CODE OF CONDUCTEVERYONE. EVERY DAY. EVERY WAY.

EVERYONE.
EVERY DAY.
EVERY WAY.

Integrity Helpline 1-855-RaiseIt | dfamilk.ethicspoint.com

MESSAGE FROM

THE PRESIDENT AND CHIEF EXECUTIVE OFFICER
AND CHAIRMAN OF THE BOARD
Dear Employee,
Dairy Farmers of America is a farmer-owned, farmer-governed dairy cooperative. We are a diverse
organization united by our shared mission, vision, and values, and our value of integrity is essential in
everything we do. We expect you to be honest, set a good example, take responsibility for your actions,and treat people with respect. That is who we are.
The Code of Conduct is the core of our Value Integrity compliance program and provides an overview
of our Value Integrity policies. The Code is intended to serve as a reference guide to help you navigate
situations you may encounter as part of your job. It helps you understand your individual responsibilities,
ethical workplace practices, and who to contact if you have a concern or need more information.
As an employee of DFA, it is important for you to understand the expectations to which we hold ourselves
accountable. We must help one another stay within the guardrails described in the Code. Everyone should
promote an environment where it is safe to ask questions and provide feedback to ensure we follow theCode. If you ever suspect unethical conduct in the workplace, or a potential violation of an applicable law
or the Code of Conduct, you are expected to Raise It, as described in the Code.
Our words, actions or inactions, choices, and decisions shape our culture. Therefore, we must conduct
ourselves in an ethical, honest way. Thank you for supporting a strong culture of integrity — a culture of
doing the right thing.
Sincerely,

DENNIS RODENBAUGH

President and Chief Executive Officer

R ANDY MOONEY
Chairman of the Board

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AT DAIRY FARMERS OF AMERICA, INC., and its family of companies (“DFA” or “Cooperative”), we live every day guided by ourvalues of integrity, quality, passion, and community. We are committed to conducting business legally, fairly, and honestly. It is
our practice to maintain the highest ethical standards, and to create a workplace free of inappropriate or unlawful behavior.

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1.

Scott Vieth and Jeff Hoegger
DFA farmer-owner and DFA employee
Windthorst, Texas

2.

WE VALUE INTEGRITYIN OUR WORKPLACE

About the Code of Conduct

4

Responsibilities
5− Responsibilities of all employees− Responsibilities of Leaders
Employees can find the full textof each Value Integrity policy on
The Parlor or through the links
included in this document.

Selena Kanosh | DFA employee
St. George, Utah

Bullying, Harassment,
and Discrimination

11

Human Rights

11

Diversity, Equity, and Inclusion 12

Decision-Making Guide

6

Workplace Violence

12

No Retaliation

7

Employee Health and Safety

12

Code Training
and Acknowledgement

7

Drug-Free Workplace

13

Raise It
8-9
− Raise It Process− What Should Be Reported?
− What Happens When You Makean Integrity Helpline Report?

3.

4.

DFA office | Dallas, Texas

IN OUR BUSINESS
Food Safety and Quality

Greg Czernik | DFA employee | Chicago, Ill.
Raquel Melo | DFA employee | St. Paul, Minn.

IN OUR MARKETPLACE
15

5.

DFA employee | Kansas City, Kan.

IN OUR COMMUNITIESAntitrust

21

Business and Financial Records 15− Financial Integrity− Records Management

Anti-Corruption
and Anti-Bribery

22

Gifts

22

External Communications− Social Media− Media Communication

16

Commodity Trading

23

International Trade23

Conflicts of Interest

17

Supplier Code of Conduct

23

Protecting DFA Assets− Information Security− Confidentiality andIntellectual Property− Data Privacy

18-19

Political Activities

25

Sustainability

25

Environmental Protection

25

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1.

Scott Vieth and Jeff Hoegger
DFA farmer-owner and DFA employee | Windthorst, Texas

WE VALUE INTEGRITYABOUT THE CODE OF CONDUCT
Just like our farmer-owners, we value integrity in everything
we do. We treat people with fairness and respect. We are
ethical, honest, professional, and trustworthy. The Value
Integrity Code of Conduct (“Code”), also informally referred
to as The Red Book, is a guide to ensure our daily businessinteractions are conducted with integrity.
The Code provides an overview of acceptable conduct andprovides examples of dilemmas that may arise. It explains
what is expected of all employees, provides the standards bywhich all employees will conduct themselves, and reinforces
our uncompromising commitment to integrity.
The Code is intended to help employees recognize potential
ethical or legal issues, direct you to the appropriate
resources to obtain more information, and understand yourresponsibility to report known or suspected violations of theCode and its underlying Value Integrity policies.

All employees of DFA are required to understand and follow
the Code. It does not matter where you work or what you dofor the Cooperative, you have a responsibility to use good
judgment and follow the Code. This includes every employee
at every level.
The Code is available electronically on The Parlor, the DFA
external website (dfamilk.com), and the Integrity Helpline
website (dfamilk.ethicspoint.com). If you have questions orconcerns about interpreting or complying with the Code or its
policies, you should discuss the situation with your manager,
or the Human Resources, Ethics and Compliance, Legal, orInternal Audit Departments.
Information contained in the Code applies to all employees.
In the event that certain terms or conditions stated inany collective bargaining agreement differ, the applicablecollective bargaining agreement language will control.

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RESPONSIBILITIESNo DFA employee has authority to engage in conduct that does not comply with the Code,or to authorize, direct, approve, or condone such conduct. It is everyone’s responsibility toprotect the Cooperative from unethical, improper, or illegal actions. Failure to do so may
result in disciplinary action, up to and including termination.

RESPONSIBILITIES OF ALL EMPLOYEES
DFA’s reputation of acting with integrity is built by every
employee, every day, in every way. Each employee is
responsible for demonstrating integrity by committing to:• Read and understand the Code
• Understand and abide by the laws and regulations
applicable to your work
• Comply with the Code and internal policies and procedures• Be professional, respectful, honest, and ethical• Complete required training and acknowledgments• Hold yourself accountable for ethical behavior• Ask for guidance if you are ever unsure about a situation
or decision• Report concerns about potential or suspected violationsof the law, the Code, or internal policies• Cooperate in investigations• Never retaliate against anyone who reports a concern 		
or participates in an investigation

LEADER RESPONSIBILITIES
While all employees are responsible for acting withintegrity, leaders have a heightened responsibility to leadby example, help employees understand and apply theCode, enforce the Code, and promote a culture of ethicalbehavior, trust, and integrity.
Leaders must:• Foster an environment where employees feel
comfortable raising concerns and asking questions• Coach their team(s) on doing the right thing andexpect ethical behavior• Ensure employees complete required training
and acknowledgments• Never retaliate, or allow retaliation, against anyone
who raises concerns or participates in an investigation• Promptly address employee concerns about conduct
with care and respect- Seek help in resolving and/or escalating issues when needed- Keep concerns confidential to the extent possible• Use good judgment and avoid even the appearance 		
of improper behavior
CONNECT THE CODE
Employees located outside of the United States, and employees doing business withparties outside of the United States, must comply with all applicable local laws, in addition
to the applicable laws and governmental rules and regulations of the United States.

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DECISION-MAKING GUIDEWe all want to do the right thing, but sometimes the answer may
not be clear. The Code is a valuable resource; however, it does notcover every situation you may encounter.
WHEN THE ANSWER ISN’T CLEAR, ASK YOURSELF
THE FOLLOWING:

1. Is it legal, ethical, and safe?
2. Is it consistent with DFA’s values, Code of
Conduct, and internal policies?
3. Does it uphold DFA’s strong reputation of actingwith integrity?

If you answered NO to any of thequestions, you should stop.

If you are UNSURE, you shouldstop, reconsider, and seek
guidance in making the rightdecision.
• Your immediate manager, nextlevel manager, or a humanresources professional are
excellent resources for guidance• You can also contact theInternal Audit, Legal, or Ethics
and Compliance Departments

4. Would I feel comfortable if my decision or action
was reported in the media?
5. Would I feel proud if my decision or action was
known to family members or close friends?

If you answered YES to every
question, then you may proceed.

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NO RETALIATION
We expect all employees to foster anenvironment where everyone feels
comfortable speaking up without fear of
retaliation. We prohibit retaliation of any
kind against any employee who reports
suspected unethical behavior, illegal activity,or actions inconsistent with DFA’s values
or the Code. No employee at any level ispermitted to engage in retaliation in any
form against any employee for reporting
good faith concerns or for participating in
an investigation. If you believe someone has
retaliated against you, Raise It.
Read the Retaliation Policy for more
information.

CODE TRAINING AND
ACKNOWLEDGEMENT
New employees will be provided training andeducation on the Code and its policies. New
employees will also receive a copy of theCode and will acknowledge they have readthe Code and agree to abide by its provisions
and principles. Employees will be required
to make similar acknowledgements on aperiodic basis and participate in periodic
training. Failure to read the Code or complete
the acknowledgement does not excuse an
employee from complying with the Code.

Wendy Einhardt | DFA employee | Cass City, Mich.

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RAISE IT
Every employee has a responsibility to promptly raise concerns about potential or suspectedillegal, unethical, or improper conduct in our workplace.
If you are not sure whether something is a violation of law or internal policy, you shouldraise the question. By asking questions or raising concerns, you help protect employees, theworkplace environment and culture, and DFA.

The Raise It process includes several
ways for employees to ask questions orraise concerns. When we say Raise It,
we mean bring it to someone’s attention
by contacting:• A supervisor or any memberof management

What should be reported?
While we cannot provide an
exhaustive list of the conduct orconcerns that should be reported,
any actions or behaviors you believe
could be a violation of the Code, DFA
policy, or the law, should be reported.

• A member of the Human
Resources, Internal Audit,
or Legal Departments

We do not expect employees todetermine whether there is aviolation; we expect employees toRaise It if they reasonably suspecta violation. You are not expected toand should not conduct your own
investigations. It is the investigation
team’s responsibility to determine
whether there is a violation of theCode or DFA policies. If there are
violations, we want to know in orderto address the situation and continue
to improve our business and culture.

• The Ethics and ComplianceDepartment:
RaiseIt@dfamilk.com
1-833-852-2020
1405 N. 98th Street, 		Kansas City, KS 66111
The Integrity Helpline (provides anoption to report anonymously):
1-855-RaiseIt (1-855-724-7348)
dfamilk.ethicspoint.com

CONNECT THE CODE
You should immediately contact a
local manager to report issues that
require urgent attention, such as:• Employee health and safety• Food safety and quality• Workplace violence

The Integrity Helpline is operated
by an independent third party withexpertise in routing concerns.

Read the Integrity Helpline Policy
for more information.

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WHAT HAPPENS WHEN YOU MAKE AN INTEGRITYHELPLINE REPORT?
1. YOU MAKE A REPORT

2. YOUR REPORT IS ROUTEDYou can choose to reportanonymously, but in most cases
it helps the investigation if you
provide your contact information
You provide as much detail anddocumentation as possible tosupport your concern(s)TO THE APPROPRIATE
DEPARTMENT AND
WILL BE ASSIGNED AN
INVESTIGATOR

Investigators typically workin the Ethics and Compliance,
Human Resources, or Internal
Audit Departments

3. THE INVESTIGATION IS CONDUCTED. PLEASE REMEMBER:
Investigators are fact finders
It is everyone’s responsibility to be open and honest, andparticipate fully in an investigation
You may be asked for additional information and documentation,and may be interviewed by the investigator

5. APPROPRIATE ACTION IS TAKEN, WHICH MAY INCLUDE:
Process or program enhancements
Policy or procedure changes
Discipline of employees
Additional or repeat training, guidance, or coaching

4. THE INVESTIGATORASSEMBLES THE FACTS
AND DETERMINESWHETHER THE
ALLEGATIONSARE ACCURATE

6. WE NOTIFY YOU OFINVESTIGATION CLOSURE
To protect employee
confidentiality, we are not able
to inform you of any disciplinary
action taken

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2.
WE VALUE INTEGRITYIN OUR
WORKPLACE

Our people are valuable, and they deserve to be treatedwith respect. We do not tolerate discrimination, and we
provide equal employment opportunities for all applicantsand employees. Employment-related decisions are basedon skills, ability, education, experience, certifications, andachievements, regardless of protected status. We respect
employees’ freedom of association, the right to collective
bargaining, and all other workplace rights.
You must do your part to create a workplace where others
feel valued and respected for their contributions — aworkplace that is free from intimidation and harassment,
and a work environment where people feel safe.

Selena Kanosh | DFA employee | St. George, Utah

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BULLYING, HARASSMENT, 				AND DISCRIMINATION
We believe all individuals should be treated with respect and dignity.
This is why we are committed to maintaining an environment free fromdiscrimination or unwelcome conduct that creates an intimidating, 		
offensive, or hostile work environment.
Bullying, harassment, and discrimination are strictly prohibited in theworkplace or any work-related setting. This type of conduct consists ofverbal, visual, written, or physical behavior that would make a reasonable
person uncomfortable, or that could interfere with the person’s job
performance. Examples include:• Inappropriate or unwelcome conduct • Hostile and aggressive comments orthat is based on, or motivated by, an
behavior meant to demean someone
individual’s legally protected category • Explicit or degrading comments• Racial, ethnic, gender, or religious slurs
about appearance• Sexual advances, requests forsexual favors, or unwelcome
demands for dates• Display of materials that insult or show
hostility toward a group or individual• Offensive jokes, pictures, texts,social media posts, comments, oremail messages
Read the Bullying, Harassment, and Discrimination Policy for more information.

REMEMBER: Harassment is determined byyour actions and how they impact others,
regardless of your intentions.

CONNECT THE CODE
While DFA prohibits all formsof bullying, harassment, anddiscrimination, certain groups ofindividuals are legally protectedfrom harassment and discrimination.
These legally protected categories
include: race, color, religion, age(40+), veteran status, national origin
or ancestry, physical or mental
disability, genetic information,
citizenship, gender, pregnancy,
sexual orientation, gender identity,or any other status protected byapplicable law.

HUMAN RIGHTS
We are committed to maintaining a work environment respecting human rights,
and we strictly prohibit forced labor or services, and unlawful child labor.
Employees are expected to:• Comply with applicable anti-human trafficking laws
• Comply with applicable child, wage, benefit, or working hour labor laws
• Raise concerns about possible human trafficking or child labor law violations
Read the Human Rights Policy for more information.

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DIVERSITY, EQUITY,
AND INCLUSION
We are focused on building andmaintaining a workforce that reflects
the diversity of the communities inwhich we live, operate, and serve.
We believe that including diverse
perspectives leads to better decisions,more creative innovation, more
effective problem-solving, and stronger
customer and consumer relationships.
We strive to provide an inclusive andequitable experience to meet theunique needs of each person and allow
everyone to feel empowered and bring
their best selves to work each day.
We are committed to fostering andstrengthening a culture of openness,
inclusion, respect, and continued growth.
Everyone at DFA is a key member ofthe DFA team, and is valued for theirunique perspectives and contributions.
We are one community.
We are one team.
We are one DFA.

CONNECT THE CODE
Everyone at DFA is expected to hold themselves
and others accountable for upholding a cultureof diversity, equity, and inclusion.

WORKPLACE VIOLENCEAll employees are expected to support and maintain a working environment
free from violence, threats of violence, intimidation, or coercion.
Employees are prohibited from engaging in any act that could cause
another individual to feel threatened or unsafe. Examples of prohibited
activities include the following:• Intentional physical contact like slapping, stabbing, punching,striking, shoving, or other physical assault• Throwing objects, damaging property, stalking, or otherwise
acting aggressively• Making oral or written statements intended to frighten,
coerce, or threaten
Read the Workplace Violence Policy for more information.

EMPLOYEE HEALTH AND SAFETY
Employees are our most important assets, and their safety andhealth are of primary concern. We expect every employee to leave
work in the same condition as they arrived. We are committed to thedevelopment, implementation, administration, and improvement ofsound and effective safety guidelines and procedures, designed tokeep employees safe and in compliance with rules and regulations
related to occupational health and safety.
We take the commitment of ensuring a safe and healthy workplaceseriously and believe it is everyone’s responsibility. Whether at ourfacilities, in the marketplace, or on the roadways, all employees are
responsible for following health and safety procedures, and generally
promoting a culture of safety. Every employee is empowered to take
immediate action for the safety of themselves and others, regardlessof role, title, or responsibility. If you see a situation that puts others at
risk, take action to keep yourself and others injury-free.
Read the Employee Safety Policy for more information.

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DFA employee | Zumbrota, Minn.

DRUG-FREE WORKPLACE
We are committed to providing all employees with a safe, healthy,
and productive workplace. To support this commitment, while onduty, at DFA facilities, on DFA property, in DFA vehicles, or at any
DFA-sponsored activity, the following are prohibited:• The unlawful manufacture, distribution, possession, use,solicitation, or sale of an illegal drug or controlled substance• Being under the influence of, or in any way impaired by, any legal or
illegal substance, that may alter or impair a person’s normal mental
and/or physical functions
Employees are expected to perform job duties free from the influenceof any substance that could impair job performance or judgment.
There may be instances, with appropriate approval, where drinking
alcoholic beverages while conducting business is permitted, but you
must comply with all laws and DFA policies, and always exercise bothmoderation and good judgment.

CONNECT THE CODE
It is your responsibility to check with ahealthcare provider about whether theuse of a medication may adversely affectyour ability to safely perform your job
duties. Notify your supervisor or local
human resources representative, prior
to performing work-related duties, if
your healthcare provider believes there
may be an adverse impact.
While many states continue to legalize
the medicinal and recreational use of
marijuana, in no event are you permitted
to be under the influence of, or in any
way impaired by, marijuana while on
duty or on DFA premises, even if you use
marijuana for medicinal purposes.

For more information, read the:• Drug and Alcohol Policy• Drug and Alcohol Policy for our Department ofTransportation-related positions

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3.
WE VALUE INTEGRITYIN OUR
BUSINESS

We are a dairy marketing cooperative
owned by dairy farm families who
expect us to act with integrity ineverything we do. We are also a foodcompany committed to producing
safe, high-quality, wholesome products.
Our farmer-owners expect us to protect
their assets and the reputation of DFA byliving our value of integrity every day. It is
our expectation that every employee makesa personal commitment to comply with theCode, use it as a reference when questions
arise about proper business conduct, andRaise It if they suspect illegal, unethical,
or improper conduct.

DFA office | Dallas, Texas

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FOOD SAFETY AND QUALITY

We recognize the importance of food safety from farm totable. Quality is one of our core values, and we expect all
employees to adhere to our uncompromising commitment tofood safety and quality. We are committed to continuously
enhancing our food safety practices and programs to ensure
we continue to produce safe, high-quality, and wholesome
food products during all phases of the food supply chain, andwe understand the importance of prudent transparency inadvertising and packaging. All employees must work diligently
to ensure our products meet customer expectations andcomply with all applicable laws and regulations. Every
employee is expected to drive and support a strong culturethat insists on the highest standard of food safety and quality.
Read the Food Safety and Quality Policy for more information.

BUSINESS AND FINANCIAL RECORDS
The integrity of DFA’s business and financial records is critical to thesuccessful operation of our business, and to the reputation and trust ofDFA’s farmer-owners, employees, suppliers, and customers.
FINANCIAL INTEGRITY
We are committed to accurately
maintaining books, records, andaccounts, and fairly reflecting
DFA’s business transactions andassets. Employees must follow allinternal processes, policies, andgenerally accepted accounting
principles to ensure DFA’s records
completely and accurately reflect
all transactions. Be alert to potential
irregularities such as suspicious or
fraudulent payments, false entries,
money laundering, or omissions inour books. Any attempt to distortor misrepresent actual or projectedfinancial information, such as sales,
cost of sales, operating expenses,
other income/expense, or earnings,
is prohibited.
Read the Financial Integrity Policy
for more information.

RECORDS MANAGEMENT
It is important for employees toknow and follow DFA’s policies
that relate to maintenance, storage,
and disposal of business records.
The Records Management Policy
includes a retention schedule toprovide required retention periods
based on the type of record. If
you are ever required to retain
certain records longer than theretention period, you will receive alegal hold or other communication
with instructions on retaining
those records.
Read the Records Management
Policy with Retention Schedule
for more information.

CONNECT THE CODEStore business and financial
records electronically where
possible, and do not maintain
duplicate records.

Examples of business records include:• Contracts• Purchase orders• Invoices• Production data
• Regulatory filings• Test results• Logbooks• Time cards• Final project documents
Be aware that emails and text
messages can contain information
pertaining to financial andbusiness records.

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CONNECT THE CODE
Be aware that social media content
you create can potentially be viewed
by a wide audience while it is actively
posted and may be available forviewing even after the content has
been deleted.

When posting or sharing to promote
the Cooperative’s products on social
media, you must disclose that you
are an employee of DFA. Here are acouple examples:
Check out my company’s great new
product! #DFAEmployee
I’m #DFAProud to work for a company
where we donate dairy products
and refrigerators through our
DFA Cares Foundation.

DFA employee | Garden City, Kan.

EXTERNAL COMMUNICATIONSSOCIAL MEDIADFA uses social media to connect with our farmer-owners, consumers,
business partners, and one another. Social media platforms can be powerfultools for demonstrating pride in who we are, what we do, and what we provide.
But if social media is not managed carefully, it can put the Cooperative at risk.
Employees may not use DFA-related social media platforms to post personal
information or make personal comments. When using social media toshare, comment, or otherwise engage on topics and issues related to the
Cooperative, keep these guidelines in mind:• Exercise sound judgment, demonstrate common sense, and act according to
the Code, internal policies, and applicable laws
• Respect the privacy and diverse set of customs, values, and points of view
held by the Cooperative’s farmer-owners, partners, customers, and employees• If you choose to discuss your employment or identify yourself as a DFA
employee in your social media profiles, include a disclaimer clarifying that theviews expressed are your own and do not necessarily reflect the views of DFA• Do not disclose confidential information or post false content• Never speak on behalf of the Cooperative’s brands on Cooperative-produced
content, industry-shared resources or online forums, groups, and chat boards
unless authorized to do soRead the Social Media Policy for more information.
MEDIA COMMUNICATION
Only spokespeople designated by DFA’s Corporate Communications
Department are authorized to communicate to the media on behalf of DFA.
If you receive a request for a comment from the media or any third party,
immediately contact Corporate Communications at dfacomm@dfamilk.com.

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CONNECT THE CODEAs you consider whether something
may be a conflict of interest, you should
ask yourself the following questions:
Taylor Hysong | DFA employee | Huntington, Ind.

1.

Could my personal interest influence,or appear to influence, my ability tomake sound and unbiased businessdecisions, or otherwise interferewith my ability to do my job?

2.

Will I personally benefit from thesituation based on my status as an
employee of DFA?

3.

Will it benefit a friend 			or family member?

4.

Will I be using DFA assets 		
for personal gain?

5.

Will my participation cause me 		
to put my interests ahead ofwhat’s best for DFA?

CONFLICTS OF INTEREST
Employees are expected to act in the best interest of DFA at all times and to
avoid conflicts of interest and even the appearance of a conflict of interest.
A conflict of interest occurs where an employee has personal intereststhat could interfere with their ability to impartially decide what is bestfor DFA. These personal interests can make it hard to be objective aboutbusiness decisions or give the appearance that you are making a choicethat will benefit your personal interests or someone with whom you havea personal relationship (like a family member), instead of DFA.
Potential conflicts of interest could arise where you have:• A romantic workplace relationship• A close personal relationship with a customer or vendor• A business or investment opportunity where you may havepersonal benefit• Outside employment• Ownership, financial interest, or board membership in any business
related to the dairy, food manufacturing, or agriculture industry• Gifts or favors that influence or could appear to influence yourjudgment or conduct with regard to business decisions
Conflicts of interest can often be resolved if properly disclosed when
they arise. If you think you may have a conflict of interest, or you’re ina situation that others may perceive as a conflict of interest, you must
promptly disclose it to your supervisor.
Read the Conflict of Interest Policy for more information.

If you answered YES to any of
the above questions, discuss thesituation with your supervisor.

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PROTECTING DFA ASSETS
Physical and electronic assets are provided for you to do your job and should not be
misused or wasted. Protect DFA property by taking the necessary steps to prevent
misuse and unauthorized use or access.

CONNECT THE CODE
Third parties include entities that do
business with DFA, such as customers,
vendors, suppliers, contractors, service
providers, and joint ventures.
CONNECT THE CODE
To safeguard our information systems,
keep your identification credentials
and passwords protected, use
multifactor authentication,and lock your electronic devices
when unattended.
Examples of intellectual property,
which are also considered confidential,
include formulas or recipes, researchand development data, trademarks,
customer and vendor proprietary
information, manufacturing processes,
and distribution methods.
Other confidential information
may include financial data, nondisclosure agreements, purchase orsale agreements, employee data, andinformation received from third parties.

INFORMATION SECURITY
Technology is critical to our business. As an employee, you may be granted
access to a variety of DFA or third-party systems and applications and/or email access. You may also be provided with electronic devices such as
computers, phones, tablets, and other digital communication tools. You are
expected to protect and use DFA’s technology in a safe and secure manner.
Failure to do so can create vulnerabilities in our systems and potentiallyresult in a data breach or have other negative consequences.
Limited personal use of phones, computers, email, or the internet is permitted,
but you are expected to exercise good judgment and refrain from allowing
personal use to interfere with the completion of your job responsibilities.
Be aware that anything you send, download, or store on or through DFA’s
systems or devices is considered DFA property, and may be monitored. You
should not have any expectation of personal privacy when using DFA’s assets.
Read the Technology Use Policy for more information.
CONFIDENTIALITY AND INTELLECTUAL PROPERTY
We are committed to protecting DFA’s assets and confidential, secret, andproprietary information from unauthorized disclosure. Our intellectual
property, such as logos, brands, product formulas, trademarks, trade secrets,
and patents, is vital in helping DFA develop new products and markets, attract
new customers and consumers, and maintain our competitive advantage.
We consider any non-public information or personal information about
DFA, our employees, farmer-owners, customers, and third parties, to be
confidential information. This information can be oral, written, or visual.
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Continued
If you access or receive confidential information or intellectual property,
whether the information is from an internal source or a third party, youare expected to comply with all applicable policies and laws regarding theprocessing and use of this information to protect it from misuse, loss, or disclosure.
Never disclose confidential information or intellectual property to anyone
outside the Cooperative unless you have explicit approval and it’s covered by anon-disclosure agreement, if appropriate. Even inside the Cooperative, do notshare confidential information or intellectual property beyond the minimum
extent possible, and only if the person(s) receiving the information has
appropriate authorization and a business need to know.

REMEMBER:
We have an obligation to protect DFA’s
assets, including, but not limited to:• DFA’s reputation• Tools• Brands• Inventory• Processes• Data• Computers• Software• Phones• Technology• Vehicles• Proprietary
information• Equipment

Your duty to protect confidential information and intellectual property lasts
beyond your employment. If you leave DFA, your confidentiality obligation
remains, and you are prohibited from sharing non-public information you
learned of while employed at DFA.
Read the Confidentiality and Intellectual Property Policy for more information.
DATA PRIVACY
We take our obligation to protect the personal information of our employees,
farmer-owners, customers, third parties, and other business contacts seriously.
We use and process personal information for business purposes only andare committed to the proper protection of this information. It is the collective
responsibility of all employees to maintain the integrity of personal information.
Read the Data Protection Policy for more information.

CONNECT THE CODE
Do not release or provide personal
information to others within DFA who
do not have a clear business need toknow and authorization to receive theinformation. Personal data includes
any information that identifies, orreasonably can be used to identify, anindividual. Examples of personal data
include contact information, financial
information, date of birth, and Social
Security numbers.

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4.
WE VALUE INTEGRITYIN OUR
MARKETPLACE
Our business structure supports our mission
to deliver value to our farmer-owners acrossthe dairy chain. From our farm services, milkmarketing, and commercial investments teams,
to the functions that support the Cooperative,
including our family of businesses and strategic
partners, the strength of our business model
comes from our collective ability and willingness
to operate throughout the entire dairy value chain.
We are committed to doing business ethically,
fairly, and legally with our farmer-owners,
customers, and suppliers, and remaining alert tothe special rules and regulations applicable to ourgovernment customers.

Greg Czernik | DFA employee | Chicago, Ill.
Raquel Melo | DFA employee | St. Paul, Minn.

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ANTITRUST
We are committed to abiding by the letter, spirit, and intent of all antitrust
laws that govern competitive behavior to protect all participants in themarketplace. We compete vigorously, fairly, and with the highest standardsof integrity. We earn our success by producing safe, high-quality, andwholesome products.
You should never enter into an agreement or an understanding (even informal)
with a competitor to do any of the following, as this activity would be an
antitrust violation:• Fix prices for our products, oursupplies, or wages and salaries• Limit production• Rig a competitive bidding process• Prevent another company, or
person, from entering the market• Refuse to deal with a customeror supplier, including potential
employees, for improper reasons• Boycott another company or person(s)• Divide markets, customers,
or territories

In addition, do not discuss or exchange information with competitors (orpotential competitors) about topics such as pricing, terms or conditions ofsale, costs, wages and salaries, market segments, customers, or marketingstrategies. If you are ever part of any communication where these topics are
discussed, immediately remove yourself from the situation and contact theLegal Department.
Antitrust laws are complex and vary from country to country. Penalties
for violations are severe and can result in crippling fines and criminal
penalties, including prison sentences for individuals, and costly civil litigation.
Consult with the Legal Department if you have questions about a potential
antitrust issue.
Read the Antitrust Compliance Policy for more information.
CONNECT THE CODE
Trade association activities can be valuable ways to promote industry
interests or legislative initiatives. However, you should not discuss
pricing or other competitive activities with competitors.
Patrick AllenDFA employee | Kansas City, Kan.

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CONNECT THE CODE
Bribe – When someone gives orpromises something of value togain favorable treatment.
Corruption – The abuse of
power for personal gain.
Kickback – Giving or receiving
personal payments as a reward
for awarding a contract oranother favorable outcome to acustomer or supplier.

ANTI-CORRUPTION AND ANTI-BRIBERY
DFA does not tolerate acts of bribery or corruption. Giving, offering, or taking
a bribe or a kickback of any kind, directly or indirectly, is strictly prohibited.
DFA employees should never offer or accept anything of value to gain or keepbusiness, influence a business decision, or expedite a process. We hold third
parties doing business on our behalf to these same standards.
A bribe may not always be obvious and can come in many forms, including the following:• Gifts• Travel or entertainment• Meals• Discounts• Favors• Education or employment opportunity• Cash or cash equivalents• Charitable or political contributions

CONNECT THE CODE
Bribery and corruption canhappen anywhere, but it
tends to be a higher risk ininternational operations
and transactions, especiallywhen dealing with foreign
government officials.

Read the Anti-Corruption and Anti-Bribery Policy for more information.

CONNECT THE CODE
Employees may make or receive
permissible gifts, which are those that:• Are of nominal value• Are customary in the industry• Are consistent with theemployee’s position 		and authority• Do not violate any laws
• Will not influence or appear
to influence the employee’s
judgment or conduct

GIFTS
Employees should be cautious about giving and accepting gifts, meals, andentertainment (“gifts”) in the workplace. Accepting gifts can create a conflictor the appearance that an individual is putting their personal interests ahead ofDFA’s best interests. Inappropriate gifts include those that create an obligation,
are in the form of cash or cash equivalents (including gift cards), or appear to belavish or extravagant.
You should always be aware of how the act of accepting a gift or gratuity might
be perceived by other customers, suppliers, or employees. If you have a question
about whether to accept or give a gift, talk to your supervisor.
Read the Gift Policy for more information.

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COMMODITY
TRADING

INTERNATIONALTRADEDFA enters into various types oftransactions to protect the Cooperativefrom potential financial losses due toprice fluctuations in the commodity
markets. These transactions may include
physical purchases and sales, such as
spot and forward contracts, as well as
options, swaps, and futures contracts.
Different regulations apply to different
categories of transactions.

As a global organization, we are subject
to trade compliance laws that vary widelyaround the world. Our international
business transactions are subject toregulations such as: government-imposed
export controls, trade restrictions, tradeembargoes, legal economic sanctions,and anti-boycott laws. Failure to comply
can seriously impact our business andreputation, lead to significant fines, andresult in the loss of our export privileges.

DFA’s Risk Management Department is
responsible for managing all regulatedcommodity trading activity to ensuretransactions comply with applicable laws
and regulations.
If you become aware of trading activity
that is not being handled by DFA Risk
Management, you should Raise It.

We have individuals in the organization
with trade expertise. These individuals
are responsible for supporting tradecontrol practices and operations. They
provide guidance with the movementof goods across international borders.
Contact the Ethics and ComplianceDepartment if you need assistance.

Read the Commodity Trading Policy 		
for more information.

Read the International Trade Policy 		
for more information.

SUPPLIER CODE OF CONDUCTWe seek to do business with organizations that will uphold our highstandards of responsible and ethical behavior, and act in ways that
positively reflect on our Cooperative. We choose suppliers carefullyand expect them to operate in compliance with the law and in a waythat is consistent with our Code, our policies, and our values. Our
Supplier Code of Conduct sets forth these standards and expectations.
Read the Supplier Code of Conduct for more information.

CONNECT THE CODE
Trade sanction laws regulate
where and with whom we cando business. Prior to executing
a transaction, third parties
involved in the transaction
are screened against the lists of“Restricted Parties” to ensure
we are able to proceed.

We are prohibited fromparticipating in foreign
boycotts not sanctioned by
the United States. Any such
request must be immediately
reported to the Ethics andCompliance Department.

When selecting suppliers, practice appropriate
due diligence. Evaluate potential suppliers
based on legitimate business criteria, such as:• Safety• Quality• Cost• Service• Reputation andintegrity• Availability andresponsiveness• Financial stability

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5.

DFA employee | Kansas City, Kan.

WE VALUE INTEGRITYIN OUR COMMUNITIESTaking care of our planet and our communities is not just an initiative — it is a responsibility that is taken to heart. At DFA,
we are constantly focused on finding new, innovative ways to conserve resources, reduce waste, and work efficiently
on farms, in our facilities, and on the road. We also encourage our employees to be active in their communities and toparticipate in the political process.

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POLITICAL ACTIVITIESDFA is committed to actively engaging in the politicalprocess to protect and promote the interests of the
Cooperative, its business, farmer-owners, and employees.
We support employees who choose to participate in
civic and community activities, including the politicaland democratic process. All political, lobbying, and civic
activity must comply with applicable laws. Use of DFA
resources (such as its facilities, email, or trademarks)
for personal political activities is prohibited. Any such
personal activities must not suggest the Cooperative’s
support. As an example, employees must not reference
their DFA role, title, or employment when making
personal political comments or conducting personal
political activities, whether in-person or online.
DFA has established a political action committee(“DFA PAC”) to ensure that our farmer-owners’ interests
are heard. The DFA PAC is registered with the Federal
Election Commission and governed by members ofDFA’s Board of Directors. The DFA PAC is fundedby personal, voluntary contributions from eligible
Cooperative employees and farmer-owners. The DFA PAC
makes political contributions on a nonpartisan basis topolitical parties, political committees, and candidates.
All contributions are made and reported in accordancewith applicable federal finance laws.

CONNECT THE CODE
Employees have the right to participate in the political process
by making personal contributions, subject to applicable legal
limits and requirements. DFA will not reimburse anyone for
personal political contributions or expenses.

SUSTAINABILITYAs leaders in sustainability, we are committed to responsible
production while helping our employees and farmer-owners
thrive, caring for the planet, and enriching communities andthe lives of consumers through all of the possibilities of dairy.
Sustainability is key to the longevity and growth of ourbusiness and our family farms. That’s why we are constantly
researching and re-evaluating best practices to benefit theenvironment and the world.

ENVIRONMENTAL
PROTECTION
We take our responsibility to be good environmental
stewards seriously. We believe it is in the best interest of
our Cooperative and communities to operate DFA facilities
in a manner that controls and minimizes the emissions ofwastewater, air contaminants, and solid waste.
To support our commitment to environmentally soundpractices, we have implemented programs that comply withthe requirements set forth by the environmental laws andregulations that govern our operations.
Read the Environmental Policy for more information.

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We all have an individual responsibility to carry out business activities inaccordance with the highest standards of ethical conduct. If you suspect 		
any illegal, unethical, or improper conduct, use the Raise It process.
Report concerns to:• A supervisor or any member of management• A member of the Human Resources, Internal Audit, 				or Legal Departments• The Ethics and Compliance Department 					at RaiseIt@dfamilk.com or 833-852-2020• The Integrity Helpline at 1-855-RaiseIt (1-855-724-7348) 			
or at dfamilk.ethicspoint.com (provides an option to report anonymously)This commitment and dedication to being ethical benefits our hardworking
farmer-owners and helps cultivate a community bound by shared values. The
choices we make affect our farmer-owners, and it is our responsibility to act withintegrity — for everyone, every day, every way.

Integrity Helpline 1-855-RaiseIt
www.dfamilk.ethicspoint.com
RaiseIt@dfamilk.com
Click to view the policies online.