Questions & Answers (Q&A)


Questions & Concerns
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Q: I don’t feel comfortable raising concerns in English. What can I do?
A:You can call the Help Line and choose your preferred language or contact us using www.telltysonfirst.com.
Q: What if I don’t know for sure whether the conduct violates the Code, company policies or the law? Do I have to be absolutely sure there is a violation of law or policy before I raise a question or a concern?
A: No. You don’t have to have all the details or be sure that something is wrong to raise a concern. We ask that you give as much detail as you have (who, what, when, where, any documents or materials relating to the report). You can trust that we’ll treat your reports seriously, fairly, and promptly, and if something needs to be fixed, we’ll take action based on what we learn.


Anti-Retaliation
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Q: What is retaliation?
A: Retaliation occurs when a team member experiences an adverse employment action for engaging in good faith in an activity covered by our policy or under state or federal law, including reporting or opposing discrimination or harassment, making a complaint about misconduct or unethical behavior, or reporting a workplace injury, illness or hazard either to Tyson or to a government agency. The Team Member is also protected if he or she assists in an investigation or proceeding concerning such a complaint, cooperates with law enforcement, or reports a possible violation of the law, this policy or any other Tyson Foods policy. Retaliation can include any negative job action, such as demotion, discipline, firing, salary reduction, or job or shift reassignment.


Employment Practices
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Q: One of my coworkers seems to be picked on constantly by others and it’s intimidating. I discussed this with another team member who advised me to ignore the situation because if I spoke up I could “become the next target.” What should I do?
A:Report it to your supervisor, a member of your management team, your local HR representative, the Help Line, or you may also report directly to the Ethics & Compliance Department by emailing ethics@tyson.com.
Q: My supervisor is recruiting and hiring new team members and appears to be excluding applicants because of age. What should I do?
A: We do not tolerate age discrimination. This concern should be reported to a member of your management team, your local HR representative, the Help Line, or the Ethics & Compliance Department. Reports of misconduct or behavior believed to be illegal, unethical, or which violates the Tyson Code of Conduct made to management or HR must be sent to E&C Department and entered into our Ethics case management system for proper investigation and tracking
Q: I have a disability and it may impact my work responsibilities. What should I do?
A: We are committed to a workplace free from disability discrimination. If conflicts arise between work requirements and a team member with a disability, contact your local HR representative to discuss the process for reasonable accommodation.


Healthy & Safety
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Q: What should I do? I noticed a machine is not running properly and may be a hazard to team members.
A: You should shut down any piece of equipment that is not running properly and immediately contact a member of management.


Food Safety
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Q: What should I do?I witnessed a team member not following a product specification but I don’t think it’s a food safety issue.
A: Contact a member of management or an FSQA representative immediately.
Q: What should I do?I see water dripping from a pipe onto product in the cooler, but the local government inspector hasn’t said anything. Does this mean it’s ok?
A: No. Team members are expected to do the right thing, even if a government inspector doesn't notice or tell us something is wrong. Contact a member of management or an FSQA representative immediately.


Gift & Hospitality
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Q: When should you disclose a Gift or Item of Hospitality?
A: If the exchange meets either of the criteria below, we expect you to disclose the gift or item of hospitality to protect yourself and the Company.
  • When one of the parties involved in the exchange is a government official.
  • When the value of the gift or item of hospitality is greater than $100 for a non-government party.
Q: How should you disclose a Gift or Item of Hospitality?
A: Complete the electronic Gift & Hospitality Disclosure Form. It will be automatically routed for appropriate approvals based on the party involved in the exchange and the value of the item. We prefer you complete the disclosure form prior to the exchange, but we understand there are circumstances that may prevent a pre-approval. There are strict rules on what we can give to a government official and a disclosure is still required regardless of value. In addition to completing the disclosure form, you must also identify the names of government officials and amounts of items you provided to a government official on an expense report when requesting reimbursement.
Q: What should I do?
A supplier gave me an expensive gift during a business meeting, and I know that because of cultural traditions it would offend him if I didn’t accept it.
A:You should report the gift immediately to Ethics & Compliance and ask for guidance. Depending on the circumstances and value of the gift, we may ask you to return the gift or donate it to charity.
Q: Can we give nominal gifts to our food safety inspectors?
We are having a lunch to celebrate a safety milestone at the plant, is it ok to invite our local USDA inspector to join us?
A: In the U.S., inspectors are not allowed to receive gifts from the Company.  This can vary by country, and if you need further guidance, refer to the policy or contact the Law Department. 


Competition
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Q: What should you do when conducting business with Suppliers or Customers?

A:

  • Base your purchasing or sales decisions on quality, value and customer service;
  • Avoid unfair or deceptive trade practices;
  • Communicate our purchasing or sales programs clearly; and
  • Deliver on your promises.
Q: What should you do when conducting business with Competitors?

A:

  • Do not enter into any agreement to set prices or other terms of sale (for example, credit terms, trade programs, etc.) coordinate bids, allocate customers, sales territories or product lines without contacting the Law Department;
  • Do not discuss transactions outside the scope of the transaction at hand;
  • Always ensure the claims you make about competitors' products and ours are verifiable and fact-based;
  • Always use legitimate means of obtaining public competitive information; and
  • Always respect their confidential information and intellectual property rights.


Intellectual Property
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Q: What are trade secrets?

A: Tyson considers trade secret information as information not generally known to the public, cannot be recreated through public sources, gives Tyson a competitive or commercial advantage, and with respect to which Tyson has taken affirmative steps to keep secret.

Q: What is considered intellectual property?

A:Creations of the mind that can include patents, trademarks, copyrights, inventions, names, images, designs, literary and artistic works and symbols.    



Conflict of Interest
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Q: I’m not sure a conflict exists – do I need to disclose it?
A: If a situation may give the appearance of a conflict, you should disclose it to protect yourself and the Company. Disclose even where you think the conflict isn’t significant or you think your decisions or job duties won’t be impacted by the conflict.
Q: How should I disclose a potential conflict of interest?
A:Complete the electronic Conflict of Interest Disclosure Form. If you cannot access the form, contact your local HR representative.
Q: Do I have a conflict of interest?
My father-in-law owns a chicken grow out operation for Tyson, do I need to disclose it?
A: Yes. A personal interest exists because your in-laws are considered family members and growers are considered business partners.  You need to complete the electronic Conflict of Interest Disclosure Form and, depending on your role with Tyson, appropriate controls may be put in place. 
Q: I’ve been asked to sit on an industry board, and the position is unpaid. Do I need to disclose the invitation before I accept it?
A: Yes. Participation in any paid or unpaid activity that may overlap with your Tyson responsibilities involving the Company’s customers, vendors, industry or competitors, including board memberships, must be disclosed.


Company Asset Use
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Q: My facility or department wants to purchase a new technical solution, wants to use online software, or purchase equipment that needs to be connected to any type of network – what do I do?

A: The purchase or use of any electronic system, service (e.g. software as a service, internet or data connection, e-commerce, web or content hosting, or data exchange), or hardware, including facility-based solutions, requires evaluation by the IT department and is required to follow standard procurement processes. Each must undergo an architecture and security risk review which will include an evaluation of appropriate language in contracts in partnership with the Law Department. All suppliers must be under a non-disclosure agreement before discussing, evaluating, bidding on, or implementing technology solutions. Using an expense report or P-card for software or hardware purchases, subscriptions, services, or contracts without prior IT approval is prohibited.

Q: An email I opened may have a virus or looks like a phishing attempt – what do I do?

A: You can either click the “Report Phishing” button from your Outlook, forward the email to ReportPhishing@tyson.com, or contact the ServiceDesk at 479-290-4305.    

Q: My facility or department wants to use online software or purchase equipment that processes information and needs to be connected to the network – what do I do?

A: Contact your IT Business Partner to discuss the outcome you are seeking. They and procurement will partner with you to find and procure a solution that meets your needs.    



Books & Records
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Q: Sometimes I discuss business with my teammates, customers, and other third parties on texting apps – is this kind of electronic communication a business record?

A: All business-related communications, including text messages and third-party messaging applications, with team members, customers, and suppliers, are subject to record retention requirements. Consult the Law Department for more information.



Bribery & Corruption
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Q: Who is considered a government official?
A:Any employee of the federal, state or local government, an agency of the government or government owned entity. See Global Anti-Corruption Policy for more details and examples which include the following:
  • Officials who are elected, for example, mayors and employees of state and federal offices, and candidates for office;
  • Officials who regulate and inspect our operations, for example, the Department of Agriculture or the Department of Labor; or
  • Officials who work for government owned or managed institutions, for example, public schools and federal or state police.    
Q: Can I pay facilitating payments to expedite the process? I was informed I could hire a local company or consultant to help get all the necessary permits from a foreign government.  An advance payment has been requested to "help move the process along."  I have been told this is a common practice in this country.
A: No. We are responsible for the actions of any third party working on our behalf. Facilitating payments are not allowed by our policy and violate the laws of many countries. The request for an advance payment is a potential red flag; the comment to help move the process along is even more so. Consult with the Law Department before proceeding.


Insider Trading
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Q: What are some examples of material information?
A:Any information which could reasonably be expected to affect the stock price for Tyson or another company.  Remember, either positive or negative information may be considered material.  Common examples of material information are: historical earnings or losses that have not yet been made public, projections of future earnings or losses, news of a pending or proposed merger, acquisition or joint venture, news of a significant sale of assets, changes in senior management, the declaration of a stock split or the offering of additional securities, significant new products or discoveries, and the gain or loss of a substantial customer or supplier.     
Q: How do I know if I’m subject to a black-out period?
A:You will be notified by the Law Department if you are subject to a black-out period    


Charitable Giving
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Q: Where do I enter information on a charitable donation made with Tyson funds on behalf of the Company?
A:In the U.S., information on donations should be entered in the Business-Initiated Donation (BID) tracking system as referenced in the Global Giving Policy. Outside the U.S., information on donations should be entered in the electronic Gift & Hospitality Disclosure Form.    
Q: If I’m making a charitable donation to a non-U.S. government official, do I need to get pre-approval?
A:Yes, charitable donations to non-U.S. government officials must be pre-approved if the value is more than $25USD or the local currency equivalent.    


Media Communications
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Q: My department sometimes circulates information about the Company that team members can post or share externally. Does this mean I’m authorized to speak on behalf of the Company?
A:At times, the Company provides information and our corporate opinions on issues of public concern that affect our Company. These announcements do not authorize you to speak on behalf of the Company. Nor are they intended to pressure you to adopt certain ideas or support certain causes. They’re content you may choose to post to your social media accounts to show support for the Company or certain causes. Your decisions to contribute your time or money to any political or community activity are entirely personal and voluntary.    


Waivers
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Q: What is the process for obtaining a waiver?
A:Code waiver requests must be submitted in writing to Ethics & Compliance Department by the team member, and must contain in detail all of the relevant facts and circumstances supporting the requested waiver. The VP Internal Governance will respond in writing to the team member.    

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