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YOUR INDIVIDUAL RESPONSIBILITIES

As a manufacturer of food products, integrity means everything to us. Without a reputation for integrity, we would fail on store shelves. We expect you to have an unwavering commitment to ethical behavior, to act with honesty, and to comply with all laws and regulations applicable to our business. Strict compliance with this Code of Ethics is mandatory for all employees, officers and directors of Dean Foods Company and its subsidiaries-and is essential to our continued success.

We expect you to be informed about the laws applicable to your role in our organization. You must never knowingly take any action that violates the law or would enable another person or entity (such as a customer or supplier) to violate the law. Remember that violations of law can carry substantial criminal and civil penalties for both our Company and any individual who causes or allows such violation.

You are responsible for your own conduct in complying with this Code of Ethics. No one has the authority to order that you violate this Code of Ethics. In fact, any attempt (successful or not) by any person to influence another to violate this Code of Ethics is itself a violation. No one will be excused for violating this Code of Ethics for any reason. And if you are a supervisor or manager, it is your responsibility to ensure that your employees understand and comply with this Code of Ethics at all times.

If asked by your supervisor, our Legal Department or a member of our Board of Directors to cooperate with an investigation being conducted in connection with an actual or suspected violation of this Code of Ethics or the law, regardless of whether it is an internal investigation being conducted by our Company or an investigation being conducted by a governmental agency, we require that you fully cooperate. Failure to cooperate will be deemed a violation of this Code of Ethics and may result in termination of your employment.

Finally, you are responsible for promptly reporting any known or suspected violations of this Code of Ethics according to the reporting procedures contained in this booklet. Failure to report a known violation of this Code of Ethics is itself a violation. If you are ever in doubt as to whether or not a certain action violates this Code of Ethics, consult your supervisor, your plant manager or the Code of Ethics HelpLine. Contact information is found on page 18.


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