Kellogg Company Retired Ees Welfare Benefit

“The form 990 is prepared by an outside accountant and subsequently reviewed by a related organization's (kellanova) benefit finance personnel and ultimately also by a member of the erisa finance committee and the trustee prior to submission.”

“The office of ethics and business conduct serves as a resource for clarification of kellanova policy or reporting issues related to ethics and business conduct. Employees are encouraged to contact the ethics office without fear of retribution or retaliation. To the extent practical, considering our need to investigate and comply with other company obligations, we will protect the confidentiality of the reporting source. The ethics office also provides required annual online training and basic information on legal and regulatory requirements, company policies, and the standards of the global code of ethics. Each year, kellanova employees are required to complete a business conduct questionnaire. This questionnaire provides employees with the opportunity to review their personal circumstances and disclose information about any relationship or activity that may be a conflict of interest and to report any known or suspected violation of company policies or practices. This obligation to disclose is a continuing obligation. Employees should promptly submit a revised questionnaire when there are any changes to the information provided. All employees are required to comply with the global code of ethics. Failure to comply with company policies, applicable laws, and/or the global code of ethics can result in disciplinary action, up to and including termination of employment.”

“The organization makes its governing documents, conflict of interest policy, and financial statements, if any, available to the public upon request.”