Our customers, suppliers and other business partners count on us to build strong, honest relationships that satisfy the demands of the marketplace.





Sara Lee will always compete fairly. Our commitment to responsible practices is a source of business strength because it builds our reputation as a trustworthy company. Unfair business practices go against our values, can damage our reputation and will not be tolerated.

Unfair business practices may involve:

• Intentionally cutting off a competitor’s source of supply.
• Pressuring customers to break contracts with competitors.
• Requiring a supplier to buy from our company before we will buy from them.

If you encounter a potentially unfair business practice, speak with the law department. Every employee is responsible for raising questions or concerns about potential issues before they happen.



Sara Lee will respect the confidential information provided to us by our customers, suppliers and other business partners.

Competitive information will be obtained legally and ethically. Stealing proprietary information, accepting disclosures of proprietary information by a competitor’s past or present employees, misrepresenting one’s identity and acting in a way that could create the appearance of an improper agreement with competitors are prohibited.

“I think Sara Lee could strengthen good ethics, by recognizing those who chose to do the right thing. It seems like we only hear of those who chose poorly.” – Mexico

Antitrust laws in the United States, competition laws of the European Union, and various laws in many other countries where Sara Lee does business, encourage companies to compete aggressively to increase their sales, market share, and profits. Sara Lee believes in free and open competition, and fully complies with these laws.

Actions that may limit competition, such as those listed below, always should be specifically reviewed in the context of the local country’s laws.

• Entering into any formal or informal arrangement, understanding or agreement with competitors that fixes prices, or allocates production, sales territories, products, customers or suppliers.
• Agreements with customers and suppliers that establish the resale price of a product, limit a customer’s right to sell product, or condition the sale of products on an agreement to buy other Sara Lee products.
• Decisions to terminate business relationships, pricing of a product below cost, and certain other pricing and promotion policies, especially when we have a substantial share of the market.
• Exchanging information with competitors regarding pricing, marketing, production or customers.
• Charging different prices to similarly situated customers.

It is the responsibility of any individual who has a question about these issues or any other discussion, decision or action that has potential antitrust implications to consult with the law department before such action has taken place. Training and more detailed information are available from the law department for any employee who has a question or concern.

In 1753 a carpenter’s son named Egbert Douwes and his wife Akke opened a grocery store in a village in the Netherlands. Imagine the temptations for a struggling shopkeeper of the time. A false weight. A coin short in making change. A few bad coffee beans mixed in with the good. A promise broken. Egbert Douwes, and later his son Douwe Egberts, must have known that these shortcuts to profitability would not pay. The Douwe Egberts name became one people could count on. It still is. – The Netherlands

Sara Lee believes in doing business with those suppliers, contractors, joint venture partners, agents, sales representatives, distributors and consultants who embrace and demonstrate high standards of ethical and responsible business behavior. All people or companies engaging in ongoing or material business relationships with Sara Lee should receive a copy of the Global Standards for Suppliers and are expected to adhere to those standards.

Sara Lee will not knowingly use suppliers who operate in violation of applicable laws or regulations, including local environmental, employment, or safety laws. Sara Lee also will not knowingly do business with suppliers who employ non-family members under the age of 15, employ forced labor, or use corporal punishment to discipline employees, regardless of whether such practices are permitted by applicable law. Sara Lee will exercise diligence to determine whether suppliers conform to these standards.

Sara Lee will favorably consider competitive suppliers who demonstrate a commitment to innovation, continuous improvement and sustainability, including positive contributions to employee education and betterment, the environment, and their communities. Additionally, Sara Lee seeks diversity in the ownership, leadership and employment practices of its suppliers.

“The Mirror Test is an excellent resource. Continue to get the message out that unethical behavior will not be tolerated.” ; – USA

Obtaining competitive bids, verifying quality and service claims on a regular basis, and confirming the financial and legal condition of the supplier are all important steps in a good purchasing decision. Agreements should be written and clearly set forth the services or products to be provided, the basis for earning payment, and the applicable rate or fee. The amount must not be excessive in light of industry practice and must be commensurate with the services provided. Only authorized individuals may enter into agreements on behalf of Sara Lee.



In many industries and countries, gifts and entertainment are used to strengthen business relationships. Throughout the world, one principle is common and clear: No gift, favor or entertainment should be accepted or provided if it will obligate or appear to obligate the recipient.

Gifts or entertainment may be provided if they are reasonable complements to business relationships. Gifts or entertainment may not exceed $250USD in value, unless approved in advance by your business practices officer. No gift or entertainment may be provided that is against the law or the policy of the recipient’s company. Gifts and entertainment may not be provided to government officials or employees. The law department and Sara Lee’s policy on Doing Business with the Government should be consulted for guidance. Offering or providing bribes or kickbacks is prohibited in all circumstances.



Accepting occasional and modest gifts and entertainment may be appropriate in developing business relationships. Gifts and entertainment should further the business interests of Sara Lee, and not be lavish or in excess of the generally accepted business practices of one’s country and industry. Employees may not accept gifts, favors or entertainment valued at more than $250USD in any fiscal year from the same company. Acceptance of gifts or entertainment that exceeds the $250USD limit requires the prior approval of your business practices officer.

Requesting or soliciting personal gifts, favors or entertainment is unacceptable. Also, accepting gifts of cash or cash equivalents is never acceptable. Additionally, employees may not exploit their position to solicit vendors, including financial institutions, to provide individual preferential treatment in pricing, terms, or loans.

Recipients of prohibited gifts or favors should let management know and return the gift with a letter explaining Sara Lee policy. If a gift is perishable or impractical to return, management should distribute it to employees or donate it to charity, with a letter of explanation sent to the donor.



Any business unit may adopt lower ceilings, taking into consideration local standards and customs.

I was responsible for getting a new facility built, but the local authorities would not provide the necessary permits without receiving “special consideration.” This made me upset. Not only is bribery bad for our country, once you start paying, you get a reputation for doing so and can never get anything done cleanly again. So I went several layers higher in the government and explained how the community was losing out of jobs and investment because of the delays. I received my permits—without bribes—a few days later. – Philippines

I was invited to a world-cup football match by one of our suppliers. It was an incredible offer—all travel and lodging paid for in a very nice hotel. My friends—who know how much I love football—thought I was crazy to even hesitate. But I decided to discuss whether I should go with my Business Practices Officer. Together we decided that it was better to decline. – Italy