Code of Ethics for Senior Corporate Officers
ConAgra Foods is committed to complete and accurate financial disclosure in compliance with applicable laws and regulations. This Code of Ethics is applicable to our chief executive officer and senior corporate financial officers. Our senior corporate officers are also subject to the provisions of our Code of Conduct which is applicable to all of ConAgra Foods' employees.
Our senior corporate officers to whom this Code of Ethics applies are our chief executive officer, chief financial officer, and controller.
Our senior corporate officers shall, in the performance of their duties for ConAgra Foods, to the best of the officers' knowledge and ability:
- Act with honesty and integrity, and ethically handle any actual or apparent conflicts of interest between personal and professional relationships.
- Disclose to the Audit Committee any material transaction or relationship that could reasonably be expected to give rise to a personal conflict of interest.
- Provide, or cause to be provided, full, fair, accurate, timely and understandable disclosure in reports and documents that ConAgra Foods files with, or submits to, the Securities and Exchange Commission and in other public communications made by ConAgra Foods.
- Comply with applicable government laws, rules and regulations.
- Maintain the confidentiality of information acquired in the course of the performance of his or her duties and not use such confidential information for personal advantage.
- Use, or cause to be used, all corporate assets entrusted to such officer in a responsible manner and in the best interests of ConAgra Foods.
- Promote, as appropriate, the provisions of ConAgra Foods' Code of Conduct relating to the reporting by employees of improper accounting or financial reporting without fear of retaliation.
- Promptly report any violations of this Code of Ethics to the Audit Committee, and promote the prompt reporting of violations of the company's Code of Conduct to the persons identified in that Code.
The Audit Committee shall determine, or designate appropriate persons to determine, remedial actions to be taken in the event of a violation of the Code of Ethics. Such actions shall be reasonably designed to deter wrongdoing and promote accountability for adherence to the Code of Ethics. The Board of Directors has full and discretionary authority to approve any amendment to this Code of Ethics for senior corporate officers; any such amendment shall be promptly disclosed as required by applicable law or regulation.
