Ethical Sourcing & Social Responsibility Policy

BARCEL USA, LLC

Barcel USA, LLC ("Barcel USA" or the "Company"), pursues all its activities with a commitment to the basic values and principles of ethical behavior, a cornerstone of which is integrity. Barcel USA’s reputation for integrity and good corporate citizenship is based on adherence to the highest of ethical standards, embracing open and honest relations between individuals employed by the Company (“associates”), shareholders, customers, suppliers, competitors, communities and governments. To maintain this reputation, Barcel USA expects all of its associates and suppliers to act ethically with the highest standards of integrity and abide by the principles of lawful conduct in all their business dealings. No one in the Company, from the President to the newest associate, is ever permitted to commit or condone any illegal or unethical act, or to instruct other associates or suppliers to do so. Any doubt as to the legality of any course of action should be discussed with one's immediate supervisor or Barcel USA legal counsel, as necessary.

This Ethical Sourcing & Social Responsibility Policy is meant to supplement the Global Policies of our parent, Grupo Bimbo, the Company Code of Business Conduct and applies to all associates.

It is every associate’s responsibility to report when he or she becomes aware of or suspects a violation of the Global Policies, Code of Business Conduct or this Ethical Sourcing & Social Responsibility Policy. The report should be made to the most senior manager at the location or area of work, the Legal Department or Human Relations Department, the communication channel set forth in the Global Policies or by calling "The Network" at 1-866-458-5428. Reports made to "The Network" may be made anonymously. No reprisals will be taken for any report made in good faith, regardless of the method used to report a violation, incident or concern.

Just as we expect our associates to uphold and commit to this Ethical Sourcing & Social Responsibility Policy, we similarly expect that our suppliers will do the same. We expect our suppliers to acknowledge, respect and adopt the Barcel USA Ethical Sourcing & Social Responsibility Policy or similar and equal standards as follows:

1. Communication: All Barcel USA suppliers are expected to review the Barcel USA Ethical Sourcing & Social Responsibility Policy and to return a written acknowledgement. The requirements of the Policy shall be communicated to the suppliers’ employees.
2. Risk Assessment: Barcel USA shall prioritize the implementation of the Barcel USA Ethical Sourcing & Social Responsibility Policy to critical suppliers, with corresponding actions and resources.
3. Monitoring and Verification: Barcel USA reserves the right to verify compliance to this Policy through self-assessments, internal and/or external audits as deemed necessary and commensurate to the risk. These may be both announced and unannounced.
4. Corrective Actions: Barcel USA expects to work with its suppliers to implement corrective and preventative actions as deemed necessary to ensure compliance, up to and including termination of supplier agreemen

Human Relations

Our associates, the people who are a vital part of our success, must be treated with dignity, respect and fairness at all times. Barcel USA is committed to the highest standards of ethics in all relations with and among its associates.

Barcel USA endeavors to communicate with associates in an open, honest and timely manner in all matters that affect them, encouraging feedback to ensure a two-way flow of communication between management and other associates.

Barcel USA is an Equal Opportunity Employer and provides equal employment opportunity regardless of race, color, religion, gender, age, national origin, disability, sexual orientation, gender identity, political affiliation, union membership or any other personal characteristic protected by law. This policy applies to all aspects of employment, including recruiting, promotion, demotion, transfer, layoff and termination, rates of pay and other forms of compensation, education and training and other working conditions.

No associate will be subject to discrimination and/or harassment based on a personal characteristic protected by law. Barcel USA will not tolerate any such discrimination and/or harassment. Barcel USA has a complaints and investigation procedure that outlines the conditions for and documentation of any disciplinary action and this has been effectively communicated to associates. Barcel USA will not tolerate abuse as a disciplinary measure.

Barcel USA is committed to provide equal employment opportunity to qualified individuals with disabilities, special disabled veterans, and other protected veterans of the Vietnam-era.

Barcel USA has developed affirmative action plans for minorities and women, those with disabilities, and Vietnam-era and special disabled veterans and other protected veterans. Our Human Relations Department will provide information regarding these plans upon request.

Barcel USA opposes any forced, bonded, indentured and prison labor. We commit to all legal compliance vis-a-vis foreign and migrant workers with no withholding of any identity documents, or wages outside any legal and fully understood contractual agreement. All basic hiring terms are to be fully understood by all workers and provided in their native language. All workers have the right to terminate their employment after reasonable notice and without penalty and have the right to leave the workplace after their shifts.

Barcel USA does not accept child labor and shall not employ any person under the age of 15 unless local law is set at 14 for developing countries as defined by ILO Convention 138. Workers under the age of 18 shall not perform hazardous work. Barcel USA has age verification procedures in place and will apply remediation measures if child labor is detected. Legitimate workplace apprenticeships are permitted.

Barcel USA respects the rights of workers to organize collectively and to do so independently, without interference, within the legal framework of the communities where the Company operates. In communities where free and independent collective bargaining is constrained, Barcel USA shall respect alternative organization channels.

We will comply with legal requirements and agreements on working hours and as a minimum will not allow a workweek of more than 48 hours, plus a maximum of 12 hours overtime, on a regularly scheduled basis. Overtime shall always be voluntary, and may be agreed through a legitimate collective bargaining agreement with all associates informed at the time of hiring. Overtime shall be compensated at the applicable mandated or agreed premium rate. Associates shall have at least one day rest in every seven day period.

Terms of employment are to be communicated and provided in writing to associates in a language understood by them. No fees or deposits are to be accepted and cannot be required by employment agencies as deductions or as wage withholdings. No wage deductions can be made as a disciplinary measure.

Our Communities and Environment

The Company operates and conducts business predominantly within the United States from which we derive our associates, customers and revenues. Every associate has the responsibility to consider the impact that our actions, as individuals and as a Company, may have on these communities on which the Company’s own health depends.

Barcel USA is committed to being a socially and environmentally responsible company, recognizing that the competitive pressures for economic growth and cost efficiency must be integrated with environmental stewardship and ecological considerations. The Company encourages the implementation of creative ideas for waste management and reduction, recycling and re-use programs.

The Company has committed to responsibly manage all aspects of its business to meet or exceed recognized environmental, health and safety standards and legal requirements and strives for continual improvement.

The health and well-being of associates and consumers is a priority, not only of management, but of everyone who works at Barcel USA. Management, to support this priority, commits to providing all necessary resources as required to manage this, including appointing managers to be responsible for environmental, and health and safety compliance and standards at a corporate level and representation at each site. Associates will be afforded regular and recorded training on environmental and health and safety standards when joining the Company, when required by law and, on internal instructions, in a language understood by all associates.

Barcel USA has an Environmental Management Plan ("EMP") that covers all bakeries and sites. This EMP is supported by an Environmental Policy and includes environmental risk assessments, objectives and targets, operational controls, controlled documentation, scheduled audits and inspections, and annual management reviews.

Specifically, Barcel USA will manage energy use, transportation, greenhouse gases, emissions to air, ozone depleting substances, water use, wastewater and effluents, waste, hazardous and potentially hazardous substances, contaminated land and groundwater, land use and biodiversity, and community nuisances as determined through a site-by-site risk approach.

Barcel USA will adopt emergency action plans that cover fire, spills and other evacuation concerns for all sites that include emergency management teams, communications plans with updated contact lists and at least one annual testing. Barcel USA will also ensure that buildings are maintained for fire safety, with required training for first aid and emergency care and those who handle and dispose of hazardous materials.

All Barcel USA workplaces will be properly ventilated for hot environments and where chemicals and solvents are used. Workplaces will also be sufficiently heated for cold environments, taking into consideration any risks to food safety. Adequate lighting and noise protection will be afforded in the workplace. Barcel USA will maintain scheduled and recorded equipment maintenance to ensure proper industrial hygiene.

Associates must report immediately to their supervisor any known breach of the Company’s environmental, health and safety standards in accordance with Barcel USA’s established environmental policies.

Each associate, with his or her own expertise in the Company’s operations, is encouraged to advance ideas to upgrade the Company’s existing environmental, health and safety practices.

Additional Supplier Responsibilities (associates refer to the Global Policies and Company Code of Business Conduct)

Gifts and Entertainment: Suppliers must not offer gifts or entertainment to Barcel USA associates to obtain personal gain, directly or indirectly, from the Company even if there is no expectation of receiving anything in return.

Conflicts of Interest: Suppliers must not enter into transactions with Barcel USA associates that create a conflict of interest.

Anti-Corruption: Suppliers must not tolerate, permit, or engage in bribery, corruption, or unethical practices whether in dealings with public officials or individuals in the private sector.

Financial Integrity: Suppliers must keep accurate records of all matters related to their business with Barcel USA in accordance with standard accounting practices such as Generally Accepted Accounting Principles (GAAP) or International Financial Reporting Standards (IFRS).

Reporting Violations: Violations of Barcel USA’s Ethical Sourcing & Social Responsibility Policy can be reported confidentially in a local language. If you have knowledge that any of these standards are being violated, you are encouraged to report the issue by calling "The Network" at 1-866-458-5428.

Confidentiality, Privacy and Security: Barcel USA trusts suppliers with confidential information, and expect our suppliers to protect it just as carefully as Barcel USA would. Suppliers must comply with applicable security and privacy laws, regulations and retention requirements, and to ensure that they have appropriate technical and security controls in place to protect Barcel USA confidential information. Confidential information means all non-public Barcel USA data, including: business plans, pricing strategies, marketing plans, team member personal information, guest personal information and intellectual property. Suppliers may not outsource, disclose, share, or use this information outside the requirements defined in their contractual or non-disclosure agreement with Barcel USA. Unauthorized disclosures could harm Barcel USA, breach the supplier’s contract, or may even be illegal.

Conclusion

It is not possible in a document of this nature to cover the full range of possible associate activities. Nor is it possible to enforce ethical behavior with a set of rules. Upholding a high standard of business conduct is the responsibility of Barcel USA and each individual associate. Often answering such simple questions as "Is this course of action good for the Company?" and "Can I justify it?" or referring to the basic guiding principle, "Am I doing what is right?" will provide guidance.

As noted previously, this policy is intended to supplement the Grupo Bimbo Global Policies and Barcel USA Code of Business Conduct, and all associates should be familiar and knowledgeable about all such policies. Any associate who violates the Grupo Bimbo Global Policies, Code of Business Conduct and/or this Ethical Sourcing & Social Responsibility Policy is subject to appropriate disciplinary up to and including termination and/or legal action.