KING ARTHUR FLOUR SUPPLIER CODE OF CONDUCT

The King Arthur Flour Company, Inc. has been promoting social and environmental responsibility since the company's founding in 1790. From the planting of the seed to the packaging we use, we strive to create products that are better for you and better for the planet. Working closely with suppliers, we're always innovating to bring greater transparency into our supply chain. While our food system has grown increasingly complex, you can trust us to always choose the best, smartest option to provide products our customers can trust and baking they will love.

The King Arthur Flour Supplier Code of Conduct ("Code"), outlined below, defines our minimum standards for social and environmental responsibility that must be adhered to throughout our supply chain. Compliance with this Code is an expectation of doing business with King Arthur Flour and we encourage suppliers to exceed these basic standards.

Laws and Regulations

Suppliers must operate in full compliance with all applicable federal, state, and local laws and regulations in which they operate and also in full compliance with this Code.

Corruption

Bribery, extortion and kickbacks are prohibited. Suppliers must comply with all applicable anti-bribery and anticorruption laws.

Child Labor

Suppliers and their Supply Chain participants must not use forced labor or child labor. Forced labor includes, but is not limited to, work or services performed involuntarily under physical threat or other penalty. This includes respecting the employees' freedom of movement and prohibits restricting worker movement by controlling identification papers, holding employee pay, or taking any other unlawful action to prevent employees from terminating their employment.

Suppliers must comply with all federal, state, and local laws regarding the minimum age of employees, including those pertaining to hours of work, wages, safety, working conditions, and the handling of certain materials. Child labor includes, but is not limited to, any practice that is not compliant with the letter and spirit of the rights set forth in the Convention on the Rights of Children, the ILO Minimum Age Convention, or the Prohibition and Immediate Elimination of the Worst Forms of Child Labor Convention.

Harassment

Suppliers must treat all workers with respect and dignity. No work shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. In addition, Suppliers will not use monetary fines as a disciplinary practice. Harassment on the basis of any characteristic described in the nondiscrimination section of this Code is strictly prohibited.

Wage and Benefits

Suppliers must pay workers at least the minimum compensation required by applicable local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime hours at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate. In addition, Suppliers must provide workers compensation insurance to their workers for work-related accidents.

Hours of Work

Suppliers must ensure that on a regularly scheduled basis, except in extraordinary business circumstances, workers are not required to work more than (a) 60 hours a week, including overtime, or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture. In addition, except in extraordinary business circumstances, all workers are entitled to at least one day off in every seven-day period.

Health and Safety

Suppliers must provide workers a clean, safe and healthy work environment in compliance with all legally mandated standards for workplace health and safety in the countries in which they operate, including the Occupational Safety and Health Act of 1970 and its implementing regulations, and any state Occupational Safety and Health Plans.

Nondiscrimination

Suppliers must ensure employment - including hiring, payment, benefits, advancement, disciplinary action, termination and retirement - is not based on characteristics such as color, race, caste, religion, age, nationality, social or ethnic origin, status, sexual orientation, gender, gender identity or expression, HIV, marital status, pregnancy, political affiliation, military service (Veterans), disability or any other status or characteristic protected by local law.

Women's Rights

Suppliers will ensure women workers receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment. In addition, workers will not be forced to use contraception.

Freedom of Association and Collective Bargaining

Suppliers must recognize and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association. Suppliers also must respect any legal right of workers to bargain collectively.

Environment

Suppliers must comply with all local environmental laws applicable to the workplace, the products produced, and the methods of manufacture. Suppliers must encourage the use of processes and materials that support sustainability of the environment.

Product Quality and Safety

Suppliers must comply with all applicable laws related to the quality and safety of their products, including any laws applicable to control of hazardous materials. Supplier must also comply with any quality assurance requirements and product specifications communicated by KAF to supplier.

Subcontracting

Suppliers must not use subcontractors to manufacture KAF products or product components that contain KAF's trademarks or tradenames without prior approval from KAF, and only after the subcontractor has agreed to comply with this Code. Suppliers must ensure that their suppliers, service providers, and extended networks have ethical and business practices that comply with this Code.

Communication

Suppliers must communicate, utilizing their existing ethical operating standards/practices or this Code, so that their workers, supervisors and permitted subcontractors are aware of the expectations /requirements detailed in this Code.

Monitoring and Compliance

KAF will take affirmative measures, including, but not limited to, announced and unannounced inspections of production facilities, to ensure compliance with this Code. Suppliers must allow employees from KAF or its designated representatives full access to facilities, documents, worker records and workers for confidential interviews in compliance with local laws. In certain circumstances, KAF may require Suppliers to allow KAF customers to accompany KAF's representatives during an audit. Those customers may also require full access to facilities, documents, worker records and workers for confidential interviews in compliance with local laws under the terms of a customer's code of conduct.

Suppliers are expected to take necessary corrective actions to promptly remedy any identified noncompliance. KAF reserves the right to terminate its business relationship with any Supplier who is unwilling or unable to comply with this Code when termination is allowed by local laws.

Application of the Code of Conduct

The Code represents KAF's core values, which apply to our entire supply network - from raw materials and components through finished goods and service providers. KAF takes active steps to communicate its Supplier Code of Conduct to all business partners.

To the extent KAF becomes aware - through either internal or external sources of information - of violations of the terms of the Code anywhere along the supply network, KAF will actively investigate and follow-up on any identified noncompliance.