any actual or suspected unauthorized access, data breach, or other risks
to personal information to the IT department, HR, your local Legal Department, or the
Data Protection Officer in your region, if you have one.

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13CARE FIRST

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Anti-Bribery and Corruption
We win business based on the integrity of ouremployees, products and services, as well as
commercial excellence and the exceptional customer
experience we provide. Ingredion is committed to
fully complying with all applicable anti-money
laundering (AML) and terrorist finance laws, rules
and regulations. We do not seek or maintain businessby trying to corrupt the judgment of our customers
or government officials. This applies equally to otherparties engaged to act on our behalf. We do nottolerate or engage in bribery. That is, we do notexchange payment for government influence orto obtain a commercial advantage.
Most countries have anti-bribery laws that prohibit
bribing a government official. Under some country
laws, such as the UK Bribery Act, bribing anyone else(commercial bribery) is also a crime. In addition, allIngredion employees, regardless of personal locationor place of business, must comply with the U.S. Foreign
Corrupt Practices Act (FCPA) as a result of the parent
company “Ingredion” being based in the U.S. The FCPA
makes bribery of government officials a crime andapplies wherever Ingredion does business.
To comply with anti-bribery laws, do not offer—directly or indirectly—any form of gift, entertainment,
inducement, or anything of value to any government
official or his or her representatives to obtain or retain
business; influence business decisions; or secure an
unfair advantage.

INTRODUCTION

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These prohibitions apply to our business operations,partners, and to anyone acting on our behalf, including
agents, consultants, suppliers, and contractors.
Some government payments are not forbidden. For
example, payments may be made to a government
entity in the normal course of business, to pay taxes orwhen the government entity is a customer or supplier.
However, payment of any kind of bribe or facilitating
payment to a government official in any country is
prohibited. Facilitating payments are discretionary
payments to government officials intended to expedite
or ensure routine actions – such as issuing licenses,
permits, or visas. If you receive a request from agovernment official for a bribe or facilitating payment,
you must decline to make the payment unless you
have a reasonable good-faith belief that failure to makethe payment may subject you or others to physicalharm. You must also report the request for a bribeor facilitating payment promptly and directly to yourmanager, the Legal Department, Corporate ComplianceDepartment, or through the Business Ethics Line.
Note that there are some governmental agencies
with formal provisions for paying a fee, for example,
to expedite permit review. Those transactions, where
payment does not influence the final decision on
the permit and is used to pay for the resources andpersonnel necessary to expedite processing, are notconsidered facilitating payments.

EVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSETWHO IS A GOVERNMENT OFFICIAL?
The FCPA defines foreign official as “any officer or
employee of a foreign government or any department,
agent, or instrumentality thereof.” Government official
includes a person who works for or is an agent of agovernment or government-owned or governmentcontrolled entity. Examples of government officials include:• an officer or employee of a government entity,
department or agency;• an officer or employee of a state-owned business,school, hospital or other entity;• an officer, employee, or official of a political party;• a candidate for political office;• an officer, employee, or official of a public
international organization, or any department
or agency of such organizations (such as the IMF
or World Bank);• a person acting in an official capacity on behalfof a government entity;• an officer or employee of a state-owned orstate-controlled commercial enterprise; or• other persons with government influence, suchas an individual with a close personal or family
relationship with a government official.
As the last item on the list shows, the definition of
government official is not always simply someone holding
the government job.

OUR STANDARDS

14CARE FIRST

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Living our Values
Corruption can take many forms. It is important that our partners and anyone engaged
to act on our behalf are aligned with our standards and expectations and uphold ourcommitment to do business with integrity and in accordance with applicable laws. Whendealing with external organizations, be aware of the warning signs that require further
investigation before hiring or working with someone from outside Ingredion, such as:• refusal to agree to Ingredion global standards or anti-corruption contract provisions;• inconsistencies or misrepresentations in the due diligence process or a reluctanceto cooperate;• requests for unusual payment arrangements, such as payments in cash or payments
to be made to a third-party intermediary (e.g., not to the vendor who is providing
the services);• requests to make charitable donations;

Our Values in Action
Q: It has been suggested that I give a $20 “tip” to an employee of agovernment-owned telephone company to ensure a telephone line isinstalled on time at a company office. Could giving such a small amount,even out of my own pocket, be against the law?
A: Yes. You need to contact your local Legal department, Corporate Compliancedepartment, or the Business Ethics Line. The transaction would beconsidered a facilitating payment, which would be prohibited under our
Ingredion policies, regardless of the amount. Paying from your own funds
on Ingredion’s behalf does not change the nature of the payment. It is abribe. Even if, thoughtlessly, the payment had already been made, it muststill be reported in the company’s accounts.

• recommendation of a party by a government official;• hiring a relative of a government official or even the offer of an internship to the relative;• commission or fees higher than the going rate;• a reputation for questionable business practices;• close social, business, or family ties to a government official.
When selecting and retaining suppliers, always:• follow our applicable bidding, negotiating, and contracting processes;• avoid potential or actual conflicts of interest with suppliers;• include FCPA clauses in all Ingredion supplier contracts;• perform appropriate due diligence to determine whether the supplier is a legitimate
enterprise, has a reputation for integrity and ethical behavior, is connected with anyone
from a government or a government organization, or if the supplier has ever engaged
in unlawful activities.

Q: A local inspector visits an Ingredion plant regularly. Recently, the inspector
stated that he found deficiencies and threatened to shut down the plant
unless the plant manager agreed to make a cash payment to the inspector.
The plant manager is concerned about any disruption to production. Since
the amount requested is small, she thinks it would be okay to make thepayment if it keeps the plant operating. Is she correct?
A: N
 o. The plant manager may think she is helping Ingredion by avoiding
disruption at the plant. However, giving anything of value to the inspector
under these circumstances would be considered a bribe, as the payment
was intended to influence the inspector’s review of the facility. She must notagree to make the payment—and she should contact the Legal Department,
Corporate Compliance, or the Business Ethics Line immediately.

For guidance on supplier due diligence, contact your local Legal contact.

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Be Preferred
We earn the right to be customer-preferred by delivering mutual
enduring value at every touchpoint of the customer experience.

IN THIS SECTION:
Competing Fairly
Gifts and Entertainment
Conflicts of Interest
Political Activity and Contributions
International Trade Compliance

Question or Concern? Visit the Business Ethics Line at INGRethics.com

BE PREFERRED

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Competing Fairly
We believe in competing fairly. In our pursuit to deliver ingredient solutions that enable our customers to create
consumer-preferred, winning products in their local marketplace, we never use illegal or unethical means to obtaina competitive advantage.

Obtaining Competitive Intelligence

Living our Values

Competitive intelligence can be obtained fairly andethically from publicly available sources, such as media
reports, trade journals, annual reports, governmental
filings, speeches of company executives, and from
customers in the context of meeting competitive offers.

We compete vigorously based on the quality of our
products, aiming to meet or exceed our customers’
needs and delivering superior ingredient solutions
that will help our customers succeed. Compete fairly:

Competitive intelligence should never be obtained
through misrepresentation, trespassing, theft, invasionof privacy, or obtaining information from co-workers
about previous employers.
When dealing with competitors, never enter into any
agreement—whether formal or informal, written orverbal—to set prices or other terms of sale; coordinate
bids; allocate customers, sales territories, or productlines; or engage in any other activity that violates
applicable antitrust or competition laws. We neverdiscuss such topics with a competitor, even in an
informal setting such as a trade show or customer
event. If you have any concerns, contact your local
Legal department.

INTRODUCTION

CARE FIRSTBE PREFERRED• do not use illegal or unethical means to obtaincompetitive advantage;• do not agree to fix prices, rig bids, or unlawfully
divide up products, territories, customers ormarkets, or limit production or sale of products;• do not make false, baseless, or misleading
remarks about our company, its competitors
or their products;• do not use information obtained by unfair
or illegal methods;• do not engage a third party to obtain competitive
information that would be unlawful if gathered
directly by Ingredion.

EVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSETOur Values in Action
Q: I have a good friend who works for acompetitor. At a trade show, my friend
proposed a strategy for each of us to increase
sales by dividing territories. Should I go alongwith the plan?
A: N o. Allocating customers or geographic
territories between competitors could bea violation of the law. If a competitor ever
initiates a discussion about allocating
territories, stop the conversation
immediately*. If you are at a trade show andthis type of conversation starts, then end
the conversation immediately. Report any
attempt to discuss anti-competitive behavior
immediately to the Legal department.
*It is appropriate for you to stop theconversation and advise that “we cannot
have this type of discussion, and if it is
not stopped, I will leave now!”OUR STANDARDS17

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Gifts and Entertainment
We are responsible for ensuring that our relationships with customers, suppliers, and other business partners are based on objective decisions and are not influenced by gifts
or entertainment offers. This section also applies to our partners or third parties, working on Ingredion’s behalf.

When is it okay to give or accept meals,
entertainment, or gifts?
A gift is GENERALLYALLOWED as long as it:

A gift is GENERALLYPROHIBITED if it:• Does not violate local law or
the recipient’s businessstandards;• Is illegal;• Does not make the recipient
feel obligated or give theappearance of an obligation;• Is not solicited;• Is infrequent;• Does not exceed generally
accepted local businesspractices;• Is a reasonable complement
to the business relationship;• Is consistent with
Ingredion’s Code of
Conduct; and• Is accurately reflected in theemployee’s expense reportand on Ingredion’s books
and records.

• Could cause—or give theappearance of causing—an employee to grant or
receive any favor in return;• Is extravagant under thecircumstances;• Coincides with purchasingor sales decisions, sincethese could appear to
improperly influence thedecisions;• Involves giving or
accepting cash or cash
equivalents such as giftcards, gift certificates,or vouchers withdenominated spending
amounts;• Is unsavory, sexuallyoriented, or offensive.

Do NOT in any event request or solicit (or expect) gifts, favors,
or entertainment, from any Ingredion business partner. Keep inmind that special rules apply when interacting with government
officials.

INTRODUCTIONGIFTS AND ENTERTAINMENTTO GOVERNMENT OFFICIALSCARE FIRSTBE PREFERRED

Giving or offering even a simple gift or meal to a government official (or someone with a close personalor family relationship with a government official) may violate local and U.S. law (and, if you are not locatedin the U.S., the applicable laws of the country in which your business is located, as well). Contact theLegal Department or Corporate or local Compliance Department before giving or offering any gift, mealor entertainment to a government official (or someone with a close personal or family relationship witha government official)—and also before you agree to receive a gift.

LOANS
Executive officers, directors, and employees may not receive loans from or have obligations guaranteedby the company, except as expressly authorized by company policy.

Our Values in Action
Q: I am part of a team working on a renewal contract with a current supplier. During negotiations, the supplieroffered four tickets to a regular season ballgame. While the individual tickets were not very expensive, theirvalue was more than what would be considered a modest amount in my location. Also, because of the teams
playing, the tickets are hard to get. Given the situation, I notified my manager. We decided that it was best to
not to accept the tickets. Did we do the right thing?
A: Yes. Seeking guidance from your manager before accepting this gift, which is of more than modest value, wasthe right approach to the situation. Given the circumstances, the supplier’s offer could be viewed as an attempt
to influence the outcome of the renewal of the contract.

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BE PREFERRED

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Conflicts of Interest
We act in the best interest of Ingredion and do not allow our business decisions to be influenced, or appear to be
influenced, by personal or family interests or friendships, or other connections we may have.

What is a conflict of interest?
A conflict of interest arises any time a personal or private interest interferes with, or gives the appearance of interfering
with, work being performed fairly and ethically without bias or undue influence. Some instances are obvious, such as
having a close relative as a manager or serving as a director on the board of a competitor.
Conflicts can arise in many situations, and our Code cannot possibly address all of them. When in doubt, contact yourmanager, Legal, Corporate Compliance, Local Compliance Committee, Human Resources, or the Business Ethics Line
before taking any action.
Remember, having a conflict of interest is not necessarily a violation of our Code of Conduct, but failing to disclose it is.

Living our Values
Conflicts of interest can negatively affect Ingredion’s reputation and business, and can have negative consequences
for individuals as well. To help avoid the negative consequences of conflicts of interest:• never let our business decisions be influenced,
or appear to be influenced, by personal or familyinterests or friendships;• avoid any situation that looks like it could affectyour judgment;• never solicit or accept anything of value that may
be perceived as a means to unduly influencebusiness judgment;• award business solely on merit in order to obtain
the best products and services at the best prices
and terms;

INTRODUCTION

CARE FIRSTBE PREFERRED

Our Values in Action
Q: Don works in corn procurement. He wasrecently transferred to a plant near his
hometown and promoted to manager. His
uncles own farmland nearby, and he haslearned that they occasionally sell corn
to Ingredion. Don is concerned that thesetransactions could create or appear to create
a conflict of interest with his new role.
Should Don disclose the potential conflict?
A: Yes. Don has a valid concern and should bring
the situation to the attention of his manager,
the Legal Department or local Compliance
Committee. After disclosure, the company canreview the situation and determine whether it
in fact poses a conflict of interest.

• always make decisions related to Ingredion basedon the company’s objectives and priorities;• never pursue any business opportunity wediscover through our work with Ingredion for
personal gain or the gain of any entity otherthan Ingredion; and• promptly disclose potential conflicts of interestby contacting a manager, Legal, Corporate
Compliance, Human Resources, or the Business
Ethics Line.

EVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSETOUR STANDARDS19

BE PREFERRED

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Political Activity and Contributions
We comply with all applicable laws regarding political activities and disclosure requirements.

LOBBYINGPERSONAL POLITICAL ACTIVITIES AND CONTRIBUTIONS

Lobbying is an attempt to influence the actions, policies, or decisions of officials intheir daily life. No employee, contractor, or agent may engage in any lobbying activities
on behalf of Ingredion without prior written approval and coordination with theGovernment Affairs professional or legal counsel responsible for the country or region.
Any approved lobbying activities must be in full compliance with applicable laws. If you
are not sure whether your communications or interactions with a government official
are considered lobbying, contact the Government Affairs professional or legal counsel
responsible for the country or region.

Ingredion respects the right of employees and others working with the company toparticipate in political activities on their own time, outside of work. Where personal
political contributions are permitted by law, understand the following additional
conditions related to your relationship with the company:• do not make contributions from company funds;• do not submit expenses for personal political activities to the company
for reimbursement;• do not use company resources or disclose Ingredion’s confidential information
when participating in the political activity; andPOLITICAL PARTICIPATION AND CONTRIBUTIONS• do not, in any way, state or suggest that you are representing Ingredionin the individual political activity (e.g., on social media).

Ingredion does not give political contributions to candidates, political party
organizations, political committees, or political organizations in return for express
or implied official acts.

The above rules also apply to any individual contractors and others who workfor Ingredion.

Living our Values
Many countries in which Ingredion does business strictly regulate lobbying activities.
Remember:

Our Values in Action• never engage in lobbying on behalf of Ingredion without prior written approvaland coordination with the Government Affairs professional or legal counsel
responsible for the country or region;

Q: I have been asked to work on a local political campaign. May I do so?

• lobbying activities must be in full compliance with applicable federal, state,
and local laws.
If you are not sure whether your communications or interactions with a government
official are considered a lobbying activity, contact the Government Affairs professionalor legal counsel responsible for the country or region.

INTRODUCTION

CARE FIRSTBE PREFERREDEVERYONE BELONGSINNOVATE BOLDLY

A: Y es. Our company encourages participation in the political process. However,
it is important that your political activities remain separate from the workplace,done on your own time and at your own expense. Therefore, you cannot use
company resources, including work hours, company vehicles, use of the company’s
computer network or telephones, or use of the company’s name or other assets,
when working on personal political activities.

OWNER’S MINDSETOUR STANDARDS20

BE PREFERRED

Question or Concern? Visit the Business Ethics Line at INGRethics.com

International Trade Compliance
We comply with all trade regulations, agreements, and restrictions that apply to our business during exchangeof goods between countries, including import customs declarations and export control laws.

Living our Values
If you are responsible for the movement of Ingredion products, or an offeror of non-commercial materials acrossborders, you must be familiar with and comply with applicable U.S. and any local laws outside the U.S. governing
trade, regardless of where you are actually based or located. Remember:• Ingredion does not conduct unauthorizedbusiness with countries or third parties thatare subject to trade embargoes or economic
sanctions (e.g., Iran., Syria, North Korea);• as a U.S.-based company, Ingredion isprohibited from participating in boycotts(e.g., refusals to sell to customers locatedin a particular country) that the United States
government does not support;• import of Ingredion goods shall undergo proper
assessment of duties from tariffs using accuratevaluations based on purchased cost (price paid)or transaction value (Ingredion Transfer Pricing
policy) for related party transactions;

INTRODUCTION

CARE FIRSTBE PREFERRED• follow your local trade compliance policies andprocedures relevant to the country and location
where you work;• contact your local trade compliance
representative or your local Legal Department
if any customers, suppliers, or forwarding agents
ask Ingredion to participate in a boycott or do
business with embargoed or restricted parties.
Remember that sanctions can and do change.
Always seek advice for the most up-to-date
positions before you take any actions.

EVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSETOur Values in Action
Q: To avoid paying customs duties in its homecountry, an international customer has asked thatan employee in the U.S. sign an origin declarationor certificate of origin identifying that thecompany’s products originate in Mexico. I know
the product was packaged in Mexico but am notaware of the manufacturing process and where
the product was originally made. May I sign the
document?
A. No, not without prior approval of the
Corporate or United States/Canada Trade
Compliance team or your local trade compliancecontact. Origin declarations and certificates oforigin are governed by local and internationallaws and they require a detailed analysis of the
manufacturing process under an established setof rules. An incorrect statement may result infalse declarations to customs authorities andsubject the company to significant fines andpenalties, even when Ingredion is not the importeror exporter.

OUR STANDARDS

21

Everyone Belongs
We embrace diversity and proactively foster an inclusive work
environment where each person is valued and feels inspired
to contribute their best.

IN THIS SECTION:
Diversity and Inclusion
Harassment and Discrimination
Anti-Violence, Threats, and Intimidation

Question or Concern? Visit the Business Ethics Line at INGRethics.com

EVERYONE BELONGS

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Diversity and Inclusion
We leverage the diverse talents and perspectives of our workforce to find new ways of adding
value to our business and to customers’ businesses.
We work to include and strengthen the diversity of our teams because it helps us achievestronger and better business outcomes, while creating a positive employee experience.

Living our Values
We believe that our growth and innovation depend on a company culture that values and promotes
diversity and inclusion. Diversity of thought, perspectives, background, and experiences isessential to the company’s long-term success. We:• value the diverse talent of our people;• demonstrate respect for each other;• actively seek out different opinions and approaches;• continuously strive to surface and remedy biases (both conscious and unconscious
biases); and• drive growth and innovation by integrating our diversity and inclusion strategies
into our business practices.

Our Values in Action
Q: I heard that diversity means that there will be preferential treatment for hires andpromotions. Is this correct?
A: No. Hiring and promotion decisions are based solely on factors such as skill, qualifications,performance, and business needs—not on personal characteristics.

INTRODUCTION

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23

EVERYONE BELONGS

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Harassment and Discrimination
Our Values in Action

We are committed to maintaining a workplace free of harassment, discrimination, and any otheroffensive or disrespectful conduct.

Q: O ne of my co-workers emailed an inappropriate
joke to me and some others in my department.
I find it offensive, but I don’t know if I should
approach my co-worker with my concern. Whatshould I do?

We recruit, train, and promote talent based on a person’s skill, ability, qualifications, performance,
and aspirations, without regard to non-job-related characteristics.

What is Harassment and Discrimination?
Harassment is any unwelcome conduct related to a person’s legally protected characteristics,
such as race or gender, that creates a hostile or abusive work environment. Harassment may beverbal, visual, or physical.

A: W
 e each have an obligation to ensure that
Ingredion is a great place to work for everyone.
Offensive behavior such as emailing inappropriate
jokes is not acceptable. If you feel uncomfortablespeaking with your co-worker directly, contact
your manager, Human Resources, or the local
Legal department.

Sexual harassment may consist of verbal, visual or physical conduct of a sexual nature thatis unwelcome or that makes someone feel uncomfortable. It can take many forms, such as:• sexual advances, requests for sexual favors or unwelcome demands for dates;• sexually oriented jokes, pictures, text, or email messages;• explicit or degrading comments about appearance; or• display of sexually suggestive pictures or pornography.
Discrimination means making employment-related decisions based on illegal, non-job-related criteriasuch as a person’s race, color, religion, age, gender, gender identity, gender expression, status, sexual
orientation, veteran status, disability, military service, or any other classification protected by law.

Living our Values
Our company celebrates the uniqueness of our employees and builds high-performing teams bycreating the conditions that allow every person to be motivated to do their best work. In living ourvalues, we:• treat people fairly and focus on the value they bring to Ingredion;• make decisions about recruitment, training, and promotions based on merit;• refuse to accept any excuses for discrimination or harassment.

INTRODUCTION

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24

EVERYONE BELONGS

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Anti-Violence, Threats, and Intimidation
We do not tolerate violent behavior, threats to people or property, or physicalintimidation or coercion.

Living our Values• We do not engage in acts of workplace violence, verbal assaults, threats,or any expressions of hostility, intimidation, aggression, or intentionallycausing someone to feel embarrassment. Our company also prohibits
the possession of weapons in the workplace.
• We speak up and report harassment and threats of potential violence
immediately. If there is potential for violence, report it immediately.

INTRODUCTION

CARE FIRSTBE PREFERREDEVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSETOUR STANDARDS

25

Innovate Boldly
We courageously strive for breakthrough innovations driven
by our relentless curiosity, bold thinking, speed of decisionmaking, and agile execution.
IN THIS SECTION:
Intellectual Property and Company Assets
Email, Internet, and Information Systems

Question or Concern? Visit the Business Ethics Line at INGRethics.com

INNOVATE BOLDLY

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Intellectual Property and Company Assets
We safeguard our company’s intellectual property and other company assets, and we use company resources responsibly.

What is a company asset?

Living our Values

A company asset is a resource or thing of value owned
by Ingredion. A company asset can take several forms,
such as:Our company assets are extremely valuable. They drive
innovation, protect our company’s reputation, andsupport us in delivering superior products, services,and solutions. We safeguard and use our company’s
assets responsibly by:• Information assets: Any data relating to our
products, business, or how we conduct ouroperations, regardless of how it is created,distributed, used, or stored.
• Financial assets: Money and anything that can beconverted into money, such as stocks, bonds, andbank deposits.
• Physical assets: Anything tangible the company
owns that is used to conduct our business (e.g.,facilities, machinery, tools, computers, mobile
phones, raw materials, vehicles, office equipment,
and supplies).
• Intangible assets: Our reputation, ideas, inventions,
intellectual property, designs, copyrights,
trademarks, patents, and trade secrets.
• Work product: Your work product belongs
to Ingredion if it is created or developed—
in whole or in part—on company time, as part ofyour duties, or using company resources
or information.

INTRODUCTION

CARE FIRSTBE PREFERRED• properly securing physical assets and following
all security procedures applicable to our jobs;• properly securing computers, laptops, and otherelectronic devices;• following Ingredion Brand Guidelines and seeking
appropriate approval prior to releasing Ingredionbranded communications;• properly securing company confidential
information and never disclosing confidential
information to anyone outside the company
unless we have explicit approval (e.g., theinformation is covered by a non-disclosureagreement); and• securing and not deleting any files, documents,
or other information that may be needed forpending or anticipated litigation, investigation,or audit.

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INNOVATE BOLDLY

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Email, Internet, and Information Systems
We use company email, internet access, and other information systems responsibly and protect the securityof our information systems.

Q: I used my company-issued computer
to download free software that I can use
in my work.

Living our Values
The company’s email, internet access, and information systems are vital tools that are necessary for innovatingboldly. Employees must exercise good judgment in using the company’s systems:• grant access only to authorized individuals
and only for as long as needed;• take appropriate steps to use strong passwords
and to protect passwords;• do not use company resources, email, andinternet access to offend, harass or threaten
others or to access, send, or store illegal or
offensive material;• make only reasonable, incidental personal useof company equipment and systems;• never download unauthorized or unlicensed
software onto Ingredion computers or mobile
devices;

INTRODUCTION

Our Values in Action

CARE FIRSTBE PREFERRED• take reasonable precautions to safeguard
company devices, such as laptops, by not leaving
them unattended while traveling or in exposed
locations where they can be stolen;• do not use company information systems to
reproduce, display, distribute, or store materials
that violate anyone else’s trademark, copyright,
licensing, or other intellectual property rights;
and

A: N
 ever install applications or software onto
devices—company owned or otherwise—that could undermine the security of
Ingredion’s information technology
assets. Installing applications directly can
introduce viruses or other rogue programs
into the company network that can cause
damage. In addition, do not click links
in emails from unknown sources, as you
may be permitting entry of potentiallyharmful code to the company’s network
unwittingly.

• report a suspected data breach, or any situationin which you believe data has or may have been
compromised, including the loss or theft of alaptop or mobile device, to the IT Service Desk
immediately.

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Owner’s Mindset
We think and act like owners—where everyone takes
personal responsibility to anticipate challenges, proactively
search for opportunities, and make decisions that are in thebest interest of the company.
IN THIS SECTION:
Accuracy of Books and Records
Insider Trading
External Communication and Social Media
Confidential Information

Question or Concern? Visit the Business Ethics Line at INGRethics.com

OWNER’S MINDSET

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Accuracy of Books and Records

Our Values in Action

We are responsible for ensuring that Ingredion’s business records are accurate and complete.

Living our Values

RECORDS MANAGEMENT

Ingredion’s public disclosures and filings are based on
the accuracy and truthfulness of our books and records.
Our company books and records must be complete,accurate, and reliable, and must follow Generally
Accepted Accounting Principles. Each of us plays a rolein ensuring that Ingredion’s business records are accurate
and complete:

We are committed to managing our documents and otherrecorded information consistently and in accordance with
relevant legal obligations and business needs. We must:• comply with our Records Management policy for all
documents, files, electronic records, and emails.
Information that relates to personal informationof employees requires special care.

• follow all internal controls and finance policies,
including travel and expense policies;• follow the retention periods specified in the Records
Retention Schedule for your country and function.

• follow applicable laws, regulations, industry
standards, and company policies when you
produce, store, or destroy records and documents;
and• follow the instructions in a Legal Hold notice.
Destruction of information subject to a Legal Hold,even inadvertently, could expose the company andyou to civil and criminal liability.

• speak up if you detect fraud or notice an inaccuracy
in a company record or a failure to follow ourinternal controls.
NEVER falsify, omit, misstate, alter, or conceal any
information or otherwise misrepresent the facts on
a company record.
NEVER encourage or allow anyone else to compromise
the accuracy and integrity of our records.
NEVER keep hidden or unrecorded funds, accounts,
or assets.

INTRODUCTION

CARE FIRSTBE PREFERRED

What is a record?
Information recorded in any medium, hard copy orelectronic, in the company’s custody or control that relates
to its business is considered a record.
A variety of information categories may be considered
records. Some examples include financial statements,
presentations, diagrams, illustrations, formulas, spreadsheets,
payroll documents, time cards, attendance records, legal
agreements, inventory records, invoices, purchase orders,
contracts, market research tests, lab tests, quality control
tests, data related to our products, travel and expense
reports, inspection records, transportation, logs, hazardous
material records, accident reports, and business plans.

EVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSET

Q: I am new to my department. When I started
my new position, I was told by a colleague that
it was okay to delay accruing certain expenses
until the next period. He said, “If we move themto next fiscal year, we are not doing anything
wrong.” Is that true?
A: N o. Deliberately delaying the accrual of
expenses, regardless of the amount, would
be a misleading, unacceptable, and possibly
unlawful practice. Every business and financialtransaction, however immaterial, must bereported accurately and honestly. Falsificationof any company document or record is a serious
offense and could result in termination of
employment.
Q: I work in Quality Assurance and we are runninglate in releasing a load to a customer. The pass/
fail for the test I am running is 2.0 g/ml andthe test result came back at 2.1 g/ml. I knowthat this customer has received late deliveriesat least three times in the last six months. If I
reject this load, this may result in a fourth latedelivery. What should I do?
A: Record the test result accurately. It is important
for the company to maintain accurate books
and records. Our customers and ingredientconsumers are depending on us.

OUR STANDARDS30OWNER’S MINDSET

Question or Concern? Visit the Business Ethics Line at INGRethics.com

Insider Trading

Our Values in Action

We do not use or share confidential, nonpublic information about
Ingredion or any other company for the purpose of buying or
selling Ingredion stock or the stock of any other company.

Living our Values
While working for Ingredion, you may learn or have accessto nonpublic information that could be relevant to an investor.
This information, called “material nonpublic information” or “inside
information” consists of nonpublic information that an investor
would consider important in making an investment decision. In orderto protect investors, securities laws have special procedures for thosewith material inside information about a company or its securities
to trade in its securities. We are prohibited from unauthorized
disclosure of the company’s or others’ confidential, nonpublic
information. To prevent insider trading:• never trade in Ingredion shares or any other publicly traded
company while aware of inside information concerning any
applicable company or securities;

Q: I went to my doctor for a routine visit. At the end of my appointment,
the doctor asked me how Ingredion stock was doing and whether heshould invest in Ingredion. I have known my doctor for many years.
I think a modest investment in Ingredion could help him recover someof what he lost after the global financial crisis. Can I tell what I know
about upcoming product launches or recommend Ingredion stock to him?
A: N
 o. Details of upcoming product launches are material, nonpublic
information that could provide your doctor with an unfair trading
advantage. Sharing that information would be illegal and could resultin prosecution.
Tell him that since you are an Ingredion employee you cannot provide
confidential information that would encourage or discourage anyone
from trading in the stock. Refer him to the Investor Relations sectionof our website or suggest he contact Investor Relations if he has
specific questions.

• never share inside information with anyone outside ofIngredion, including immediate family, relatives, or friends;• take care to protect inside information from accidental
disclosure by being careful with company documents andtalking discreetly; and• avoid tipping: passing along material, nonpublic information
about Ingredion or any other company to anyone who may
trade in securities.

INTRODUCTION

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Question or Concern? Visit the Business Ethics Line at INGRethics.com

External Communication and Social MediaOur Values in Action

Having an Owner’s Mindset means we embody a culture of personal accountability in everything we do,including our communications. We communicate truthfully, factually, and responsibly about Ingredion.

Q: On LinkedIn, I noticed that a user posted a question
on my profile about a potential acquisition. The news
media had already discussed the acquisition, but noofficial announcement had been made. May I commenton the post?

Living our Values
We are committed to engaging our customers and stakeholders through effective communication. Social
media, such as social networking sites, blogs, photo- and video-sharing sites, forums, and chat rooms haveprovided us with new ways to engage and collaborate with others. We embrace these communication
opportunities, and we are committed to using them responsibly. This means we:• communicate truthfully and accurately about
Ingredion and always through the authorized
Ingredion communications channels;• identify opinions as your own unless you areauthorized to speak on behalf of the company;• never post, discuss, or disclose confidential
information belonging to Ingredion or
entrusted to us by customers or others;• do not use Ingredion’s logos, trademark,or copyrighted materials when using social
media outside of work. We do not postconfidential information, images, photos,
videos, or audio clips of Ingredion facilities
without written permission;• refer all media inquiries to Corporate
Communications or Investor Relations(or the local equivalent of these functions
in your region); and• never use Ingredion communication systems
or information technology to post harassing
or discriminatory content, or anything that
could reasonably make others feel bulliedor threatened.

A: No. Information about the potential acquisition is
confidential company information. If the media chooses
to speculate, then that is their choice. Your publicly
commenting may result in legal consequences andreputational damage for the company. Even after theacquisition has been publicized by Ingredion, commenting
can reveal undisclosed information. Refer any negative
mentions of the company that you notice on social media
to Corporate Communications. Do not attempt to respondon your own.
Q: A
 fter a positive meeting with leadership, a senior leader
sent out a tweet from his private Twitter account: “Goodmeeting. Good numbers = Happy Board.” Ingredion’s
official earnings announcement was due to be released
to all investors later in the week. However, the tweet wasfrom his private account so there’s no problem, right?
A: Wrong. If the official earnings have not been announced,
the leader’s Twitter followers may be considered to haveaccess to insider information, which can have significant
legal and reputational consequences for the company
and the individual who issued the tweet. Report this typeof finding to your local Human Resources or through the
Ingredion Business Ethics Line.

INTRODUCTION

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Question or Concern? Visit the Business Ethics Line at INGRethics.com

Confidential Information

Our Values in Action

We protect the confidential information of our company and of our business partners.

What is confidential information?
Confidential information includes nonpublic information
that, if improperly disclosed, could be useful tocompetitors or harmful to Ingredion, our suppliers, ourcustomers, or other organizations or people. Confidential
information might be relevant in an investor’s decision
to buy, sell, or hold Ingredion securities or the securities
of any of our business partners.
Confidential information is generally something ofcommercial value to Ingredion, for example, earnings
forecasts, business plans, strategies, and significant
restructurings or investments; potential mergers,
acquisitions, or divestitures; pricing, sales information,
research, new product development, formulas andproduct recipes; manufacturing processes; undisclosed
marketing and promotional activity, significant
management changes; draft or unpublished accounts;
and events regarding Ingredion securities would all
qualify as confidential information. We must recognize
when something is confidential and take steps to keepthat information secure, and not lost, damaged, or given
away accidentally.
Disclosure of nonpublic, material information, whether
intentional or inadvertent, may trigger certain public
disclosure requirements for the company.

INTRODUCTION

CARE FIRSTBE PREFERRED

Employee information, including particularly sensitive
personal information, such as health records, should also
be kept confidential and only accessed by the Ingredion
staff who need to know that information for the purposeof their role, for example to an employee’s manager.

Living our Values
While working at Ingredion, you may have access toconfidential information of our customers, suppliers,
business partners, or other organizations or people.
We must always take reasonable precautions
to prevent its unauthorized disclosure. Protect
confidential information:• do not disclose the confidential informationof one customer to another;• disclose confidential information only to those
who are authorized and have a business needto know it;• do not share confidential information with anyone
outside our company without proper authorization.

Q: I am working on an M&A project with a crossfunctional team. At the end of a meeting, someof the team members continued discussing thestatus of the deal during the walk to a local
restaurant. Is this a problem?
A: Yes. Information related to an M&A deal isconfidential. Outside the meeting room, individuals
who do not have a legitimate need to know may
overhear confidential information. Take care not
to disclose company confidential information in
public places.

Q: I can get a lot of things done by returning
calls while waiting to board flights or trains.
Is this a problem?
A: B
 e careful not to discuss nonpublic company
information in public places where others
may overhear you, such as taxis, elevators, atconferences, and particularly at trade shows. When
it is necessary to conduct a telephone call in a
public place, be mindful of your surroundings.

Contact the Corporate Compliance department or yourlocal Legal department immediately if you know orsuspect that information was mishandled in any way,even inadvertently, or is at risk.

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33

Question or Concern? Visit the Business Ethics Line at INGRethics.com

We consistently
demonstrateintegrity and highethical standards

INTRODUCTION

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OUR STANDARDSQuestion or Concern? Visit the Business Ethics Line at INGRethics.com

Our Code of Conduct
Our Code applies to everyone at Ingredion and its
affiliates around the world, including employees,
contract workers, agents, company officers, andDirectors. In some cases the Code applies to third
parties and others working on the company’s behalf.

Living our Values
Our Code of Conduct provides guidance on the
ethical behaviors that drive our business decisions. It
promotes a common understanding of right and wrong
across our company, wherever we operate. Remember:• in a competitive business environment, no
document or policy can answer every questionin every situation;• speak up! Bring questions about situations notdiscussed in this Code (or that may arise in yourinteractions with customers, team members,
suppliers, or others), to your manager, theLegal Department, the Corporate Compliance
Committee, or Human Resources Department,
or contact the Business Ethics Line;• communicate to contractors, agents, and otherbusiness partners that they are expected to
uphold the standards of our Code of Conduct
when working with or on behalf of Ingredion.

INTRODUCTION

CARE FIRSTBE PREFERREDCOMPLIANCE WITH POLICIES, LAWS,
AND REGULATIONSOur Code of Conduct provides the framework for how
we work as a company. We must follow the Code of
Conduct AND the policies, laws, and regulations that
apply to our work and the countries where we dobusiness. Note that our policies reflect the laws of thecountries where we do business and may be more
stringent than other laws require.

BUSINESS INTEGRITY, ETHICS,
AND COMPLIANCE PROGRAM
The mission of our compliance program is tosupport and foster Ingredion’s culture of integrity
and compliance with the law, consistent with thecompany’s values.
If you are unsure what laws or policies apply toyour work, ask a manager, HR, Legal, or Corporate
Compliance, or contact the Business Ethics Line.
We all have a duty to speak up if we are unsure what
to do, have a concern, or if we see or suspect aviolation of policy or law.

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35

CONTACTS
For

Contact

Reporting Concerns

Discuss the issue with• your manager;• another manager;• the Human Resources, Legal, or Regional or Corporate Compliance department; or• use the Business Ethics Line (INGRethics.com) to report concerns or ask questions(anonymously if you wish) in your language

Legal Questions

Contact your local Legal support

Concerns regarding product safety and quality

Contact your local Quality Management representative

Questions regarding trade complianceContact International.Compliance@ingredion.com

Human Resources-related policy and procedure questions

Contact your local HR support

Inquiries regarding the trading of securities

Contact the Office of the Corporate Secretary

Policies related to the Code of Conduct

Visit the Corporate Policy Center on InSite

Questions about the Compliance Program

Ask the Corporate Compliance Officer (AsktheCCO@ingredion.com)

Question or Concern? Visit the Business Ethics Line at INGRethics.com

INTRODUCTION

CARE FIRSTBE PREFERREDEVERYONE BELONGSINNOVATE BOLDLYOWNER’S MINDSETOUR STANDARDS

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