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Commitment to Ethical Conduct and Anti-Corruption Compliance

ADM is committed to doing business with integrity. This means avoiding corruption in all forms, including bribery. We abide by all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and local laws in every country in which we do business.

ADM has an Anti-Corruption Program intended to provide a level of awareness about anti-corruption laws in order to avoid inadvertent violations of the law and to enable employees to recognize potential issues in time for these to be addressed appropriately. Our Anti-Corruption Program encompasses compliance procedures and key controls designed to minimize the potential for corruption in ADM’s global business dealings. The Anti-Corruption Program protects the company from anti-corruption risks in the context of:

  • Commercial transactions with government entities and government employees;
  • Hosting and gifting provided to government entities and government employees;
  • Government tenders and private tenders;
  • Hiring current or former government employees;
  • Due diligence on third parties with which ADM does business;
  • Donations and contributions;
  • Political contributions;
  • Commercial bribery and extortion;
  • Due diligence in the context of mergers, acquisitions, joint ventures and investments;
  • Anti-corruption training;
  • Anti-corruption auditing;
  • Anti-corruption monitoring; and
  • Maintaining accurate books and records.
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