We are committed to building relationships based on integrity. This value, in alignment with the Monsanto Pledge, helps us earn and retain the trust of people across multiple stakeholder interests with whom we interact in the normal course of our business.

Our commitment against corruption starts with a strong culture of integrity set at the highest levels of the company. We analyze all of our business units for risks related to corruption and maintain constant vigilance in auditing all business units for compliance with our Anti-Corruption Policy, Code of Business Conduct (Code), Corporate Controller Policies and other compliance related protocols. Regional Working Groups meet to consider and, where appropriate, approve employee interactions with government officials before those interactions occur.  Working Group membership includes the highest-ranking business, finance and legal executives in each business region or unit. These teams are accountable for employee compliance with Monsanto’s anti-corruption program and controllership policies.

Maintaining a strong culture of integrity in a dynamic corporate environment requires continuous review, consideration and oversight. In 2011, the Business Conduct Office (BCO) implemented updated global anti-corruption risk mitigation protocols, launched these protocols across all of our business units in multiple languages through our Regional Working Group structure and completed numerous training and communication campaigns to ensure employee awareness.

In 2012, the Board of Directors approved an update to the Code, which was published and distributed to all employees in 30 different languages. These important initiatives were presented to our organization with a fresh look powered by a new branding theme that carries over into our broader training and communication efforts. Updates to the Code include an on-line interactive version for employees and external links for use by suppliers and vendors who conduct work related to or on behalf of Monsanto in compliance with our Code.

 IN 2012, AN UPDATED CODE WAS PUBLISHED IN 30 DIFFERENT LANGUAGES

For more information, please visit www.monsanto.com/whoweare/Pages/business-conduct.aspx

GRI LA MA GRI LA 8 Code of Business Conduct and Employee Training

Monsanto’s Code helps employees recognize and deal with a broad range of potential issues. The Code provides guidance on the importance of respecting each other, protecting the environment, health and safety, proper stewardship of our products, research methodology, use of company resources, and accurate communication about our finances and products.

It also addresses the many legal and ethical facets of integrity in business dealings with customers, suppliers, investors, the public, and governments that regulate us and the communities in which we do business. The Code also provides employees with information on several ways to raise questions or request guidance before making decisions or taking actions.

Employee training promotes awareness of the Code and prepares employees to act appropriately in business situations when faced with an ethical dilemma. Training helps employees anticipate situations likely to arise in the dynamics of our business and to be prepared to meet those challenges. In 2012, the Business Conduct Office (BCO) supported training programs for more than 20,000 employees using computer-based presentations.  Training focuses on Monsanto’s social, legal and ethical responsibilities including:

• Code of Business Conduct and annual certification of compliance
• GRI SO 3 UN 10 Anti-corruption and Monsanto’s anti-corruption practices
• GRI HR 3 UN 1 Human rights
• UN 1 Respect in the workplace
• UN 1 Employee opportunities to raise business conduct concerns for both employees and managers
• Software anti-piracy
• Information privacy
• Insider trading
• Conflicts of interest
• Trade and professional association participation
• Lobbying

Training for newly hired employees includes sections on these topics to assure awareness across our organization.

The BCO also promotes awareness of the Code by maintaining training materials on a dedicated website accessible by computer-enabled employees in all global regions. Employees are encouraged to seek additional guidance on the Code and our commitment to integrity from their managers, their human resources generalists and the senior management team in their region.

Posters placed throughout all of our physical locations direct employees to toll-free telephone numbers and the Business Conduct Office confidential mailbox to enable direct access by all employees who feel their concerns may not be fully heard or appreciated in their local environment. Retaliation for reporting good-faith concerns to the BCO is strictly prohibited.

GRI LA MA UN 10  Recognizing Integrity: Business Conduct Awards

Each year, we recognize employees who demonstrate integrity in exceptional ways.

Program Overview and History

In 2010, the Business Conduct Office (BCO), in cooperation with other functional areas, developed an awards program that recognizes exemplary behavior that supports and reinforces the BCO’s compliance and ethics program and the company’s culture of integrity.

Program Concept

The program recognizes group or individual employee contributions that serve to strengthen Monsanto’s culture of integrity, recognize and address compliance with all legal, regulatory and company policy requirements, or create efficiencies in existing compliance practices.

 FOR 2012, MONSANTO RECOGNIZED 68 EMPLOYEES AS GLOBAL AWARD WINNERS CONTRIBUTING TO THE CORPORATE CULTURE OF INTEGRITY.

Award Categories

• Integrity Champion Award — Compliance awareness or educational projects or initiatives that result in employees, vendors or customers conducting business in a way that clearly demonstrates a commitment to integrity.
• Compliance in Action Award — Initiatives or action that detect and address internal control weaknesses that may lead to non-compliance issues.
• Operational Excellence Award — Ideas and resulting action plans that create meaningful process improvements and efficiencies to existing compliance activities.
• Courage in Integrity Award — Demonstration of individual courage and foresight to recognize and proactively address observed non-compliance under adverse conditions.

For 2012, across all categories, we recognized 77 employees as regional award winners who contributed in a meaningful way to their region’s culture of integrity and 68 employees as global award winners who contributed to Monsanto’s corporate culture of integrity in ways that hold the potential for improvement across all or multiple business units.