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					                           Term Paper
                                    on
                         “SARA LEE”
PREPARED FOR:

JASHIM UDDIN
ASSISTANT PROFESSOR
DEPT. OF BUSINESS ADMINISTRATION
EAST WEST UNIVERSITY


PREPARED BY:

Yeasin Islam              (2009-1-10-203)
Sujan Kumar Gosh            (2009-1-10-252)
Fuad Hassan Khan           (2009-2-10-287)


SECTION:    01




                            TH
DATE OF SUBMISSION: 15 DECEMBER 2011
                              Letter of Transmittal


Date: 15th December 2011


To
JASHIM UDDIN
ASSISTANT PROFESSOR
DEPT. OF BUSINESS ADMINISTRATION
EAST WEST UNIVERSITY


Subject: Submission of term paper on “Sara lee”Company




Dear Sir,
Here I am submitting our term paper on ““Sara lee”Company” prescribed by you
in your course. For this Purpose, we have gone through internet, different books,
articles, journals, interview of authorities and employees of the respective
organizations and class lecture sheets for the relevant information of the assigned
topic.


Please call me for any further information at your convenient time and place.


Yours truly,
Md. Yeasin Islam
2009-1-10-203
Mobile: 01736841739
                                  Introduction
Based in Downers Grove, Ill., Sara Lee Corporation is a global manufacturer and
marketer of high-quality, brand-name products for consumers throughout the world.

Our businesses are:

       North American Fresh Bakery
       North American Retail
       North American Foodservice
       International Beverage
       International Bakery
Sara Lee Corporation's leading brands are household names known around the globe. Our
preeminent brands are built on consumer needs and expectations, offering exceptional
quality and value. Our brands include Ball Park, Douwe Egberts, Hillshire Farm, Jimmy
Dean, Senseo and our namesake, Sara Lee.
Sara Lee Corporation builds and maintains leadership positions through innovation and
responsiveness. Some of our brands are decades - or even centuries - old, and many are
leaders in their respective categories.


                           Our Mission:
                  To simply delight you... every day
Our Vision: To be the first choice of consumers and customers around the world by
bringing together innovative ideas, continuous improvement and people who make things
happen.
Our Values:
 Act with INTEGRITY
      Use IMAGINATION
      be INCLUSIVE
 Work as a TEAM
      Have PASSION to excel

.




                                 Financial Information
Sara Lee Corporation stock is listed under the symbol SLE on the New York and Chicago
stock exchanges. The stock is also traded on the London exchange. Options are traded on
the American Stock Exchange. The corporation's daily trading activity, stock price and
dividend information are in the financial sections of most major newspapers. Quarterly
earnings reports and related news can be found in the Investors section of this Web site.
                                          History

Sara Lee was 8 years old when Charlie Lubin, a bakery entrepreneur, decided to name his
new line of cheesecakes after his daughter, Sara Lee. His company was purchased in
1956 by Consolidated Foods, where Mr. Lubin continued to serve as a senior executive
for many years. In 1985, Consolidated Foods changed its name to Sara Lee Corporation.
Although Sara Lee has never had a management role at the corporation, she has appeared
in some television advertisements for our bakery products. In her words, her father told
her the product “had to be perfect because he was naming it after me.” Today Sara Lee is
a philanthropist who spends most of her time supporting the education and advancement
of women and girls in science.




                                   Government Rule

The Sara Lee Corporate Governance Guidelines shown on this page contain key
provisions of Sara Lee's corporate governance principles. These principles, which have
been approved by Sara Lee's board of directors, provide the framework for the
governance of Sara Lee.

Sara Lee is committed to sound principles of corporate governance and we believe that
they are important to gaining and retaining the trust of investors, employees, customers
and suppliers. We also understand that there is a healthy and energetic debate about what
constitutes sound principles of corporate governance, and the Guidelines are reviewed on
a regular basis.




                               Our Products
                           Bakery ::

1Bistro Collection
2Bon Gateaux
3Bony
4Chef Pierre
5CroustiPâte
6Madame Brioche Martinez
7Rudy's Farm
8Sara Lee - Desserts
9Sunbeam
                           Beverage::

Bravo
Butter-Nut Cappuccino
Caboclo
Café Continental
Café do Ponto
Café Pilão
Cafitesse
Chat Noir
Douwe Egberts
Harris
Hornimans
Jacqmotte
Java Coast
Kanis & Gunnink
Kayo
Laurentis
Maison du Café
Marcilla
Maryland Club
Merrild
Moccona
Natreen
Natrena
Paradise
Piazza d'Oro
Pickwick
Prima
Seleto
Senseo
Soley
Steamers
Van Nelle
                                         Meats ::

Ball Park
Bryan
Deli d'Italia
Deli Perfect
Galileo
Gallo Salame
Hillshire Farm
Jimmy Dean
Kahn's
Mr. Turkey
R.B. Rice
Sara Lee - Deli
State Fair

                                      Environment

Sara Lee’s environmental programs are designed to optimize our use of all resources
while creating, packaging and distributing our products in a manner that lessens their
impact on the eco-system.


Our Commitment to the Environment
Design, source, produce, package and distribute our products in a manner that strives to
minimize their impact on the eco-system throughout their lifecycle.
                                    Sustainability Policy
“Sara Lee is committed to promoting wellness and nutrition, supporting our communities and protecting our planet in a
manner consistent with our core values.”

Wellness & Nutrition
        Offer a variety of wholesome, tasty and nutritious products to help consumers achieve their dietary goals.
        Promote healthful eating and more active lifestyles.
        Ensure the safety and quality of all our products.
Environment
        Design, source, produce, package and distribute our products in a manner that strives to minimize their impact
     on the eco-system throughout their lifecycle.
Social Responsibility
        Provide a workplace that is safe, diverse, inclusive and offers development opportunities for all.
        Promote responsible and ethical behavior in all business transactions.
        Support the communities where our employees live and work through volunteerism, financial support, product
     donations and working partnerships.
        Dialogue with our key stakeholders to increase the sustainability of our business.
                          Wellness & Nutrition
Wellness and nutrition at Sara Lee encompasses our efforts to provide the
best possible products to our consumers, to encourage balanced lifestyles
and to provide safe, quality products.


                 Our Commitment to Wellness & Nutrition
“Feed your healthier lifestyle with Sara Lee”
Sara Lee is working to provide an approach to healthier eating and balanced
lifestyles while demonstrating that great taste, high quality and good health
don’t have to be constant trade-offs. Our sustainability commitment to
wellness and nutrition includes:
Offering a variety of wholesome, tasty and nutritious products to help
consumers achieve their dietary goals by:
     Communicating openly, transparently and responsibly about our
   products with consumers, customers and stakeholders so they can make
   informed choices and;
     Leveraging science-based knowledge and recognized experts, together
   with consumer input, to develop and improve our products.
Promoting healthful eating and more active lifestyles by:
     Encouraging active, balanced lifestyles that include physical activity
   and responsible enjoyment of a variety of foods and beverages.
     Entering into strategic partnerships that advance our commitment and
   increase the reach of our wellness and nutrition efforts
Ensuring the safety and quality of all our products by:
     Providing product quality and safety.
We are dedicated to honoring our commitment and promoting healthful eating and active
lifestyles. With all that’s happening, we think you’ll agree it’s time to: “Feed your
healthier lifestyle with Sara Lee.”
                              Policies & Commitments
Global Environment Policy

Sara Lee Corporation provides high-quality, brand name products to people around the world. We strive to
serve our consumers and customers while protecting the environment in our global community. Sara Lee is
committed to comply with or exceed applicable legal requirements and to continue to improve
environmental performance in a sustainable manner that respects the earth and its finite resources.
Our Global Environmental Management System (GEMS) is a tool to help ensure environmental aspects are
integrated into our daily business. GEMS also ensures constant attention to reducing waste, optimizing
natural resource and energy usage, and minimizing the overall environmental impact of our business.

Sara Lee is further committed to working with our suppliers and engaging in dialogue with members of our
global community to make sound sustainable environmental progress. Our diligent adherence to this
commitment will help us maintain our position as a corporate leader in generating value for our customers,
shareholders and society.

Energy, Greenhouse Gases and Climate Change Policy
Scope
Sara Lee Corporation is a global manufacturer and marketer of high-quality, brand-named food and
beverage products. This policy pertains to all activities of Sara Lee Corporation that consume energy and
emit greenhouse gases.
Energy use and greenhouse gas emissions occur during each step of the life cycle of our products from raw
material to end-use. Because energy usage and greenhouse gas emissions can affect climate change, we are
committed to minimize energy usage and greenhouse gas emissions during the manufacture of our products
and to work with partners, suppliers, customers, consumers and stakeholders to help minimize their energy
usage and greenhouse gas emissions related to our products.

We will:
        Measure the energy usage and greenhouse gas emissions from our direct operations (GHG
    Protocol scope 1 and 2);
        Set energy use and greenhouse gas emissions goals for our direct operations and, where possible
    and relevant, associated indirect aspects (GHG Protocol scope 3);
        Reduce energy use and emission of greenhouse gases and their precursors by a combination of
    improved energy efficiency, technology change and the use of biofuels, biomass and other renewable
    energy;
        Consider energy usage and greenhouse gases in our decision-making processes for deployment of
    capital and new product planning;
        Engage our employees in a company-wide culture of responsible energy management;
        Work to help minimize energy and greenhouse gas emissions throughout the lifecycle of our
    products by engaging with partners, suppliers, customers, consumers and stakeholders;
        Consider adoption of carbon offset programs only when we are explicitly required to do so, and
    only when reliable certification standards and/or strict quality assurance schemes are available; and
        Understand the impact of energy and greenhouse gas trends and the risks they may pose on our
    business and the wider community.
Water Policy

Scope
Sara Lee Corporation is a global manufacturer and marketer of high-quality, brand-named food and
beverage products. This policy pertains to all activities of Sara Lee Corporation that consume or influence
the consumption of water within our operations and business processes worldwide.
Water is used in each step of the life cycle of our products – from raw material to end-use. Water is a scarce
and valuable natural resource and we are committed to optimizing the use of water associated with
sourcing, manufacturing and use of our products and to protect the water resources that we may impact.
Additionally, we will work with our partners, suppliers, customers, consumers and stakeholders to help
minimize their water usage related to our products.

We will:
         Measure the water use and wastewater discharge from our direct operations, including where
     water is sourced and wastewater is discharged;
         Understand the impact of global and local water resource trends (e.g. water availability,
     competition for finite resources) and risks to our operations posed by these trends;
         Assure that our water use and discharge activities respect the quality and availability of local water
     resources;
         Engage our employees in a company-wide culture of responsible water management;
         Maximize efficient use of water through a combination of improved product design, production
     efficiency, technology change and implementation of water best practices;
         Consider water aspects in our decision-making processes for deployment of capital and new
     product planning; and
         Engage our partners, suppliers, customers and stakeholders to improve water efficiency in the
     lifecycle of our products.
Waste Management Policy
Scope
Sara Lee Corporation is a global manufacturer and marketer of high-quality, brand-named food and
beverage products. This policy pertains to all Sara Lee Corporation operations and business processes that
consume resources and have the potential to produce wastes and by-products.

We are committed to eliminating wastes that are produced during the manufacture of our products,
minimizing the proportion of our wastes disposed in landfills and working with partners, suppliers,
customers, consumers and stakeholders to help minimize their waste generation during the lifecycle of our
products.

We will:
        Measure each waste stream produced from our direct operations;
        Understand the impact of global waste management trends on our business;
        Set goals to reduce the generation of wastes and disposal of our wastes in landfills;
        Apply the waste hierarchy (remove, reduce, reuse, recover and recycle) to minimize waste
     generation through a combination of improved product design, production efficiency, technology
     change and implementation of waste management best practices;
        Consider waste minimization and potential waste impacts when we deploy capital and design new
     products;
     Engage employees in a company-wide culture of responsible waste management; and
        Engage business partners, suppliers, customers and stakeholders to minimize waste generation
     throughout the lifecycle of our products.
Sustainable Packaging Policy
Scope
Sara Lee Corporation is a global manufacturer and marketer of high-quality, brand-named food and
beverage products. This policy pertains to all activities of Sara Lee Corporation that design, produce and
use packaging within our operations and business processes worldwide.

We use packaging to contain and protect our product quality and safety during production, transport and
storage, and to display information on our products. Packaging plays a vital role in brand recognition and
brand messages. Packaging can also be part of the product functionality. For example, ready-made
packaged food and single serve coffee solutions - providing a higher consumer convenience and can reduce
food waste. Packaging is a source of waste and environmental impact so we are committed to manage it in
the most responsible way possible.

We will:
        Support the implementation of sustainable packaging as defined by the Sustainable Packaging
    Coalition, of which we are a member company:
     Sustainable Packaging:
      o Is beneficial, safe & healthy for individuals and communities throughout its life cycle;
      o Meets market criteria for both performance and cost;
      o Is sourced, manufactured, transported, and recycled using renewable energy;
      o Optimizes the use of renewable or recycled source materials;
      o Is manufactured using clean production technologies and best practices;
      o Is made from materials healthy in all probable end of life scenarios;
      o Is physically designed to optimize materials and energy; and
      o Is effectively recovered and utilized in biological and/or industrial closed loop cycles.

        Improve the sustainability of our packaging by continually leveraging sustainability principals
     (5R’s - Remove, Reduce, Reuse, Renew and Recycle) and best practices during packaging design;
        Take into account that different materials will have different environmental impacts and choose
     materials with a lower impact, provided that other essential packaging requirements are not
     compromised;
        Take a holistic approach to packaging optimization by considering the environmental impact of
     the whole product in all life cycle stages, not just the packaging;
        Investigate new sustainable packaging solutions with bio-based raw materials that are recyclable,
     compostable or biodegradable and incorporate post-consumer recycled content;
        Together with our suppliers, actively work to eliminate Polyvinyl chloride (PVC) packaging and
     Bisphenol A (BPA) from packaging when an appropriate replacement is available and has been
     quality tested; and
        When appropriate, engage with our partners, suppliers, customers and stakeholders to minimize
     packaging waste throughout the lifecycle of our products.
 
Global Safety Policy
Sara Lee is committed to providing a safe and healthy work environment for its employees, contractors,
and visitors. Each facility, through its management team, must implement a safety program that includes
appropriate job risk analyses and training, meets or exceeds applicable laws and government regulations,
and complies with Sara Lee's own safety and health standards. We believe each job should be performed
safely and are committed to continuous improvement in our safety performance.

Because safety is everyone’s responsibility, each employee is responsible for observing the safety and
health rules and practices that apply to his or her job and work environment. Employees are responsible for
taking precautions necessary to protect themselves and their co-workers, including immediately reporting
accidents, injuries, and unsafe practices or conditions. Appropriate and timely action will be taken to
address known unsafe conditions.

The health and safety of all employees, and the quality and productivity demanded by consumers,
customers, and stakeholders, require each employee to report to work free from the influence of any
substance that could prevent him or her from conducting work activities safely and effectively.

Genetically Modified Ingredients (GMO) Policy

As a global company, Sara Lee must comply with the laws and business practices and structures of the
many countries in which we do business, while also taking into account consumer preferences and
operating costs. Because of this, we address genetically modified (GM) issues on a geography-by-
geography basis. In Europe, for example, local laws and supply chain structures often enable companies to
segregate commodities by genetic origin. In these markets, Sara Lee has contractual agreements with
suppliers aimed at purchasing only ingredients from conventional (non-GM) sources. By contrast, in the
United States raw materials are not segregated in the commodities market by their genetic origin. Like most
food manufacturers in this country, we purchase our ingredients based on factors such as regulatory
approval, quality, availability, and price. Regardless of the country in which we are doing business, Sara
Lee remains firmly committed to using only ingredients that have been evaluated for safety and approved
by all applicable regulatory authorities such as the U.S. FDA, USDA and EPA. We will continue to
monitor developments in this field and respond appropriately to new findings, and to comply with all
policies established by applicable food-safety regulators in the various markets we serve.

Animal Testing Policy

Sara Lee is committed to responsible and humane practices in the development, manufacturing and
marketing of our wide range of high-quality branded consumer products. Sara Lee does not use or request
animal testing on any products, ingredients or combination of ingredients, unless explicitly requested by
national or international regulatory authorities. In the rare event of such requests, it is Sara Lee’s policy to
explore all viable alternatives to conducting tests, including the reformulation of products and the use of
alternative ingredients.

Policy on Marketing to Children
The vast majority of our advertising is not focused on children. When we do advertise directly to children
under 12 years of age, we have set rigid standards that our Sara Lee products must meet:

        fill a recognized nutritional need in children’s diets
        non-meat containing products must meet FDA’s definition for “healthy”
        meat containing products must meet USDA criteria for “extra lean”; may have no more than 0.5
     grams of trans fat and no more than 480 milligrams of sodium per labeled serving and must contain
     10% or more of the Daily Value of one of the following per RACC: vitamin A, vitamin C, iron,
     calcium protein or dietary fiber.
All advertising directed to children must adhere to the guidelines of Children’s Advertising Review Unit
(CARU) of the Better Business Bureau.

Policy on Marketing in Schools

We will not market to children while at school. We do not conduct direct student marketing or brand
promotional activities in schools (preschool/kindergarten, primary schools, and secondary schools).

Human Rights Policy

As an international business, Sara Lee strives to respect and uphold the basic principles contained in the
Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at
Work, and laws in the jurisdictions in which we do business. Sara Lee recognizes our responsibilities both
to support and respect the protection of internationally proclaimed human rights within our sphere of
influence, and to avoid complicity in human rights abuses. To fulfill these responsibilities, Sara Lee is
committed to:

Treating employees with respect and dignity by, among other things:
        Prohibiting forced labor;
        Not employing anyone under the age of 15;
        Preventing discrimination in the workplace based on race, color, gender, national origin, age,
     religion, disability, veteran status, marital status, sexual orientation, and other protected
     characteristics;
        Protecting against physical, mental or emotional punishment and abuse;
        Respecting the rights of employees to associate freely; and
        Recognizing the lawful rights of employees to choose or not choose collective bargaining
     representation.
Working with suppliers and other business partners who commit to uphold and support these same
standards. Specifically, Sara Lee expects its suppliers and business partners to, among other things:

        Comply with all applicable laws and regulations, including local environmental, employment and
     safety laws;
        Not use forced labor of any kind;
        Not employ non-family workers under the age of 15;
        Avoid discrimination in the workplace based on race, color, gender, national origin, age, religion,
     disability, veteran status, marital status, sexual orientation, and other protected characteristics;
        Not use physical, mental or emotional abuse to discipline employees;
        Respect the rights of employees to associate freely;
        Recognize the lawful rights of employees to choose or not choose collective bargaining
     representation.
In addition, Sara Lee will favor competitive suppliers who seek to go beyond the minimum standards cited
above and who:

        Contribute to the continued education and betterment of employees;
        Have demonstrated a commitment to standards of environmental stewardship, diversity,
    employment, and community involvement that exceed the minimum legal requirements.
As appropriate, Sara Lee will monitor its own operations and those of its suppliers in order to assess
compliance with the principles set forth above, and to strive for continuous improvement of the working
conditions of Sara Lee’s employees and those of its suppliers and business partners.

Global Anti-Corruption Policy

This Sara Lee Corporation (“Sara Lee”) Global Anti-Corruption Policy (“Policy”) applies to all Sara Lee
officers, directors, employees, subsidiaries and affiliates[1] wherever located with respect to their activities
on behalf of Sara Lee (hereinafter collectively referred to as “Employees”). This Policy contains standards
of conduct and practices that must be followed in representing Sara Lee. It should be read in conjunction
with the Sara Lee Corporation Global Anti-Corruption Guidelines (“Guidelines”).
Sara Lee strives to maintain the highest possible ethical standards. Throughout its worldwide operations,
Sara Lee seeks to avoid even the appearance of impropriety in the actions of its Employees and Business
Partners. Accordingly, the prohibitions and requirements of this Policy are designed not merely to comply
with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other anti-corruption laws, but to avoid even the
appearance of questionable conduct, as espoused in Sara Lee’s Global Business Standards and Global
Standards for Business Partners, in connection with Sara Lee operations.

Sara Lee recognizes that our Employees are citizens of many countries and that our operations are subject
to many different laws, customs and cultures. In some countries, it may be both customary and expected
that gifts and entertainment of nominal value be given to government officials, customers and potential
customers in appropriate circumstances. While recognizing these aspects of doing business in a global
economy, it is essential also to keep in mind that the FCPA, other U.S. federal and state laws, and laws of
other countries mandate that Sara Lee’s dealings be in compliance with all applicable laws and the highest
standards of business ethics, including the specific compliance procedures outlined in this Policy and
Guidelines. In some countries, Sara Lee management may issue specific anti-corruption guidelines to
conform to local laws, but always consistent with the principles outlined in this Policy.

The Law Department[2] is available to assist in interpreting the Policy, Guidelines, the FCPA and local
anti-corruption laws. If, based on the information in this Policy, any Sara Lee employee is uncertain
whether a particular course of action might be in violation of law or of Sara Lee’s Global Business
Standards, the Law Department must be consulted in advance.

Unlawful, Improper or Unethical Activities
Engaging in any unlawful, improper or unethical activities or conduct, including, but not limited to, the
offering, authorizing, approving and payment of a bribe, on behalf of Sara Lee is strictly prohibited.
Employees are expected to conduct Sara Lee business in accordance with all applicable laws in the
countries in which Sara Lee does business. Employees must avoid any activity that might violate the
Policy, Guidelines, the FCPA or local anti-corruption laws.

Payments to Government Officials [3]
Sara Lee Employees and Business Partners are prohibited from directly or indirectly making, promising,
authorizing or offering anything of value to a government official on behalf of Sara Lee. Things of value
include, but are not limited to, money, stored-value cards, gifts, loans, loan guarantees, payment of debts,
transportation, use of property or equipment, job offers and entertainment. In addition, facilitating
payments, or nominal payments to low level government officials to encourage actual performance or more
expeditious performance of a routine government action, such as processing a permit, are strictly
prohibited.

This prohibition shall apply in all circumstances except the following limited situations. Note, however,
that even in the following circumstances, Employees must obtain advance written approval from the Law
Department.

Promotional and Marketing Expenses
Sara Lee may pay for the reasonable cost of a government official’s meals, lodging, entertainment or travel
if, and only if, the expenses are directly related to the promotion, demonstration or explanation of Sara Lee
products or services, or the performance of a contract with a government, or agency thereof. Such
promotional or marketing expenses must be legitimate and reasonable in light of routine business travel and
entertainment.

Promotional Gifts
Promotional gifts of nominal value may be given as a courtesy, as a token of regard or esteem, or to
promote goodwill. Such promotional gifts must be of nominal value and should generally bear Sara Lee’s
logo or trademark. Such promotional gifts may, however, not be given to influence any act or decision of a
government official in his or her official capacity. If in doubt, please contact the Law Department.

Political Contributions
Sara Lee does not make contributions to candidates for political office even when permitted by law.

Sara Lee respects the right of each of its Employees to participate in the political process and to engage in
political activities of their choosing. While involved in their personal civic and political affairs, however,
Employees must at all times make clear that their views and actions are their own, and not those of Sara
Lee. Accordingly, Employees and Business Partners may not make any political contributions in cash or
kind through or on behalf of Sara Lee.

Charitable Contributions
Sara Lee is committed to the communities in which it does business and permits reasonable donations to
charities. Employees must ensure that donations are given only to legitimate charities and are only used for
proper charitable purposes and not otherwise misapplied in violation of this Policy, the FCPA or local law.
Applicable procedures, including obtaining approval from the Law Department, are set forth in the
Guidelines.

Recordkeeping
Employees must ensure that Sara Lee’s books and records and internal controls meet the highest legal,
moral, ethical and professional standards. Employees must make and keep books, records and accounts
that, in reasonable detail, completely, accurately and fairly reflect all payments, expenses and transactions.

All transactions, including transactions involving government officials, must be recorded completely and
accurately so that the purpose and amount of any such payment is clear. No undisclosed or unrecorded
funds or assets of the company should be established for any purpose. False, misleading or artificial entries
should never be made in the books and records of Sara Lee for any reason.

Gifts Received from Government Officials
Employees should not accept gifts from government officials. If, under extraordinary circumstances (e.g.,
diplomatic protocol, ceremonial recognition), it is not practical for the employee to reject or return a gift,
the gift must be turned over promptly to Sara Lee Management, regardless of its nature or value.

Cash Payments
Cash payments of any kind to any third party, other than documented petty cash disbursements, are strictly
prohibited. Company checks shall not be written to “cash,” “bearer,” or anyone other than the party entitled
to payment.

Hiring Business Partners
Under certain circumstances as identified in the Guidelines, the engagement of a Business Partner may
require (a) a due diligence review to determine the Business Partner’s willingness to comply, and history of
compliance, with this Policy, the FCPA and local law, and (b) advance written approval from the Law
Department. Please consult the Guidelines for the applicable process to follow.

Acquisitions
FCPA and local law compliance is also crucial in the context of mergers, acquisitions, joint ventures or
other business combinations in which Sara Lee may engage. Whenever Sara Lee is acquiring an interest in
or entering into any of these business relationships, the Law Department must be notified of the potential
business relationship. Applicable procedures, including completing a due diligence review and obtaining
approval from the Law Department, are set forth in the Guidelines.

Compliance
Employees who violate this Policy or the Guidelines are subject to disciplinary action, up to and including
dismissal. Employees who suspect this Policy may have been violated have a duty to immediately notify
the highest manager in that country, the Law Department or the Global Business Practices Office.
Employees may also contact their local Business Practices Officer, the Resource Line at 1-800-285-7964,
(Business.Practices@saralee.com) or submit a report through www.SaraLeeResourceLine.com. Any person
who, in good faith, reports suspected legal, ethical or policy violations will not suffer any adverse
consequences for having done so.

--------------------------------------------------------------------------------
[1] Affiliates include joint ventures where Sara Lee has management responsibility.
[2] In this Policy, Law Department means the in-house lawyer or legal department responsible for your
business or function.
[3] For purposes of this Policy, a “government official” means any officer or employee of a government or
any department, agency or instrumentality thereof (which includes a government-owned or government-
controlled state enterprise) or of a “public international organization,” any person acting in an official
capacity for or on behalf of a government or government entity or of a public international organization,
any political party or party official or any candidate for political office. Therefore, government officials
include not only elected officials, but also consultants who hold government positions, employees of
companies owned by governments, political party officials, elected members of parliament, civil servants,
administrative and judicial officers, political candidates, members of the military and others. The term
“public international organization” includes such organizations as the World Bank, the International
Finance Corporation, the International Monetary Fund and the Inter-American Development Bank. The
family members and close personal friends of these government officials are also included in the definition
of “government official.” The Law Department should be contacted if there is a question as to whether a
person or organization should be treated as a government official, political party or party official, political
candidate or official of a public international organization for the purpose of this Policy.

Privacy Policy

Sites Covered
This Privacy Policy applies to this site, www.saralee.com, and all sites of the affiliates of Sara Lee
Corporation ("Sara Lee") that are linked to this site (collectively, the "Sites"). By viewing or using any Site,
you are agreeing to the terms set forth in this Privacy Policy. For other terms and conditions that apply to
your use of the Sites, please review our Legal Statement.

Personal Information Collected
For purposes of this Privacy Policy, "personal information" means any information by which you can be
personally identified, and includes your name, address, telephone number, e-mail address, account number
and similar information. Most Sites do not require that you submit personal information to Sara Lee;
however, some Sites may request personal information in order to help Sara Lee serve you more
effectively. Sara Lee generally collects personal information only when you voluntarily submit such
personal information to us, for example by submitting a comment or inquiry or completing a registration
form.

Use and Retention of Personal Information
It is Sara Lee's policy to maintain all personal information as confidential, regardless of the purpose for
which it is submitted, and to use such personal information only for the following purposes:
         For the specific purpose for which it was volunteered (for example to submit a comment, receive
      account information, purchase products, apply for employment, etc.);
         To track our visitors' use of the Sites for internal market research; and
         To notify our visitors of updates to the Sites or promotional product opportunities.
From time to time we may use the information we collect to notify you about other services we think you
will find valuable and interesting such as updates to the Site. However, if you do not want to receive this
information, you can let us know when you register by using the tick box provided.

It is Sara Lee's policy to keep personal information only for so long as needed for such purposes. Sara Lee
does not sell, rent or otherwise distribute to third parties personal information about visitors to the Sites,
except as needed for Sara Lee to provide the services for which such information was volunteered.
However, the Sites contain links to sites controlled by, and pages maintained by, independent third parties.
Sara Lee does not control use of information provided to such third parties. If you access other sites using
the links provided, the operators of these sites may collect information from you which will then be used by
them in accordance with their privacy policy, which may differ from ours.

Authorized third parties may need access to some of your personal information or that of your child under
age 12 to provide the services for which you/your child provided such information. For example, if you
purchase a product, we would use third party shippers to deliver the order to you and we would need to
provide the shipper with your name and address. It is Sara Lee’s policy to provide to third parties only that
amount of personal information that they require to complete the requested service or transaction.

Given the global nature of both the Internet and Sara Lee, using the Internet to collect and process Personal
Data usually involves the transmission of data on an international basis. By browsing the Site and
communicating electronically with us, you agree that we may export Personal Data to one or more of our
offices in other countries and process it there in accordance with this policy. Although data may be held in
countries that do not have strict data privacy laws, we do take steps to maintain the privacy and security of
your Personal Data.

Protection of Children’s Privacy
Sara Lee is very concerned about protecting children’s personal information. For this reason we limit the
personal information we collect from children 12 and under to only what is necessary to respond to their
online requests, such as a request for a screen saver, online newsletter, coupon or to enter a sweepstakes.
Sara Lee will delete the information from our system when the requested activity is completed. At times it
may be necessary to ask the child to provide an email address of a parent so we can notify the parent or
seek consent. We will not condition a child's participation in any online activity on the child's disclosure of
more personal information than is reasonably necessary to participate in that activity.

Parents are encouraged to regularly monitor and supervise their children's on-line activities.

Access Rights
You have a right to review personal information about you or your child under age 12 that is held by Sara
Lee. To obtain a copy of your personal information or that of your child under age 12, or to request deletion
of all personal information about you or such child in Sara Lee's possession, please submit your request in
the “Contact Us“ section of saralee.com.

Cookies
A "cookie" is a small piece of information sent by a web server to a web browser that enables the server to
collect information back from the browser. We use "cookies" to identify you when you visit the Site (our
server recognizes information regarding your domain name or access provider and e-mail address) to
understand how you and other visitors use the Site so that we can serve you better. Most Web browsers
automatically accept cookies but you can usually change your browser to prevent this.

Policy Revisions
Sara Lee reserves the right, at its discretion, to change, modify, add, or remove portions of this Privacy
Policy at any time. You should check this page periodically for changes. Your continued use of this Site
following the posting of changes to this Privacy Policy will mean that you accept those changes.
Sara Lee’s Compliance with the California Transparency in Supply Chains Act of 2010
Sara Lee supports fundamental human rights of all people and complies with employment laws in countries
in which it operates. Sara Lee's Global Business Standards specifically state that the company "will not
employ forced labor, including prison or bonded labor" and "will not allow physical punishment or abuse."
All employees are trained on the Global Business Standards upon hire and receive related training
throughout the course of their employment with the company.

To ensure compliance, Sara Lee's Global Standards for Business Partners, which is incorporated in all
contracts, state that "business partners will not use forced or involuntary labor whether bonded, prison or
indentured, including debt service." To ensure compliance, the company requires direct suppliers on a
rolling basis to respond to a Supplier Sustainability Questionnaire, which asks whether their organization
prohibits forced labor, slavery and trafficking. Sara Lee will not knowingly do business with suppliers that
allow forced labor, slavery or trafficking.

--------------------------------------------------------------------------------
[1] Compliance is monitored and appropriate disciplinary action would be taken in situations on non-
compliance.
[2] Additional third party independent unannounced audits are not reasonably necessary.

Commitments
Palm Oil Commitment
Palm oil is not a major raw ingredient for Sara Lee. Our use is modest, less than 0.05% of the world
production. We do not source palm oil directly; rather, we currently purchase palm oil-containing raw
materials primarily from suppliers that are RSPO members.

However, we recognize there are environmental and social sustainability issues associated with the
production of palm oil. Therefore, Sara Lee commits to support palm oil produced in an environmentally
and socially responsible manner by purchasing only from suppliers that are RSPO members by July, 2011.

Salt Reduction Commitment
Sara Lee Corp. is committed to reducing salt an average of 20 percent over the next five years across its
key categories of fresh bread, hot dogs, lunchmeat, breakfast foods and cooked sausage. This initiative will
encompass Sara Lee’s top food brands, including Jimmy Dean®, Ball Park®, Hillshire Farm® and Sara
Lee®. The effort builds on the successful salt reduction the company has already accomplished, which
includes the launch of a line of lower-sodium lunchmeats and sodium-reduced options of fresh bread
products.

Cage-Free Egg Commitment
Sara Lee Corp. has joined the national movement away from using eggs from caged hens by beginning a
new cage-free egg purchasing program. Sara Lee Corp. has committed to purchase more than one million
cage-free eggs per year. Sara Lee understands that animal welfare is important, which is why the company
is proud to switch more than a million of the eggs it uses to cage-free.

Healthy Weight Commitment Foundation
Sara Lee Corp. is part of the Healthy Weight Commitment Foundation (HWCF), which joined First Lady
Michelle Obama and the Partnership for a Healthier America to commit to reduce 1.5 trillion calories by
the end of 2015. HWCF manufacturing companies will pursue their calorie reduction goal by developing
and introducing lower-calorie options, changing recipes where possible to lower the calorie content of
current products, or reducing portion sizes of existing single serve products. These calorie reductions are in
comparison with what was available in the marketplace in 2008.

Sustainable Refrigeration Commitment
As a member of The Consumer Goods Forum (TCGF) we commit to the following resolution on
Sustainable Refrigeration:

As the Board of the Consumer Goods Forum, we recognize the major and increasing contribution to total
greenhouse gas emissions of HFCs and derivative chemical refrigerants. We are therefore taking action to
mobilize resources within our respective businesses to begin phasing-out HFC refrigerants as of 2015 and
replace them with non-HFC refrigerants (natural refrigerant alternatives) where these are legally allowed
and available for new purchases of point-of-sale units and large refrigeration installations.

We recognize that barriers exist to wide scale adoption of more climate-friendly refrigeration, namely
legislative restrictions in some markets, availability, cost, safety, maintenance and servicing. We will work
to overcome those barriers by strengthening existing collaborative platforms and initiatives. We also will
use our collective influence to encourage our supply base to develop natural refrigerant technologies that
meet our business demand under commercially viable conditions.

Deforestation Commitment
As a member of The Consumer Goods Forum (TCGF) we commit to the following resolution on
Deforestation:

As the Board of the Consumer Goods Forum we pledge to mobilize resources within our respective
businesses to help achieve zero net deforestation by 2020.

We will achieve this both by individual company initiatives and by working collectively in partnership with
governments and NGOs.

Together we will develop specific, time bound and cost effective action plans for the different challenges in
sourcing commodities like palm oil, soya, beef, paper and board in a sustainable fashion.

We will also work with other stakeholders – NGOs, Development Banks, Governments etc – to create
funding mechanisms and other practical schemes that will incentivize and assist forested countries to
conserve their natural assets and enable them to achieve the goal of zero net deforestation, whilst at the
same time meeting their goals for economic development.
                          Business Practice (Global not local)
Sara Lee’s Global Business Practices is encapsulated in a document called Global
Business Standards written in a simple manner, translated into more than
20 languages and distributed to every employee.

Sara Lee has a global infrastructure of Business Practices Officers overseeing the ethics
and compliance program in each of the company’s business units. They are responsible
for making sure every employee receives regular training, a key component of the
program. Employees learn from actual case studies about questionable behavior and use
the business practices program to agree on a proper course of action.

The company also has Business Practices Committees that meet regularly to assess their
organization’s efforts and to review and investigate inquiries, complaints and any
allegations of wrongdoing. Employees are encouraged to raise issues through a variety of
channels: their supervisor or manager, other managers, Human Resources, Internal Audit,
Legal Department, Business Practices Officer, or the Business Practices Resource Line at
+1.800.285.7964. Outside the United States, callers may contact the Resource Line toll-
free by using the AT&T Direct Access number, or by calling +1.312.345.5715 and
reversing the charges. Local toll-free numbers also are available in several countries.

The Resource Line is available worldwide 24 hours a day, seven days a week. Employees
may call confidentially or anonymously, send an email to
Business.Practices@saralee.com or post a report onto www.saraleeresourceline.com.

Sara Lee’s commitment to conducting business with integrity does not end with
employees. The Global Standards for Business Partners define the minimum
requirements for Sara Lee's business partners. Sara Lee believes in doing business with
those business partners, including suppliers, manufacturers, contractors, joint-venture
partners, agents, distributors and consultants, who embrace and demonstrate high
standards of ethical business behavior. Sara Lee expects all business partners to comply
with the law, do the right thing and communicate concerns about inappropriate business
practices promptly to the company. Living up to these responsibilities will help create
continued success for Sara Lee and its valued business partners.

Business partners, their employees and their business partners may contact the Resource
Line to report concerns or violations of the standards.
                              Conclusion ::
The goal of the Global Business Practices program is to support the Sara Lee culture

where doing the right thing is our everyday way of doing business. It emphasizes not

only compliance with laws, but also, more important, behavior consistent with Sara Lee’s

mission, vision and values. The program gives employees a framework within which to

make decisions. Sara lee provides food service based on standard quality it doesn’t focus

on local market which gives similarity of their product all over the world but it has some

dissimilarity with local product cause local products are made of customer based on

particular area.

                                     Reference ::
1.www.saralee.com

2.North America Contacts
Desserts: +1.800.323.7117
Foodservice: +1.800.261.4754
Meats: +1.800.925.3326
Senseo USA: +1.866.473.6736
Sara Lee Consumer Affairs
P.O. Box 3901
Peoria, IL 61612
3.International Contact
Sara Lee International
P.O. Box 2
3500 CA Utrecht
The Netherlands
+31.30.297.91.11

				
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