Training-Contact-Action – Making Compliance and Integrity Part of Our Culture

We have dedicated compliance and integrity staff and five regional compliance officers around the world who work with senior management to implement our program. Our compliance and integrity team helps to ensure that our employees know what is expected of them and how to make the right decisions, especially when faced with difficult situations. Our mandatory in-person and online training programs help employees understand legal and ethical business practices.

Speaking Up and Being Heard

We expect employees to ask questions and raise concerns about business practices when they see something they think might be wrong. There may be times when employees are not comfortable speaking with their supervisors, compliance officers or human resources contacts, or simply wish to remain anonymous. Where not prohibited by local law, we have implemented a toll-free telephone “helpline” so that our employees can anonymously report instances of suspected wrongdoing or ask questions about compliance matters. Our helpline operates in more than 60 countries.

Listening, Investigating, Acting

In 2006, our compliance and integrity group received approximately 1,100 contacts from around the world through our “Speaking Up” channels. Many of these contacts were questions about our compliance policies and program or matters that we referred to other departments for handling.

Last year, we received more than 600 allegations of misconduct that required investigation. Some of these matters resulted in disciplinary action, including:

• 21 written warnings, and
• the separation of 72 employees from the company.

Report to Management and the Board

To ensure that senior management and the Board of Directors are aware of any potentially significant matters, our compliance and integrity group reports investigation to members of our executive team and the Audit Committee of the Board of Directors.

External Reports of Wrongdoing

Reports from people outside of company of suspected wrongdoing may also be brought to our attention in two ways:

By mail:

Compliance Department
Kraft Foods Inc.
Three Lakes Drive
Northfield, IL 60093
USA

By e-mail:

Kraft-Compliance@kraft.com