Mondelez International, Inc.

CODE OF BUSINESS CONDUCT AND ETHICS FOR NON-EMPLOYEE DIRECTORS

We have adopted a Code of Business Conduct and Ethics for Non-Employee Directors that is designed to foster a

culture of honesty and integrity, focus on areas of ethical risk, guide non-employee directors in recognizing and

handling ethical issues, and provide mechanisms to report unethical conduct. Annually, all non-employee directors must

acknowledge in writing that they have received, reviewed, and understand the Code of Business Conduct and Ethics

for Non-Employee Directors.

EMPLOYEE CODE OF CONDUCT

We have adopted the Mondelēz International Code of Conduct (the “Code of Conduct”) for all our employees, which

reflects our values and contains important rules for conducting our business. The Code of Conduct is part of our global

compliance and integrity program, which provides training throughout the Company and encourages reporting of

potential wrongdoing through anonymous reporting options and a publicized non-retaliation policy.

The Chief Ethics & Compliance Officer provides an annual report to the Audit Committee on the overall implementation

and effectiveness of Mondelēz International’s Compliance program and provides quarterly updates to the Audit

Committee on Code of Conduct compliance, investigation trends, and training activities. The Chief Ethics & Compliance

Officer also provides an annual report to the PCC on workplace compliance-related matters. The Chief Ethics &

Compliance Officer reports to the EVP, Corporate & Legal Affairs, General Counsel and Corporate Secretary and has

the authority to communicate directly with the Audit Committee regarding alleged or actual violations, if any, of the Code

of Conduct.

WHERE TO FIND MORE INFORMATION

To learn more about our corporate governance practices, you can access the corporate governance documents listed

below atwww.mondelezinternational.com/investors/corporate-governance. We will also provide copies of any of

these documents to shareholders upon written request to the Corporate Secretary.

•Articles of Incorporation

•By-Laws

•Guidelines

•Board Committee Charters

•Code of Business Conduct and Ethics for Non-Employee Directors

You can access the Code of Conduct atwww.mondelezinternational.com/about-us/our-way-of-doing-business/

code-of-conduct.

We will disclose in the Corporate Governance section of our website any amendments to the Code of Business

Conduct and Ethics for Non-Employee Directorsor the Code of Conduct, and any waiver granted to an executive officer

or director under these codes, within four business days of such amendment or waiver to the extent required.

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CORPORATE GOVERNANCEReview of Transactions with Related Persons