Panera Bread

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(Aluminum Ammonium Sulfate Aluminium Potassium Sulfate)

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(GMP)

Ask whether the base is dairy, frozen yoghurt or sorbet.

(IMP)

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(Calcium Disodium EDTA/ Disodium Dihydrogen EDTA)

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(Glycerol and

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Polyglycerol Esters)

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(Sucrose Polyester

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Concentrate)

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(Mono, Di & Triglycerides, all forms)

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Ask whether it is cooked in butter or a meat stock rather than oil.

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(HFCS)

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Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask whether it is cooked in butter or a meat stock rather than oil.

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Ask whether the l-cysteine is plant-derived.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

(TBHQ)

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A Note from Niren Chaudhary, CEO b

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ƒ The Panera Way Our Stakeholders Our DEI Focus Our Results

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ƒ B

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ƒ B Creating the World We Want to See bb Our Progress

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Who is Covered Under this Code Team Member Responsibilities Manager Responsibilities

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And Reporting Violations

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Governance Code Waivers and Revisions

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O Equal Opportunity, Diversity and Respect Human Rights To report a known or suspected issue, call (888) 840-4151 or visit https://panerabread.allvoices.co C © 2026 Panera Bread | Code of Business Ethics & Conduct CONTENTS

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T Proprietary Information and Intellectual n Property Fraud, Waste and Misuse

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I of Bribery and Corruption Anti-Money f Laundering Commitment n

Ask whether it has honey in it, most other menus that describe this dish name honey.

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Competition Laws and Anti-Competitive Activities Gathering Competitive Information a l

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Ask what it is made with. The menu does not list the ingredients.

Our team members, guests, communities, shareholders and

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Make personal connections and eliminate barriers to exceed guests’ expectations Anticipate guests’ needs and get it right the first time If things go wrong, act urgently to resolve guest issues and rebuild trust

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Dream freely outside the constraints of our resources Be curious – have the courage to try new things and take bold actions Lead with head and heart insights that combine data and instincts

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Offer solutions, not problems Focus on what we can control and hold ourselves and others accountable Take ownership of our decisions and the outcomes

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Be vulnerable – ask for help, offer support and have each other’s back Speak with courage, listen with curiosity and disagree with respect Once we agree to a decision commit to execute and own it fully

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Create energy through positive spirit and fun Recognize and reward performance done the right way Coach and inspire each other to unlock our full potential

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Always assume positive intent and believe in people Deliver candid feedback with compassion Foster an environment of diversity openness and equity

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At Panera, we are committed to delivering exceptional service that engenders fierce brand love. This starts with Warmth for Guests, one of our guiding values, and ensuring all guests are treated with respect, fairness and kindness

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Our associates are the heart and soul of Panera. We are committed to creating a diverse, equitable and inclusive environment in which all associates are respected, celebrated for being their best authentic selves and inspired to reach their full potential J@rl

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Our Franchise partners, who operate about 53% of our more than 2,100 Panera bakery-cafes, are crucial in delivering an elevated experience for guests and associates, advancing our DEI strategy and achieving our mission of One Panera for a Healthier and Happier World

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We are committed to extending our Panera warmth beyond the walls of our bakery-cafes, support centers and FDFs and into our local and national communities through donations, fundraising and grant opportunities l1 We believe Panera has a responsibility to protect our natural resources and limit our environmental impact. In 2021

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We believe

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Creating value is the output of doing the right things the right way. By taking care of our associates and guests and serving our communities, our purpose reinforces our profits. People want to work for companies with purpose, consumers want to buy from them and investors want to invest in them. Our shareholders sustain us and we sustain them

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Representation in leadership

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Ask what it is made with. The menu does not list the ingredients.

Commitments that bring it to life

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Culturter ansformation commitmentotbs u ildf oundatwiohni let hinkinbgo ldt houghts takinbgr avaec tion

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Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Meaning that our DEI agenda is firmly entrenched in our business practices viewed as a growth enabler and championed by our leadership. In addition, our dream survey tells us that associates Associate Engagement Survey can feel our progress, with 75% saying they have a sense of belonging at Panera

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ƒ Three-year vision for DEI

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ƒ Commitment to track supplier diversity spend

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Is based on three primary commitments

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With Community outreach

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All three as we work to create the world we want to see

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In initiatives to enable its portfolio companies to exchange best practices including through the quarterly held ESG

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Monthly, sharing structured processes for integrating brand-centric DEI strategies into our businesses to extend the reach of our impact. Pamela Morris-Thornton is a co-leader of this group

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Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Our Ethics & Compliance Committee is responsible for administering this Code in an objective and consistent manner. The Committee is made up of a small group of senior leaders who enforce this Code o a known or suspected issue, call (888) 840-4151 or visit https://panerabread.allvoices.co C Panera Bread | Code of Business Ethics & Conduct

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A waiver is approved, we will disclose it if required i this Code must be approved by our parent company’s by law t Board of Directors. In the extremely rare situation that We and require regulations Team that Members apply to to us comply in the with locations n the laws, where rules we

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Our Team Members represent diverse ethnicities, races genders, experiences, backgrounds, beliefs and identities. This is also true of our guests. Our goal is to make everyone feel welcome, safe and at home, whether they are a Team Member or a guest Equal Opportunity, Diversity and Respect We are committed to providing equal employment opportunities to Team Members and applicants regardless of race, color, religion, age, gender, sex (including pregnancy, sexual orientation or gender identity) disability, genetic information (including medical history) national origin, citizenship, marital status, veteran status or any other characteristic that is protected by the laws and regulations that apply to us. Unwelcome conduct

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Handling, preparing and storing food and when cleaning

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And internal procedures, including e for the reporting of responsible manner while at work. Team Members must weapons in the work d environment comply with all occupational, health and safety laws accidents, injuries and unsafe equipment, practices or conditions. Acts or threats of violence will not be Team or sell Members illegal i drugs; must transfer, never use, sell, possess, use or possess transfer tolerated, nor will the possession of a firearm or other Company- substances f sponsored including prescription events); or drugs misuse or over-the- other n must never report to work or perform work while alcohol (unless approved by a senior manager for counter medications, while on our premises or when o under the influence of substances, including alcohol conducting our business. In addition, Team Members

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Avocado for warm bowl

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On my team. A childhood friend of my spouse has the perfect background for the position. Can I just recommend her to Human Resources?

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A potential conflict of interest in this situation because the candidate is your spouse’s childhood friend. You should not make or influence any decisions concerning this potential recruitment

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Relationship to your Human

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And remove yourself from the hiring decision. In addition it may not be possible for this person to take a position on a team that you lead

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Course of action

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All transactions, assets and liabilities are properly recorded on a timely basis all transactions are authorized by management and made in accordance with applicable laws and regulations; and

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Or statutory principles

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Ask what it is made with. The menu does not list the ingredients.

False or misleading information and must never change or n inspection, your manager please and Human immediately Resources contact Manager. the Legal Department

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With the Legal Department

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A Team Member will not be disciplined for refusing to pay a bribe, regardless of its impact on sales, profitability, project completion or other aspects of our business. The ultimate cost and long-term negative effect of bribery and corruption far individual Team Members. These penalties can include significant t outweigh any short-term benefits Both the USFCPA and the CFPOA may result in criminal and civil specific requirements n penalties, as well as reputational harm, for both the Company and fines and jail terms for those involved. Please carefully review our Anti-Corruption Compliance Policy for further guidance and for Members, but also for the actions e of third parties who represent

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W/ Arugula, Romaine, Kale, Radicchio, Tomatoes, Red Onions, Cucumbers & Reduced Fat Balsamic Vinaigrette, Salads, Panera Kids, Kids & Adults Menu

Ask for it without the yogurt add-on, and whether the dressing contains dairy, egg or anchovy, and whether cheese comes on it.

Ask whether anything is added to it, on its own this is vegan.

Ask whether anything is added to it, on its own this is vegan.

Black Bean Soup w/ Black Beans, Onions, Celery & Red Peppers, Bread Bowl, Soups

Ask whether the beans are cooked with lard, bacon or a meat stock.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the dough has milk, whey or honey in it.

Ask whether the batter is made with butter, milk or egg.

Ask which of the rolls are vegetable, and whether the sushi rice is seasoned with dashi.

Ask whether the beans are cooked with lard, bacon or a meat stock.

Low Fat Vegetarian Black Bean Soup w/ Black Beans, Vegetarian Broth, Onions & Red Bell Pepper, Cup, Soups, Panera Kids, Kids & Adults Menu

Ask whether the beans are cooked with lard, bacon or a meat stock.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether anything is added to it, on its own this is vegan.

Ask for it without the egg.

Ask whether the dough is made with milk, butter or egg, and whether the glaze contains butter or honey.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the sweets are set with gelatin or coated with shellac or carmine, gummies and marshmallows usually are.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether it contains butter, milk or egg.

Ask whether the batter is made with butter, milk or egg.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the batter is made with butter, milk or egg.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the dough contains milk, butter, egg or ghee.

Ask what it is made with. The menu does not list the ingredients.

Ask whether anything is added to it, on its own this is vegan.

Ask whether they are fried in beef fat or dusted with a seasoning that has milk in it.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask what dressing comes on it, oil and vinegar is the safe swap, and to leave off any cheese.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask what dressing comes on it, oil and vinegar is the safe swap, and to leave off any cheese.

Ask: World of Vegan lists it as vegan as sold; still ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the batter is made with butter, milk or egg.

Ask whether the batter is made with butter, milk or egg.

Ask whether the dough has milk in it, and to leave off any dairy cheese.

Ask which of the rolls are vegetable, and whether the sushi rice is seasoned with dashi.

Ask whether it is cooked in water or in milk.

Ask whether they are fried in beef fat or dusted with a seasoning that has milk in it.

Ask what it is made with. The menu does not list the ingredients.

Ask whether the batter is made with butter, milk or egg.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the batter is made with butter, milk or egg.

Ask whether anything is added to it, on its own this is vegan.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the dough contains milk, butter, egg or ghee.

Ask which of the rolls are vegetable, and whether the sushi rice is seasoned with dashi.

Ask which of the rolls are vegetable, and whether the sushi rice is seasoned with dashi.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the batter is made with butter, milk or egg.

Ask whether the batter is made with butter, milk or egg.

Ask whether the dough contains milk, butter or egg.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether it is a cream or honey liqueur, straight spirits are vegan.

Ask whether the dough contains milk, butter, egg or ghee.

W/ Strawberries, Pineapple, Cantaloupe & Honeydew, Breakfast Favorites, Breakfast

Ask whether anything is added to it, on its own this is vegan.

W/ Arugula, Romaine, Kale, Radicchio, Tomatoes, Red Onions, Cucumbers & Reduced Fat Balsamic Vinaigrette, Salads

Ask what dressing comes on it, oil and vinegar is the safe swap, and to leave off any cheese.

W/ Sesame Seeds, Bread, Artisan Breads, Freshly Baked Breads, From Our Bakery, 2 oz

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask whether the dough contains milk, butter, egg or ghee.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Ask which of the rolls are vegetable, and whether the sushi rice is seasoned with dashi.

Ask whether it is cooked in water or in milk.

Steel Cut Oatmeal w/ Strawberries, Pecans & Cinnamon Crunch Topping, Breakfast Favorites, Breakfast

Ask whether it is cooked in water or in milk.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

W/ Organic Quinoa, Brown Rice, Lentils, Tomato Sofrito, Kale, Spinach, Lemon & Soy Miso Broth, Bowls, Broth Bowls

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the broth is vegetable rather than meat or fish stock.

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Efforts focused on impact

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Continue to advance inclusivity in the global business community as a member of the Business for Inclusive Growth initiative (B4IG). This involvement allows us to share our best practices and learn from other global business leaders

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Through ready access to fresh water and a diet to maintain full health and vigor

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By providing an appropriate environment including shelter and a comfortable resting area

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Through prevention or rapid diagnosis and treatment

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By providing sufficient space proper facilities, and company of the animal's own kind

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By ensuring conditions and treatment that avoid mental suffering

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Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Ask what it is made with. The menu does not list the ingredients.

Forums

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If this situation were to become public, would t I be Is the situation consistent with our Guiding Values with commitments. our Guiding Values and Behaviors n and ESG and Behaviors and ESG commitments? comfortable? I ask that you read and commit to always act consistently Please face with refer legal, to this compliance Code to e answer and/or any ethical questions issues. that Never you the you Speak at the Up end Line of d this or any Code, of the should other resources you need additional we list for hesitate to reach out to the Legal Department, the Ethics Headshot of Marlene Gordon assistance i & Compliance Team, the Human Resources Department reports f made in good faith. You will find more information inn Thank you Remember that we do not tolerate any form of retaliation for our Non-Retaliation Policy Marlene Gordon Chief Legal Officer

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Ask what it is made with. The menu does not list the ingredients.

Panera Bread depends on its Team Members to follow the law and make the right decisions. This Code of Business Ethics & Conduct provides practical overviews of some of the legal and ethical standards Team Members must follow on a daily basis. This Code is in addition to other Panera Bread policies and procedures. It is your responsibility to ensure that you know, understand and comply with this Code in addition to the Panera Bread policies. A commitment to integrity, acting honestly and ethically and complying with the letter and the spirit of the law are critical to Panera Bread’s continued success

Ask whether the bread has milk or egg in it, and to leave off any cheese or mayo.

Should promptly report that information n there is, a violation or possible violation of any applicable laws, rules or regulations or our policies, including this Code uncover and promptly address e unethical conduct or Taking action to detect and prevent problems is part of our problems before they d occur and remedy situations that culture. Each one of us has a duty to help the Company violations of applicable laws, regulations, this Code and our other, and with i our guests, suppliers and other business policies. When you report concerns, you help us prevent more Team complex Member f and involved may to expose civil and our criminal organization liability and and the have already happened. You also help build trust with each partners. If left unaddressed, these issues can grow, become n reputational harm

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Interest could lead to serious problems both for us and the i and their disclosure requirements can be

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Members, for your own advantage or benefit other subjects not related to our business

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Ask what it is made with. The menu does not list the ingredients.

Low Fat Vegetarian Black Bean Soup w/ Black Beans, Vegetarian Broth, Onions & Red Bell Pepper, Bowl, Soups

Ask whether the beans are cooked with lard, bacon or a meat stock.