Ethics & Compliance Overview
The Global Ethics & Compliance (E&C) team, led by the Chief Compliance Officer (CCO), oversees our enterprise-wide commitment to upholding ethical business practices. Among other key responsibilities, the E&C team promotes and enforces the Mars Ethics & Compliance Guide, our workplace guide to winning with integrity, through training, reporting, investigations and other engagements. The team reports bi-annually to the Audit Committee of the Board on compliance activities, risks, trends and program effectiveness.
Other key responsibilities include:
- Implement and oversee policies on antitrust, anti-bribery/corruption, data privacy, conflicts of interest and other compliance topics.
- Advise on and support sustainability policies, codes of conduct and processes.
- Oversee confidential reporting and investigation processes, and help assess and mitigate compliance risks associated with third-party suppliers.
- Integrate new acquisitions into our compliance framework.
- Conduct risk-based assessments to prioritize compliance efforts.
- Measure and monitor Associate engagement with ethics and compliance culture and programs.
- Chair a cross-functional corporate compliance committee with other key governance, risk and compliance leaders at Mars.
- Foster a culture of ethics with global and local leadership support that includes a strong emphasis on speaking up and non-retaliation.
Whistleblower Protections & Reporting Mechanisms
Mars is focused on fostering a speak-up culture where all Associates feel empowered to ask questions and raise issues safely, confidentially, and without fear of retaliation. In our own operations, we seek to ensure that all Associates in Mars workplaces are aware of and have access to our accredited Ombudsman program (including a toll-free hotline and online portal) to help resolve workplace issues impartially and respectfully.
Our Ethics & Compliance program further enables Associates and third parties to confidentially report concerns 24/7 through the program’s dedicated and published electronic mailbox chiefcomplianceofficer@effem.com. Associates may also submit reports through our Ethics & Compliance Helpline, accessible via phone or internet form. When using the Helpline, Associates have an option to remain anonymous. The operators answering phone calls to the Helpline speak over 150 languages.
Mars does not tolerate any form of retaliation, punishment or retribution against anyone for raising or helping to address an ethics or compliance concern in good faith, no matter the escalation channel used. Our Non-Retaliation Policy is prominently displayed on the Helpline landing page and reinforced through routine business engagements and other communications. Anyone who thinks they have or someone they know has suffered retaliation is instructed to contact the Chief Compliance Officer at chiefcomplianceofficer@effem.com or the Ethics & Compliance Helpline.
Data Security & Privacy Protection
Mars is committed to ensuring that the personal data that its stakeholders entrust to Mars is managed with transparency and security, in line with both regulatory requirements and Mars internal standards. Mars complies with all applicable global privacy regulations. Our Privacy Policy and other public disclosures provide transparent information on our data collection and handling practices, and our internal policies and procedures document clear processes to ensure appropriate governance, as well as recognition of the statutory rights of our stakeholders and robust data security practices. In addition to internal tracking and assurance activities, we engage our internal audit function to regularly assess elements of data privacy and governance, reinforcing accountability across the enterprise.
In parallel, we are committed to responsible AI and digital ethics, embedding safeguards that ensure our use of technology aligns with human rights and our core values. This commitment is reflected in both our statement of Data Ethics and Responsible AI Policy, with enterprise governance co-led by the Chief Compliance Officer and Chief Information Security Officer, under the oversight of the Mars Leadership Team and with visibility at the Board level.
Anticorruption
Ethical conduct is central to our identity at Mars. We adhere strictly to our Global Anti-Corruption Policy, ensuring that integrity is embedded in every aspect of our business. Anti-corruption is not only a legal obligation—it is a sustainability imperative that underpins our commitment to responsible, ethical sourcing and building and maintaining stakeholder trust.
We prohibit corruption in any form, including giving, accepting, or authorizing bribes. We expect all of our business partners, such as our distributors, customs brokers and other suppliers, to maintain the same standards as we do when acting on our behalf and detail these expectations in our Anti-corruption and Human Rights Expectations for Business Partners(Opens a new window) as well as our Supplier Code of Conduct.
Antitrust & Competition
Mars is committed to preserving fair, honest and vigorous competition for the benefit of consumers and to promoting a competitive economy in which each business enterprise has an opportunity to compete fairly on the basis of price, quality and service. We foster competitive integrity by providing mandatory training to Associates on antitrust and competition laws, ensuring that Mars remains legally compliant while promoting fair market practices and innovation through responsible business collaboration.