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Compliance and Ethics

At ADM, we believe in making a positive impact.

In February 2021, ADM was recognized by Ethisphere, a global leader in advancing the standards of ethical business practices, as one of the 2021 World’s Most Ethical Companies. This marks the second consecutive year ADM has received this recognition, which honors companies who understand the importance of leading and prioritizing ethical business performance, and have demonstrated an overall commitment to integrity.

We maintain high ethical standards across our global workforce. We expect employees to take responsibility for their actions and adhere to our values of honesty and integrity, consistent with our commitment to always conduct business fairly and ethically.

ADM has established a corporate governance and oversight process whereby leaders from compliance, internal audit and risk management meet quarterly with the board of directors and members of ADM’s executive committee. These meetings ensure company leadership is aware of key risks and related risk mitigation efforts, drive alignment with the company’s strategic priorities, and help protect shareholder interests.

ADM’s Code of Conduct guides us on how to make sound decisions and illustrates proper actions for conducting our businesses. Our Code promotes a shared understanding of what achieving the right results the right way means. By knowing and following our Code, each of us does our part to maintain and further build trust with our various stakeholders—including our colleagues, customers and business partners, shareholders and communities.

ADM prohibits all forms of corruption, including bribery, and we abide by all anti-corruption laws in every country we do business. We have a robust anti-corruption program that includes a global Anti-Corruption Policy and other compliance procedures and controls designed to minimize the potential for corruption in ADM’s global business dealings, such as enhanced due diligence, screening, monitoring of high risk third parties, and pre-approvals before hosting or entertaining government officials. We train our employees and high-risk third parties to raise awareness of corruption risks and applicable anti-corruption laws in order to both avoid inadvertent violations of the law and enable early recognition and handling of potential issues. Our Anti-Corruption Policy is updated periodically to address new risks and incorporate continuous enhancements, including an updated policy in 2021.

We have a strong “Speak Up” culture at ADM, which helps us handle issues and address problems in a timely manner, building trust with one another and with our customers, suppliers and business partners and protecting the company from legal, financial and reputational risks. Employees are encouraged to voice concerns or ask questions through multiple channels, including by talking with their supervisors, Human Resources, or Compliance, or at any time through additional reporting channels such as The ADM Way Helpline, which is available by phone or web in more than 30 languages. Reporting via the Helpline can be done anonymously, where permitted by law. ADM does not tolerate any form of retaliation for making a good-faith report of actual or potential misconduct. The ADM Way Helpline may also be used by stakeholders outside of ADM to raise questions or voice concerns.

We feel a deep and genuine regard for the safety and well-being of all people, communities and resources, and we treat them with care and consideration. We demonstrate trust and openness. And, we are good stewards of the environment. Our Human Rights Policy protects human rights defenders, whistleblowers, complainants and community spokespersons from any form of retaliation.

In 2020, we received a total of 968 reports, concerning topics like employee relations, environmental, health and safety (EHS), diversity, equal opportunity and respect in the workplace, and misuse or misappropriation of assets or information. We log and track all reports we receive. Each is classified by type and then assigned to an investigator to conduct an independent and objective investigation. If an allegation is substantiated, we implement corrective actions which can include coaching and counselling, process or control improvement, verbal or written warnings, or termination.

Employee and business partner training are important components of our compliance program. In 2020, all employees completed required compliance training on topics such as anti-corruption, conflicts of interest, data privacy and protection, and speaking up.

COVID-19 continued to impact the way we live, do business and communicate during these extraordinary times. To more effectively manage risk related to our third-party relationships during the pandemic, we enhanced our existing third-party training program by conducting 21 virtual Vendor Compliance sessions around the world. In these sessions, regional business leaders and Compliance personnel provided training and engaged in rich discussions with approximately 580 vendors, JV partners, customers and other business partners on topics such as anti-corruption, conflicts of interest, accurate books and records, supplier expectations, human rights, privacy, security, and sustainability. And consistent with our commitment to ongoing compliance monitoring of third-party service providers acting on the company’s behalf, in 2020 ADM conducted 24 compliance audits of third-party intermediaries around the world.