MY ROLE

Every Land O’Lakes employee—regardless of role—has a part to play in maintaining our reputation for fairness, integrity and ethics. This includes protecting information, communicating with care and avoiding confl icts of interest.

It can be easy to rationalize the wrong behavior by telling yourself things like: Just this once. No one will ever know. Ironically, those making the wrong decision sometimes do so believing they are acting in the Company’s best interests.

As a guardian of the Company’s reputation for integrity and ethical behavior, you should understand that while business challenges and ethical dilemmas may change, our commitment to doing what's right, every day, does not.

Here are some of the most important standards each employee must follow, every day, every time.

RESPECT CONFIDENTIALITY Confi dential information is any information that is not public. It includes trade secrets, strategic plans, consumer insights, engineering and manufacturing ideas, product recipes, designs, databases, records, price information and unpublished fi nancial information.

Never disclose, or allow the disclosure of, confi dential information unless required by law or directed by Company leadership. Use special care in storing or transmitting confi dential information, as required by Company policy and our Information Classifi cation standard. Honor confi - dentiality commitments made to our customers, vendors and business partners. Never disclose their confi dential information without their written consent.

Be aware of your surroundings when working, especially when traveling or away from the offi ce. Can others overhear your conversations? Is your laptop screen visible by others?

Keep in mind that the obligation to respect confi dentiality continues, even if your employment with Land O’Lakes ends. Likewise, never disclose the confi dential information you learned while working for other employers to Land O’Lakes.

If you believe that Company confi dential information has been stolen or disclosed without permission, contact the Law Department immediately.

RESPECT PRIVACY Members, employees, customers and business partners all trust Land O’Lakes with sensitive, and sometimes private, information. Before collecting, using, sharing or deleting any such information, make sure you understand your responsibilities under the Company’s Privacy policy, our privacy notices and any applicable agreements with the information’s owner.

USE COMPANY ASSETS RESPONSIBLY Company information and technology are essential to performing your role successfully. Be sure to use—and safeguard—them appropriately.

Use all Company information and assets (such as hardware, software and internet access) consistently with this Code and Company policies, especially those relating to discrimination, harassment, confi dentiality, privacy and compliance with the law. Take care to protect those assets from theft or damage.

Passwords matter! Never share your password and don’t leave your laptop unattended in an exposed location.

Land O’Lakes monitors the use of its assets. Employees should not have an expectation that information stored on or transmitted via those assets is private.

PROTECT INTELLECTUAL PROPERTY How can employees safeguard the Company’s intellectual property? » Only use approved and authorized Company trademarks. Report any suspected misuse of our trademarks, logos or brands. » Never disclose Company trade secrets to unauthorized persons. » Report to leadership any new product, technology or unique business solution developed while working for Land O’Lakes.

Respect the intellectual property rights of others as well. Never use intellectual property that does not belong to Land O’Lakes without permission from its owner.

COMMUNICATE WITH CARE Communications are the lifeblood of any business. They also carry substantial risk if done carelessly or thoughtlessly. As technology makes communication increasingly virtual, the nuances of in-person communication can be lost.

Don’t be misled by the casual nature of texts or instant messages —they carry the same weight and importance as an old-fashioned memo. Before hitting “send,” ask yourself how you would feel reading these words on tomorrow’s front page.

Be sure your communication passes these critical tests: » Don’t use profanity, slurs or other off ensive language. » Don’t disparage other employees, customers, members or business partners.

» If you need to include “Destroy after reading,” don’t write it in the fi rst place. » Avoid sarcasm or humor; they do not translate well into written communications. » Don’t use antitrust red-fl ag words (e.g.,

“dominate” or “monopolize”) even jokingly. » Don’t exaggerate; be completely factual. » Don’t speculate on the legality of behavior. » Be sure you are safeguarding confi dential or private information. » Make sure your communications are consistent with the Company policies on Appropriate Behavior in The Workplace,

Confi dentiality and Privacy. » If your communications are on social media platforms, read and follow the

Social Media policy.

All inquiries or requests from representatives of the media, industry or governmental agencies, including all requests for comment, must be directed to the Communications Department.

AVOID CONFLICTS OF INTEREST A confl ict of interest is a situation where an employee’s personal interests confl ict with—or even appear to confl ict with—the Company’s best interests.

Nothing is more corrosive to an employee’s or business’ reputation for integrity and ethical behavior than an actual — or even perceived— confl ict of interest. An employee who accepts lavish entertainment from a vendor, then later chooses that same vendor for a lucrative contract, will inevitably have their motivation for selecting that vendor questioned—even if that vendor was the best choice. Confl icts can also arise with existing vendors, as we expand the scope of our relationship with them.

Land O’Lakes expects every employee to “act with integrity.” Read and follow the Company’s Confl ict of Interest policy, which addresses the most common types of confl icts, such as: » Gifts and entertainment » Working with family members » Insider trading » Doing business with Land O’Lakes » Serving on an outside Board of Directors » Outside employment » Working for competitors » Personal fi nancial interests

KEEP ACCURATE BUSINESS RECORDS Land O’Lakes is committed to the integrity of its records, and requires that all reports, documentation, fi nancial statements and other business records are accurate and comply with all applicable accounting procedures and internal controls.

Every employee is responsible for ensuring the accuracy and completeness of business records they create or maintain.

Always consult the Company’s Records Management policy and Retention Schedule before destroying any business record. If the record is subject to a litigation hold, maintain the record until notifi ed otherwise by the Law Department.

A N D

1

I see so much misinformation on social media about farming practices and bio-technology. These issues that are so important to our members and customers. Can I jump in to correct the record?

Land O’Lakes can best support our members when we speak with a strong, unifi ed voice. That's why our Social Media policy outlines the rules that apply when an employee uses social media on behalf of the Company, or when referring to the Company or its products.

Can I use my Company computer for personal use?

While limited personal use is permitted, you should not have any expectation of privacy if you use Company assets for personal use.

3

The local newspaper has contacted me for a quote about our plant expansion. Can I respond?

No. Refer all media requests to the Communications Department. See the Information Disclosure policy for more information.

5

Land O’Lakes isn't a public company, so I don’t need to worry about insider trading—right?

Wrong. Through your role at Land O’Lakes, you might learn material, non-public information about another company, such as merger or divestiture plans, a new product off ering or other information that could have an impact on that company’s stock. Never share or use that information to your benefi t. See the Confl ict of Interest policy for more information.

A customer needs me to alter the date on a purchase order—something about their accounting rules. Can I help them out?

No. All business records must be complete and accurate—no exceptions.

4

I think someone might be recording my conversations. Is that OK?

No. The Company prohibits the unauthorized, or secret, use of camera, sound or video recording or streaming equipment.

6

A vendor regularly wines and dines our leader at fancy restaurants with expensive bottles of wine. Our leader won’t hear anything negative about this vendor and keeps giving them new business. Isn’t this a conflict of interest?

This scenario illustrates why gifts and entertainment by new or existing vendors can be a problem. This vendor may be capable and the best choice for our business, but the leader’s behavior has created the perception that his or her judgment may be clouded by frequent, lavish entertainment. Employees are required to avoid actual—and perceived —confl icts of interest by following the Confl ict of Interest policy whenever gifts or business entertainment are off ered.