Code of Conduct

Delivering Integrity

Our Business Practices

Make and Deliver Food That is Safe to Eat

We are a food company, and nothing is more important to us than ensuring that the food we provide to our customers is safe to eat. Food safety is a personal responsibility of every associate at US Foods®. We encourage our associates to raise food safety concerns immediately. 

HOW WE DELIVER:

  • We comply with all applicable food and consumer product safety laws in every jurisdiction in which we do business
  • We follow all food safety and quality protocols in our workplaces and respond quickly when issues arise to help ensure the safety and quality of our products

Learn More:
pdf iconProduct Recall & Recovery Policy and Procedures
pdf iconResponsible Sourcing Policy and Supplier Code

Question: I work in receiving operations, and we received a load of produce that did not meet our temperature requirements for receiving. However, we were busy, and my supervisor told me to accept the load anyway. What should I do?

Answer: You should always raise concerns that could have food safety implications; if your supervisor does not listen, call your FSQA regional manager or another leader for help immediately.

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Compete Fairly

The way we compete is as important as what we achieve.

HOW WE DELIVER:

  • We do not enter agreements with competitors that limit competition, whether formally or informally
  • We respect competitive bidding processes, and we do not rig or fix the outcomes
  • When gathering competitive intelligence, we use appropriate sources, are truthful and do not misrepresent who we are

Question: I am going to a trade show. May I go to a competitor’s booth?

Answer: Yes. You may go to the booth and collect any publicly distributed material. However, if you talk to anyone at the booth, identify yourself as a US Foods associate and avoid conversations about pricing, specific customers or markets. A good practice is to consult the Law Department for guidance before you attend.


Question: I am friends with a salesperson for a competitor. Occasionally we talk about marketing plans and potential customers. Should I be concerned?

Answer: Yes. You may be revealing confidential information. You also may be violating competition laws that ban discussions of marketing and pricing.

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Respect Laws Around the World

Wherever we conduct business, we follow the law.

This helps us to build trust with business partners, customers and governments.

HOW WE DELIVER:

  • We follow the laws and regulations of the United States and, as applicable, any country in which we do business
  • We comply with global trade controls and economic sanctions that prohibit us from doing business with certain countries, governments, entities and individuals. We comply with laws that govern how food may be imported and exported internationally
  • We respond truthfully, appropriately and promptly to government inquiries and requests for information

Learn More:
pdf iconResponsible Sourcing Policy and Supplier Code

Don’t Make Improper Payments or Seek Improper Influence

We do not influence our customers’ decisions through improper payments or other improper means.

Winning and preserving customers’ trust every day is more important than any benefit we might get from doing business improperly.

In some parts of the world, making payments or giving other consideration to get business may be something that others do – we won’t. We would rather lose the business than secure it improperly.

HOW WE DELIVER:

  • We do not offer and will not pay bribes or kickbacks to anyone, including payments to secure permits or approvals and small payments to speed up a routine government process
  • We work with partners that have a reputation for integrity, and we report signs that a representative is unethical or could be paying a bribe
  • We make sure that any gifts, hospitality or travel we offer to government officials, healthcare customers or commercial customers are reasonable, pre-approved where necessary and in line with US Foods policy
  • We don’t use charitable donations or hires as favors to influence customers

Learn More:
pdf iconAnti-Corruption Policy
pdf iconGifts and Entertainment Policy

Question: One of my customers is a state university. Recently, my main contact there asked me whether US Foods could pay his way to a trade convention. What should I do?

Answer: Government officials at all levels - federal, state and local – are restricted in what they can accept from vendors such as US Foods. Our policy requires advance approval from the Law Department before giving anything of value to a government official. In this situation, the contact is a state associate, and the request likely exceeds the annual limit we permit for state officials from US Foods.

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Select Suppliers with Integrity

We rely on our supplier relationships for our success. To achieve our mission, we need suppliers that are as committed as we are to our company standards.

HOW WE DELIVER:

  • We select the best suppliers for the job by carefully considering their proven track record, reputation for integrity and other merits – not based on favoritism
  • We work to eliminate child labor, human trafficking and other labor abuses in our supply chain

Learn More:
pdf iconResponsible Sourcing Policy and Supplier Code

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Keep Accurate Books and Records

Our records are clear, accurate and complete.

We rely on these records to understand our performance and make good decisions.  Moreover, investors rely on clear, accurate and complete records to understand our financial results and where we are headed as a company. Finally, these clear, accurate and complete records are necessary to meet our regulatory obligations as a public company.

HOW WE DELIVER:

  • We honestly and accurately record and report financial transactions and business information, following applicable laws, regulations and accounting practices
  • We are transparent about our commitments to our partners and customers, and our written contracts reflect the actual economics of the agreement
  • We execute financial transactions only with appropriate authorization and record them in compliance with US Foods accounting practices
  • We comply with all applicable laws, including the Sarbanes-Oxley Act of 2002, to ensure that financial reporting is accurate and complete, and internal controls are in place
  • When we retain and dispose of documents, we follow established corporate record retention requirements

Learn More:
pdf iconRecords Retention Schedule
pdf iconRecords Retention Quick Guide
pdf iconAnti-Corruption Policy/Accounting and Internal Controls

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Treat Gifts, Entertainment and Travel Responsibly

We demonstrate sound judgment when exchanging business courtesies.

Giving and receiving reasonable gifts and entertainment can build goodwill between US Foods and those with whom we do business. But gifts, meals or trips that are extravagant or that lack either transparency or a legitimate purpose may be viewed as bribes or as simply inappropriate. These things erode trust and harm our business.

HOW WE DELIVER:

  • We develop positive relationships free from corruption and commercial bribery
  • When we offer or accept gifts, hospitality or travel, we make sure they are reasonable, appropriate and have a legitimate business purpose
  • We never give or accept cash, including gift cards
  • We do not solicit gifts, hospitality or travel from third parties, or put them in a position where they feel obligated to provide something in order to do business with us

Learn More:
pdf iconGifts and Entertainment Policy

Question: May I accept a business meal from a supplier?

Answer: In most circumstances, modest and infrequent business meals may be accepted. However, whenever a supplier pays for a meal, always consider the specific circumstances and whether your impartiality could be compromised or appear to others to be compromised. 


Question: A vendor I work with just finished an important project for me on time and under budget. I would like to show my appreciation with a gift. What is appropriate?

Answer: When we give gifts, we set the tone for how we conduct business – purely on business considerations. As a general rule, we should limit gifts to or from any one vendor or partner to $250 per year (excluding all government officials or healthcare customers for whom more restrictive limits apply). We should also take into account the vendor’s gifts and entertainment policy, as we would want them to consider ours.

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Do Not Trade on, or Tip, Inside Information

We maintain trust with our investors and the public by respecting financial disclosure laws.

In our work, we may become aware of material, non-public information about US Foods or companies we do business with. Information is material if a reasonable investor would consider it important in deciding whether to buy or sell that company’s securities.  Information is “non-public” if it has not been broadly communicated to the investing public.

Trading US Foods stock or the stock of any other company based on this information is illegal and breaks trust with our investors and the public.

HOW WE DELIVER:

  • We never buy or sell any securities based on material, non-public information
  • We do not give anyone tips regarding material, non-public information, whether family, friends or colleagues
  • We do not recommend or suggest that anyone trade in the securities of another company we do business with
  • We consult with the Law Department before buying or selling public securities where we have questions as to whether we may be in possession of material, non-public information

Learn More:
pdf iconInsider Trading Policy

Question: My family and friends often ask me about US Foods and whether they should buy stock. Usually I tell them what I know about our business and suggest they buy stock. Is this a problem?

Answer: The same rules about inside information apply whether you buy or sell stock yourself or if you give the information to someone else, known as “tipping.” If a relative or friend buys stock based on material, non-public information that you give him or her, both of you could be liable for violation of securities laws. You should be cautious about such conversations and consult the Law Department if you are unsure.

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Safeguard US Foods Resources, Confidential Information and Intellectual Property

We are responsible stewards of US Foods resources, including information and technology resources.

We use company resources, including information and ideas, to perform our jobs every day. These resources belong to US Foods; we owe it to our investors to use them responsibly and in ways that preserve trust and add value.

We might lose our competitive advantage if we disclose US Foods confidential information. We also lose trust if we disclose confidential information that we learn from the companies with whom we do business. Protecting information and ideas, whether our own or those of others, is crucial to our business success and builds our reputation as a trustworthy partner.

HOW WE DELIVER:

  • We spend US Foods funds wisely, and guard against waste and abuse
  • We understand that business-related data is US Foods property. We use best practices to protect access to confidential information, and avoid discussing it in common spaces or with colleagues who don’t need to know it
  • We do not use confidential information for non-US Foods business use, and we maintain confidentiality even if we stop working for US Foods
  • We preserve US Foods own intellectual property rights through copyrights, trademarks and other forms of intellectual property that protect the value of our innovation
  • We respect the confidentiality and intellectual property rights of others, and do not use confidential information without authorization

Learn More:
pdf iconAcceptable Use of Information Assets Policy
pdf iconTravel and Expense Policy
pdf iconInformation Security Policy

Question: I am able to get an early start on my day by returning calls during my train ride to work. Is this a problem?

Answer: You should be careful not to discuss non-public company information in public places where others may overhear you such as taxis, elevators or at conferences or trade shows. When it is necessary to conduct a phone call in a public place, be aware of your surroundings. When flying, ensure you use a privacy screen if you plan to use your laptop.

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