Compliance & Ethics

Compliance & Ethics

At ADM, we believe in making a positive impact.

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High Standards & Expectations

At ADM, we believe in leading by example, setting a global standard for “good business” that other companies in our industry will follow.

In March 2022, we were recognized by Ethisphere, a global leader in advancing the standards of ethical business practices, as one of the 2022 World’s Most Ethical Companies™, marking the third consecutive year we have received this recognition.

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.

Our 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, business partners, shareholders and communities.

We prohibit 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 employees and 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 version of the policy which was published 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. We encourage employees 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. We also added a QR Code in 2021 to further enhance accessibility to our Helpline. Reporting via the Helpline can be done anonymously, where permitted by law. We do 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 wellbeing 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 2021, we received a total of 1077 reports, concerning topics such as 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 review into the concerns raised. If an allegation is substantiated, we implement corrective and disciplinary actions which can include coaching and counseling, process or control improvement, verbal or written warnings, financial penalties, or termination.

Training is a key component of our compliance program. In 2021, employees completed required training on topics such as business integrity, antitrust and competition law, insider trading and human trafficking. Above and beyond our global annual required training, Compliance also led dozens of trainings sessions for targeted employee populations.

We published over 80 global and regional compliance communications in 2021 to improve employee understanding of ethics and compliance expectations, enhance awareness of compliance risks, provide guidance on courses of action, and increase transparency into how ADM investigates and remediates issues of concern. The communications covered topics such as anti-corruption, data privacy and records retention, conflicts of interest, trade sanctions, speaking up, and more. We also launched the Compliance Compass, which is an internal bi-monthly awareness campaign that features case studies highlighting real-world, anonymized compliance and ethics challenges faced by ADM colleagues.

We conducted eight virtual Vendor Compliance sessions to manage risk related to our third-party relationships around the world. In these sessions, regional business leaders and compliance personnel provided training and engaged in rich discussions with approximately 300 vendors, joint venture 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 our behalf, in 2021 we conducted 16 compliance audits of third-party intermediaries around the world.


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