Business Ethics & Corporate Governance

Pilgrim's strives to be a company of people known for conducting business with the highest levels of honesty, integrity and ethical behavior.

As a public company, Pilgrim's has established strong controls for compliance with requirements of Section 404 of the Sarbanes-Oxley Act of 2002. The foundation of these controls is our Code of Business Conduct and Ethics, which outlines what is expected of each employee, officer and board director. The policy contains guidance on compliance with laws and regulations, insider trading, conflicts of interest, corporate opportunities, confidentiality, fair dealing, protection and proper use of the company's assets, accuracy of records and reporting, disclosure controls and procedures, and interaction with public officials. The policy is distributed to all new employees, and each employee must sign a form acknowledging that he or she has read it. (A copy of this policy can be found online at http://www.pilgrims.com/company/code-of-conduct.aspx.)

Ethics Training

Pilgrim's provides ethics training for all of our salaried and salaried non-exempt employees. Our web-based ethics training program is a comprehensive curriculum of coursework covering many legal and ethical issues associated with our business. Employees who take this ethics training course must pass a comprehensive test to demonstrate their knowledge of our Code of Business Conduct and Ethics Policy, which includes our company's policies on related party transactions, internal disclosure, confidentiality, animal welfare, and discrimination and harassment. Employees must pass an annual test in order to meet internal training compliance requirements. In addition, certain employees are required to complete an annual business conduct compliance certification that verifies their compliance with company policies and applicable law, including the company's Code of Business Conduct and Ethics, the Foreign Corrupt Practices Act of 1977 and the Sarbanes-Oxley Act of 2002. The certification is required of all salaried and salaried non-exempt employees, as well as hourly employees, who have access to company funds or who work in shipping, purchasing, receiving, safety or security.

PRIDE Line

Another important anti-fraud control Pilgrim's has implemented is the PRIDE Line. This confidential toll-free hotline is available 24 hours a day, seven days a week, to allow employees, suppliers, customers and other interested parties to report any situations that could cause harm to our company or our employees. We encourage open communication throughout our company, and we encourage employees to bring any issues to the attention of their supervisors or human resources department.

However, in cases where direct communication may not be possible, the PRIDE Line is available so that anyone who believes there is a situation or activity that could potentially harm the company can be assured that their concerns will be heard and acted upon.

We contract with an outside vendor to provide this service, ensuring strict confidentiality for anyone who uses the PRIDE Line.

For more information about Pilgrim's corporate governance structure, including our audit committee charter, governance policies and related-party transactions, please visit http://www.pilgrims.com/company/corporate-governance.aspx.