Support GMCR’s Purpose, Principles, Policies and Procedures and encourage our business partners to do the same

This Code of Ethics outlines assumptions and expectations of ethical behavior, but does not cover all possible ethical dilemmas. All GMCR employees, directors, and officers are responsible for recognizing possible violations of this code and for using basic integrity as a guide in all decisions actions, and relationships. As a company and as individuals we must work to bring our Purpose and Principles to life and to uphold the idea that doing the right thing is the way we do business. It is only through adhering to our own high standards that we are able to expect the same from our business partners and competitors.

If ethical choices or dilemmas arise that you are unsure about, please contact your Supervisor or the VP or Human Resources and Organizational Development. Any violations of this Code of Ethics may result in disciplinary action, up to and including termination of employment.

If you are aware of any suspected or known violations of the Code of Ethics or other company policies or guidelines, you must report such concerns either to the VP of Human Resources and Organizational Development, the of the Audit Committee or the 24-hour Business Conduct Line.

All concerns, questions, and complaints relating to matters referred to in this code will be taken seriously by GMCR, and resolution of issues will be sought promptly and confidentially. You are protected from retaliation if you are bringing a problem, question, or concern to light that relates to matters in this code, or other reports of misconduct, as long as it is done in good faith and in a business-like manner.

If this code is amended or modified, which can only occur with approval from the Board, you will be informed. Any waivers from this code, only granted by the Board, must be made in accordance with and disclosed to the extent required by any applicable laws and regulations. Any waivers granted for executive officers or directors must be promptly disclosed to shareholders in accordance with the rules of NASDAQ. Any amendments made to this code or waivers from this code granted to the company’s executive officers, financial officers, Controller, or any person performing similar functions, are subject to shareholder notification requirements, filing requirements, and other applicable provisions of federal securities laws.