Act with integrity while still maintaining the confidentiality of GMCR information

The success and integrity of GMCR depend on the protection of confidential business information and trade secrets. As employees, directors, and officers of GMCR we are trusted with certain knowledge; it is our responsibility to uphold this trust and refrain from inappropriately divulging any information.

As a publicly traded company, GMCR is required to adhere to federal laws and regulations prohibiting the disclosure of “insider information.” The sending or posting of confidential information is against GMCR policy and is subject to laws and Securities and Exchange Commission (SEC) regulations with respect to insider information. These laws and rules make it illegal to use information - obtained as an employee – about the Company that is not generally available to the public for purposes of personal profit or to advise others in order that they may profit. GMCR submits periodic filings (10-Q’s, 10-K’s and 8-Ks) to the SEC that disclose Company information. Information not in these documents is confidential information and may not be discussed outside the Company by any GMCR employee. If you have questions about whether certain information may be disclosed, please check with our Chief Financial Officer or the VP of Human Resources and Organizational Development.

Following are some examples of confidential business information:

• Coffee Recipes
• Personnel information
• Customer and Vendor lists and information
• Sales information, organization, plans and forecasts
• Financial information and plans
• Marketing and sales information, strategies and plans
• New materials research and plans
• Pending plans, projects and proposals
• Research and design strategies and plans
• Production processes and plans