Reporting known or suspected violations of our Code of Ethics can
be a sensitive issue. However, you must recognize that violations could have a
profoundly adverse effect on our communities, our investors, our customers and
our co-workers, and on the livelihoods of all of us. Therefore, it is our
policy that you must promptly report all violations (or suspected violations)
of this Code of Ethics according to the reporting procedures described below.
It is so important that you report known or suspected violations of this Code
of Ethics that failure to do so will itself be treated as a violation of this
Code of Ethics. No disciplinary or other retaliatory action will be taken
against any person as a result of reporting in good faith any known or
suspected violation.
Every violation of the Code of Ethics will constitute a valid
ground for dismissal of the person violating this Code and could result in
civil or criminal action against that person.
Reporting an Accounting Problem or a Violation of Law
If you are aware of or suspect a breach of this Code of Ethics
that in any way involves our Company's financial statements or accounting
practices or any other violation of law, you must report it immediately to our
Chief Compliance Officer or to the Chairman of the Audit Committee of our Board
of Directors by calling the Code of Ethics HelpLine at 888.332.3980. The
toll-free HelpLine is answered by a third-party call center not affiliated with
Dean Foods Company and is available both to our U.S.-based and international
employees.
The operator who answers your call will prepare a written report
of your conversation and forward your complaint to the Chief Compliance
Officer, who will then issue your report to any other person(s) you designate.
You should give the operator as much detail as possible about the facts
surrounding your report or complaint. It will be helpful in our investigation
if you give your name to the operator; however, it is not necessary that you do
so. You may make your report anonymously. All anonymous reports will be investigated
as thoroughly as reports for which the caller is identified.
Reporting Other Violations of This Code of Ethics
If you are aware of or suspect a violation of this Code of Ethics that does not involve our Company's
financial accounting practices or any other violation of law, you should report
itto your immediate supervisor or your local Human Resources Manager. Or, if you do not feel comfortable discussing
the matter on a local level, you should report it to the Code of Ethics
HelpLine at 888.332.3980. Calls to this toll-free number may be made
anonymously.
Cooperation with Law Enforcement
It is our policy to cooperate with law enforcement agencies.
Senior management of our Company, in consultation with the General Counsel and
the Audit Committee of the Board of Directors, will conduct reviews and make necessary
determinations as to whether or not certain activity should be disclosed to law
enforcement or regulatory agencies for further investigation. If you believe
you have information that should be disclosed to a law enforcement agency, you
should contact your supervisor or call the Code of Ethics HelpLine.
To report an accounting or recordkeeping violation.
Code of Ethics HelpLine
888.332.3980
To report anything you believe to be a violation of the law
Code of Ethics HelpLine
888.332.3980
To report harassment or any other violation of our Code of
Ethics
Your local Management
Your Location
Your local Human Resources Manager or
Your Location
Code of Ethics HelpLine
888.332.3980
To report receipt of any confirmation request from an auditor
or one of our customers or suppliers
Chief Financial Officer
214.303.3400
To report any information request from a shareholder,
securities analyst or media representative
Investor Relations Dept
214.303.3438
To report any non-routine information request from or
investigation by a governmental agency
General Counsel
214.303.3400
International employees
Local Management
Your Location
Code of Ethics HelpLine
888.332.3980
Amendments to the Code of Ethics
Any Amendments to this Code of Ethics must be approved by the Dean
Foods Company Board of Directors. We reserve the right to change or rescind any
or all provisions of this Code of Ethics, and any other of our policies, rules
and procedures, at any time and without prior notice.