CODE OF ETHICS

MESSAGE FROM THE CHIEF EXECUTIVE OFFI CER

The vision of Pioneer Foods is to be a leading food and beverage company through globally trusted brands. This can only be achieved if we adhere to the values of the company and commit
ourselves to ethical behaviour and good corporate governance. Our aspiration is to be regarded as an ethical and responsible corporate citizen by all our stakeholders. Such a reputation
can only be earned through dedication and commitment to ethical practices by everyone in the organisation.
The Social and Ethics Committee of the Board of Directors has approved this revision, and it was ratified by the Board at its meeting on 17 October 2013. As the leadership of the firm, we
realise that this code will only be effective if we are seen to be setting the right tone at the top. As such I want to give you my personal commitment that I will use our company values to
guide my actions and decision-making and expect the same from you.
I request all our stakeholders to familiarise themselves with the content of this code, to adhere to it on a daily basis and to report concerns or knowledge about misconduct to our
independent hotline (Tip-offs Anonymous).
If you have any questions or require additional information, do not hesitate to contact the Executive Manager: Corporate Affairs & Sustainability / Company Secretary / Line manager or your
supervisor.
Phil Roux
Chief Executive Officer
17 October 2013
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WHAT IS OUR CODE OF ETHICS?
Our Code of Ethics is the most important policy document in the Company. It defines and communicates acceptable and expected behavioural standards for Pioneer Foods. By providing
guidelines our Code of Ethics empowers each of us to make decisions based on our core values.
The purpose of our Code is therefore to guide us in the way we conduct business and enhance our reputation with our stakeholders.
WHAT IS ETHICS?
Ethics and morality (these terms can be used interchangeably) refer to that which is good or right in human interaction. Ethics involves three key, interlinked concepts self, good, and
other. Thus ones conduct is ethical if it gives due consideration not only to that which is good for oneself, but also good for others.
Business ethics refers to the ethical values (the good) that determine the interaction between a company (the self) and its stakeholders (the other).
OUR VISION, VALUES AND STAKEHOLDERS
Our vision is to be to be a leading food and beverage company through globally trusted brands. This provides us with purpose and direction. To continue on our path of being a sustainable
company, we have to ensure that our values permeate all our activities, interactions and decisions.
Our core values are:
Integrity
Passion
Consumer / Customer Focus
Development and Recognition of People
Accountability and Commitment
Adaptability
The Pioneer values should always guide all our actions and decisions. Although they are all important, some values are specifically relevant with regards to particular stakeholder groups, as
indicated in the table below.

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Stakeholder Group












Critical relevance to stakeholder group Important relevance to stakeholder group Limited relevance to stakeholder group
Although our values are powerful, we recognize that guidance might be required to apply them practically. Pioneer Foods therefore developed a set of practical guidelines to assist you to
live our values with Passion.

PRACTICAL GUIDELINES
Consumers Customers Employees Shareholders Communities

Government

Competition

Suppliers
Integrity
Passion
Consumer / Customer Focus
Development and
Recognition of People

Accountability and
Commitment

Adaptability
Values
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As a minimum requirement, the laws of the country should always be adhered to. But ethical behaviour should go beyond legal compliance. The practical guidelines in this section should
always be consulted and if in doubt contact the Corporate Affairs & Sustainability Department / Company Secretary / line manager or your supervisor. Where appropriate, reference is
made to a more detailed HR policy. All references to Pioneer Foods are applicable to all group companies.

VALUE ETHICAL ISSUE PRACTICAL GUIDELINE RELEVANT POLICY
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INTEGRITY Conflicts of interest Employees will sometimes be confronted with a conflict between their personal interests and the
interests of the company. Conflicts should preferably be avoided but where they occur should be
declared and managed properly. Examples of potential conflicts that should be avoided are:
Giving or receiving gifts or entertainment of excessive value
Having a second job without proper disclosure and / or authorization
Having an undisclosed financial interest (direct or indirect, e.g. through a spouse or close
family member) in a supplier or business partner of Pioneer Foods
HRPP01B: Conflict of
Interest
Bribery, corruption, theft
and fraud.
No form of bribery, corruption, theft or fraud will be tolerated. This includes petty theft the
principle is regarded as more important than the potential loss to the company. The Prevention and
Combating of Corrupt Practices Act clearly defines the offense of corruption, and training programmes
will assist employees to develop a good understanding of the legal requirements in this regard. Any
activity that falls within this category is illegal and could lead to summary dismissal. In addition,
Pioneer will provide full cooperation with the authorities to assist criminal investigations.
LAW_POL 003 Whistle
Blowing Policy
HRPP11- Employee
Relations

HIV / Aids The company has adopted a code of good practice regarding HIV/AIDS.
The code aims at creating a caring, non-discriminatory work environment in which people living with
HIV or AIDS are able to be open about their health status without fear of stigma or rejection.
At the same time, it aims to create a balance between the rights and responsibilities of all parties in
the workplace. We have conducted an HIV / AIDS Risk Analysis and undertake to review its impact on
our business.
HRPP-10A HIV AIDS
CoGP.doc
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VALUE ETHICAL ISSUE PRACTICAL GUIDELINE RELEVANT POLICY
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Sexual harassment Pioneer Foods regards sexual harassment as harmful to the working environment. It can also have
distressing effects upon health; confidence, morale, performance and productivity of those affected
by it. All employees have the right to work in a pleasant and productive work environment where
individual rights and the dignity of each employee are respected. This includes the right to work in an
environment that is free from sexual and other forms of harassment. Furthermore, all employees
share the responsibility for fostering a pleasant working atmosphere, which allows optimum
performance and productivity.
HRPP-11K Sexual
Harassment.doc
Recruitment and selection Pioneer Foods seeks to attract the best available potential from the labour market.
It seeks to ensure an equitable, fair and just identification of individuals with a particular focus on
employees from designated groups (meaning black people, women and people with disabilities)
whose competencies meet the present and future requirements of the Company.
HRPP05- Recruitment &
Selection
Confidentiality of
information
Personal information (being any identifiable information relating to a person) disclosed via Pioneer
Foods' ICT resources will be secured using such technical and organisational measures as are
reasonable and appropriate.
Personal information will only be collected for the lawful purposes of Pioneer Foods, as defined from
time to time.
Pioneer Foods information must at all times be protected in a manner commensurate with its
sensitivity and criticality.
IT_POL001



CONSUMER /
CUSTOMER FOCUS AND
PASSION
Customer service and
complaints
We pride ourselves and are committed to providing consistently the highest levels of service to our
customers and the consumers of our products. We promise to address each and every complaint with
the necessary urgency. We take all complaints very serious and have thus developed a complaints
management guideline to which each division must adhere.
Complaints Management
Guideline (Legal Doc)
Divisional Customer
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Some of the divisions outsource complaints management to independent contractors but retain
responsibility to ensure that these comply with Group guidelines.
As part of this process the complainant is kept informed of any delays or progress made regarding
their complaints.
Complaints Procedures


Fair treatment of
customers and other
external stakeholders
We commit to treating all external stakeholders in an even-handed and fair manner. This means that
we do not judge people; we remain objective in our dealings and guard against favouritism.

Stakeholder Relations
Policy

DEVELOPMENT AND
RECOGNITION OF
PEOPLE
Training & development We believe in growing our own timber. It enables individual career growth and enhances business
performance through maximizing skills and potential. We focus on capacity building to enable
business sustainability.
Learning, development solutions and interventions include, but are not limited to; leadership
development, functional competence development, skills acquisition, mentoring & coaching, study
assistance, on-the-job training, multidisciplinary & cross divisional projects, job enlargement/
enrichment, secondments, international assignments, and other operationally directed activities.
HRPP09: Learning and
Development
HRPP04 Talent
Management
Salaries & wages We believe in adopting the principles of a standard approach to our application of remuneration
practices within all the companies business units and functions.
HRPP07:Recognition,
Reward, and Benefits;
Fair treatment of all
employees
Human Resource policies define the relationship between the company and employees and aim to
ensure fair and consistent treatment of all. This includes fairness in terms of job levels and job
descriptions within different divisions and an equitable spread of workloads. These policies also
reflect dynamic changes taking place in the South African workplace, with increasing focus on issues
such as employment equity, affirmative action and training and development.
HRPP06- Conditions of
Service
HRPP05: Recruitment and
Selection;
HRPP03: Transformation;
HRPP09: Learning and
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Development
Employee Wellness
Pioneer Foods would like to ensure that it has well motivated, healthy and committed employees who
are equipped with the adequate life skills to make a meaningful contribution to the sustainability of
the business and society in general. Through its Wellness Awareness Programme the company
attempts to create awareness and promote healthy living through education and training, to provide
employees with the necessary life skills to improve their quality of life, to pro-actively reduce the risks
of health related claims and level of absenteeism and to promote productivity through a more
knowledgeable, healthy and empowered workforce.

HRPP 10: Employee
Wellbeing
Alcohol & Drug Abuse In the interest to the safety of our staff and plant, no employees are allowed to enter Pioneer Foods
premises for the purpose of conducting work while under the influence of alcohol or drugs.
HRPP11- Employee
Relations
HRPP-10C Substance
Abuse.doc

ACCOUNTABILITY AND
COMMITMENT
Supplier guides We expect all our suppliers to act in and ethical and responsible manner in their business dealings. We
expect all suppliers to ensure the following:
Legal compliance
Ensure they comply with all relevant legislation
Employment practices
Ensure they hold health and safety in the highest regard.
Suppliers will respect each employees right to freedom of association and the effective recognition to
the right to collective bargaining.
UN Global Compact
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Eliminate and not partake in any forms of child, forced and compulsory labour practices.
Not discriminate in respect of employment and occupation.
Human Rights
Ensure they are not implicit in any form of human rights abuse and that they support, respect and
protect internationally proclaimed human rights.
Environment
Ensure compliance with all relevant environmental legislation.
Strive toward minimizing its impacts on the environment.
Anti-Corruption
Not engage in any form of corruption activities.
Transformation BBBEE Credentials
Ensure our suppliers implement meaningful transformation as measured and reported through their
relevant SANAS approved scorecards.
Media Statements All official requests for media statements should be referred to the Executive Manager: Corporate
Affairs and Sustainability. The relevant Business Executive will also be in a position to make
statements to media and brand related statements should be referred to the relevant Brand Manager.
Employees should refrain from discussing official Pioneer Foods business with the media and refer
them to the media contact.
Media contacts can be found on the Pioneer Foods website at http://www.pioneerfoods.co.za

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Stakeholder relations






We believe in conducting business truthfully and openly and will engage with numerous stakeholders
through an inclusive and interactive model of reporting, as shown below:

Stakeholder & Engagement Methods

Shareholders and investors: Results presentations, one-on-one meetings, investor relations functions.

Employees: Staff magazine, internal and external electronic communication channels, management
presentations

Communities: Various CSI initiatives

Government and regulators: Various CSI initiatives

Supplier: On-going interaction in the course of doing business

Customers: On-going interaction in the course of doing business

Stakeholder Relations
Policy
Investor Relations We believe in conducting our business truthfully and openly and to ensure consistent messages are
communicated. All investor related queries i.e. financial performance, disclosures; etc. should be
directed to our Chief Executive Officer or Financial Director.
Investor relations contacts can be found on the Pioneer Foods website at
http://www.pioneerfoods.co.za

Fair competition Any form of price fixing, bid rigging and market division is not only unethical but also illegal. Pioneer
Foods will not tolerate any uncompetitive behavior and disciplinary action will be taken against
offenders this could lead to dismissal and Pioneer Foods will cooperate with the authorities to assist
criminal investigations.
LAW_POL 004
Competition Law
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Insider trading A closed period for trading in Pioneer Foods shares is maintained for prescribed periods to prevent
any insider trading of Group shares. (These periods apply at least every six months from 15 March and
15 September respectively until the publication of the interim or annual financial results.) The
definition of an insider can be found in the Insider Trading Policy.
LAW_POL 008 Insider
Trading Policy
Safety and Health Pioneer Foods is committed to maintaining high occupational health and safety standards in respect
of its employees and clients. Occupational health and safety performance is monitored at Group and
divisional level, with regular inspections performed at all premises and the results reported to senior
management.
All sites will ensure they identify risks and hazards and implement the necessary controls to mitigate
those risks.
Health & Safety Policies

HRPP-10 Employee
Wellness.doc
HRPP-10B Smoking.doc
Environment We will comply with all relevant environmental legislation and wherever possible strive to go beyond
mere compliance. Our main environmental objective is to minimise and manage our environmental
impact. We will consider the impact on the environment in our entire decision making processes, in
particular minimizing our impact on air, water, waste and climate change. We will re-use, reduce and
recycle wherever possible and relentlessly strive to reduce our carbon footprint.
We will ensure that we convert our raw materials into consumables efficiently. This means reducing
the amount of raw material for each product.

CAST Pol_001
Environmental Policy
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Accurate record keeping All records and supporting documents must accurately describe and reflect the nature of the
underlying transactions. No undisclosed or unrecorded account, fund or asset will be established or
maintained.



FIN_DOCS POL 001
Retention of documents
HRPP05: Recruitment &
Selection; HRPP03:
Transformation; HRPP06:
Conditions of Service;
HRPP07:Recognition,
Reward, and Benefits;
HRPP09: Learning and
Development; HRPP11:
Employee Relation.
Good governance
principles
We adhere to applicable laws, regulations, and industry guidelines in the various jurisdictions, in
which we trade, as well as our internal policies and procedures. (This includes Financial and Non-
Financial Related)


Responsible giving and
receiving of gifts.
We take cognizance of the objectives of the Millennium Development Goals (MDG) and with a
commitment to the highest ethical standards of community service.
We therefore seek to achieve corporate and social objectives by focusing on four strategic areas:
Food Security
Education
Environment
Enterprise Development
CAST_POL002_PFG
Corporate Giving Policy

HRPP01B: Conflict of
Interest
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All employees should declare any gifts they receive and write it up in their respective gift registers.
Company assets Company assets should be used to further the interests of the business. In certain cases it may be
acceptable for employees to make limited use of such assets for personal purposes, e.g. the
occasional personal phone call or using access to the Internet to do banking, etc. Use of company
assets is regulated through existing HR policies and procedures manuals and these documents should
be consulted
HRPP07:Recognition,
Reward, and Benefits

Travel, Accommodation
and Entertainment
Travel, accommodation and entertainment should be consistent with the needs of the business and
should be used as appropriately as possible to accomplish business objectives in a cost-efficient
manner and in keeping with normal company requirements
HRPP07:Recognition,
Reward, and Benefits
Ethical purchasing and
human rights
Pioneer Foods is committed to ethical purchasing of all its products and services, and expect all its
suppliers to respect basic human rights, including a requirement to oppose child labour and inhumane
working conditions. Whilst there currently is no formal supply chain integrity system in place, all
employees are encouraged to report concerns in this regard to the confidential hotline. This
particular component of the Pioneer Foods Code of Ethics will also be communicated to all our
suppliers.
FIN_PROCURE_POL 003
Procurement Policy
Corporate Social
Investment
Pioneer Foods is committed to communities in which it serves and operates improving the quality of
life and focusing on the education, development and socio-economic upliftment of the
underdeveloped communities. The corporate social investment strategy invests and deploys resources
in programmes that promote sustainable social and economic development, education, HIV/AIDS
education and community empowerment. The focus is on programmes or projects that tie in with the
Groups businesses and core capabilities in order to be supported internally
CAST_POL002_PFG
Corporate Giving Policy

Genetic Modification of
Foods
Pioneer Foods recognises the contribution that modern biotechnology can make towards the
availability, quality and nutritional value of food and therefore supports scientific research in this field.
The Company will consider the responsible use of genetically modified raw materials and their
GMO Position Statement
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application in food in line with our strategy and market demands.
In addition, the company is committed to providing its customers with affordable, nutritious, high-
quality and verified safe foods
Finally, Pioneer Foods will adhere strictly to labeling and Consumer Protection Regulations, providing
consumers with information as required.

ADAPTABILITY Employment equity The company views transformation as a business imperative and is committed to the implementation
of employment equity.
We promote an inclusive culture that values diversity in the workplace.
HRPP03- Transformation

Freedom of association
and collective bargaining

We acknowledge and value our employees as key stakeholders in the employment relationship. Every
effort is made to improve communication to build relationships and trust in the workplace through
various platforms of engagement at all levels of the business.
We provide employees the freedom to associate and respect collective bargaining to build and
enhance relationship between organised labour, representative unions and management. This leads
to open communication, mutual respect, and shared responsibility.
Divisional Collective
Bargaining agreements and
operating points
Diversity and
Transformation
Pioneer Foods is committed to transformation and cultural diversity aligned to the principles
enshrined in the South African constitution. The company views transformation as a business
imperative and is committed to the implementation of employment equity. The company promotes
an inclusive culture that values diversity in the workplace. We subscribe to the principles of
employment equity and affirmative action in the belief that the development of its people is a moral
obligation as well as an investment in the sustainability of Pioneer Foods. Recruitment, employment
and remuneration will be based on suitability for the work to be performed, measured against the
excellence standards to which Pioneer Foods aspires, and reward will be fair and adequate.
HRPP03- Transformation
HRPP05: Recruitment and
Selection;

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ETHICS QUICK TEST
A code of ethics is never intended to provide all answers to every conceivable question about ethical behaviour. Common sense can often guide decision making, and the following quick
test questions can be applied whenever anyone has doubts about specific behaviour.
Is it legal? If not dont do it! Good
Does it feel wrong? If it does dont do it!
Will you try to hide it? If you will dont do it!
Will you or someone else gain at the expense of the company? If the answer is yes dont do it! Self Others
For a decision or action to be ethical there needs to be a balance between what is good for you or the Company and what is good for the other parties or stakeholders involved in the
decision or action. If you believe that you have maintained this balance, then you seem to be on the right track.
WHERE TO FIND HELP
If you have any questions about the interpretation of the practical guidelines provided in this Code, or concerns about what the right thing to do is, you can contact the Corporate Affairs &
Sustainability Department, the Company Secretary, your Line Manager or your supervisor.

REPORTING MISCONDUCT
Every employee has a responsibility to report unethical behaviour of which they have become aware of. An independent hotline service, Tip-Offs Anonymous, is available 24 hours per day to
receive complaints or allegations regarding unethical conduct. The service provides different language options. Employees and any other stakeholder can report anonymously and
confidentially any unethical conduct by employees or service providers. You do not have to produce evidence of the unethical behaviour when you report, but you must have reasonable
grounds for your suspicions. Your report must be made in good faith as malicious reporting is unacceptable.
The toll free number to dial is: 0800 005 909, or e-mail [email protected]. You may also report unethical conduct directly to the Company Secretary.
APPLICATION OF THE CODE

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The Pioneer Foods Code of Ethics applies to our Directors and all permanent and temporary employees. We also expect that our suppliers, contractors, consultants and other external
stakeholders will comply with the values and guidelines in our Code, thereby assisting us to enhance our ethical culture.
STATUS OF THIS DOCUMENT
The Social and Ethics Committee of the Board of Directors has approved this revision, and it has been ratified by the Board. Compliance with the Code is a condition of employment. Non-
compliance can lead to disciplinary action in terms of our disciplinary Policies. The Pioneer Code of Ethics should be read in conjunction with the Pioneer Disciplinary Code, which spells out
specific examples of undesirable behaviour and associated penalties.

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All references are to specific policies of the Pioneer Foods Group or related best practice. Most of these policies can be found on the Pioneer Foods Intranet.
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