SYSCO CORP
For the period ended Oct 3, 2024. Filed Oct 3, 2024.
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Oct 3, 2024 · Filed Oct 3, 2024
Contents
GLOBAL CODE OF CONDUCT
Our Global Code of Conduct (the “Code”) is guided by our
values and expectations which we believe are important to
delivering exceptional service with the highest degree of
integrity. We require all of our directors, officers and
colleagues, including our CEO, Chief Financial Officer, and
Chief Accounting Officer, to understand and abide by the
Code, as it represents our commitment to conduct our
business with the highest standards of moral and ethical
behavior in accordance with our values: Rooted in Integrity,
Committed to Inclusion, Drive Together, Define Excellence,
and Grow Responsibility.
The Code addresses the following, among other topics:
fraud;
anti-corruption and anti-bribery;
export/import laws and trade sanctions;
human rights;
diversity equity, and inclusion;
workplace safety;
antitrust;
competition and fair dealing;
professional conduct, including customer relationships, equal
opportunity, and receipt of payments and gifts;
political contributions;
conflicts of interest;
insider trading;
financial disclosure;
intellectual property; and
confidential information.
The Code, which is reviewed periodically by our Governance
Committee, requires strict adherence to all laws and
regulations applicable to our business and requires employees
to report any violations or suspected violations of the Code. We
have published the Code on our website in the Overview
section under “Investors—Corporate Governance” at
www.sysco.com. We intend to disclose any future amendments
to or waivers of our Code on our website atwww.sysco.com
under the heading “Investors—Corporate Governance.”
Reporting a Concern or Violation
Our Code explains that there are multiple channels for an
employee to report a concern, including to a colleague’s
manager, a human resource professional, our Global Ethics
and Compliance department, or to the Sysco Ethics Line. Our
Ethics Line is available 24 hours a day, 365 days a year,
worldwide, to receive calls or web submissions from anyone
wishing to report a concern or complaint, anonymous or
otherwise. Our Ethics Line contact information can be found on
our website atwww.sysco.com under the heading “About
Sysco – The Sysco Story – Sysco Global Code of Conduct.”
Our Senior Vice President, Legal, General Counsel and
Corporate Secretary or Vice President, Chief Compliance
Officer are responsible for informing the Chair of our Audit
Committee of reports or allegations of impropriety relating to
our accounting, internal controls, or other financial or audit
matters. All such matters are escalated, investigated and
responded to in accordance with the procedures established by
the Audit Committee to ensure compliance with the
Sarbanes-Oxley Act of 2002.
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