Issue Date

BLJNGE Part I Global Policies and Procedures

Section 1 Compliance Policies and Procedures

Prepared by Carla Heiss
Chapter 1.1 Code of Ethics Approved by Board of Directors - Corporate Governance
Committee

Code of Ethics
Table of Contents:
Introduction
Purpose
Required Business Conduct of Directors, Officers and Employees

Introduction
Bunge Limited has adopted the following Code of Ethics for itself and its subsidiaries and affiliates
(together "Bunge") to set forth its principles of business ethics. Bunge is a global company and must be
sensitive to the cultures and customs of the countries where it operates and respect the communities and
environment where it does business.

Purpose
The purpose of this Code is to establish minimum guidelines of business conduct required of all Bunge
directors, officers and employees. The members of the Bunge Limited Executive Committee are
responsible for implementing and monitoring compliance with this Code in their respectiveBunge
companies.

Required Business Conduct of Directors, Officers and Employees

1. All Bunge directors, officers and employees must comply with the following principles:
A. Conflicts of Interest. Directors, officers and employees cannot engage in any activity that
might create a conflict of interest, or the appearance of one, between the directors, officers and
employees and Bunge. A conflict of interest occurs when an individual'S private interests
interfere in any way, or even appear to interfere, with the interests of Bunge. A conflict of
interest can arise when a director, officer or employee takes action or has an interest that may
make it difficult to perform his or her Bunge work objectively and effectively. Conflicts of interest
also arise when a director, officer, employee or family member is in a position to receive
improper personal benefits as a result of his or her relationship with Bunge. Each director,
officer and employee is expected to avoid any outside activity, financial interest or relationship
that may present a possible conflict of interest or the appearance of a conflict. Each director,
officer and employee is required to disclose any conflict of interest to such officer or employee's
manager or the Legal Department and, in the case of a director, to the Legal Department.
While it is not feasible to specify all the activities that may give rise to a conflict of interest, or the
appearance of one, the fol/owing are some rules regarding specific areas where a conflict might occur.
These rules are not exhaustive and do not limit the generality of the conflict of interest policy.

i. Personal Investments. Ownership by a director, officer or employee (or a member of

his or her immediate family) of a financial or other beneficial interest in any enterprise
which does business with or is a competitor of Bunge is prohibited unless approved in
 writing by the Bunge Limited Executive Committee member responsible for the
appropriate Bunge company. However, ownership of less than 1% of the outstanding
equity securities (or in excess of 1% through mutual funds or similar non-discretionary,
undirected arrangements) of any publicly-traded company is permissible.
ii. Corporate Opportunities. Directors, officers and employees are prohibited from (a)
taking for themselves personally opportunities that are properly within the scope of
Bunge's activities, (b) using corporate property, position or confidential or proprietary
corporate information for personal gain, and (c) competing with Bunge. Directors, officers
and employees owe a duty to Bunge to advance its legitimate interests to the best of their
abilities.
iii.Business Affiliations. Except with the prior written approval of the Bunge Limited
Executive Committee member responsible for the appropriate Bunge company, it is
prohibited for any director, officer or employee to serve as a director, officer, consultant,
employee or in any other capacity in any enterprise which: (a) is a competitor of Bunge; or
(b) conducts or seeks to conduct business with Bunge; or (c) directly interferes or has the
appearance of interfering with the performance of their duties as a director, officer or
employee.
iv. Business Gifts. Acceptance by a director, officer or employee (or a member of his or
her immediate family) of gifts of a value that may appear to or tend to influence business
decisions or compromise independent judgment is prohibited. In certain environments,
the exchange of limited non-cash business courtesies may be acceptable. Bunge does
not seek, however, to improperly influence the decisions of its business constituents by
offering business courtesies, just as Bunge requires that the decisions of its directors,
officers and employees not be affected by having received a business courtesy. Any
business gift given by a Bunge employee must have the prior approval of the employee's
supervisor. Sales or marketing representatives may make business gifts of their regular
Bunge products or promotional items per established local policies for the purpose of
generating business goodwill. Following are some general guidelines for applying this
policy:
• Do not accept a gift related to a Bunge business of more than token value. Even
if the gift is less than token value, you should only accept it if it is consistent with
common business practice. Any offer to a director, officer or employee of a gift or
other business courtesy that exceeds $50 in value, or that seems inconsistent
with common business practices, should be immediately reported to the
employee's or officer's supervisor and, in the case of a director, the Legal
Department. Directors, officers and employees must also immediately report any
offers of cash, a fee or kickback to the Legal Department.
• Regarding meals and entertainment, a director, officer or employee may offer or
receive meals or simple entertainment provided that business is discussed and
that the activity has a clear business purpose. The guideline for the receipt of
meals or entertainment shall be normal industry practice in your locality
consistent with local legal or fiscal requirements. Any activity that might be
considered lavish or extravagant is not permitted. While the gift value limitations
described above do not strictly apply in the case of meals and entertainment,
those limitations are an indication of the reasonableness of the meals or
entertainment. Any offer to a director, officer or employee of meals or
entertainment that seems inconsistent with normal industry practice in your
locality, inconsistent with local legal or fiscal requirements or which shall involve
travel or overnight lodging is subject to prior approval by the employee's or
officer's supervisor and, in the case of a director, the Legal Department.
• A director, officer or employee also should not accept any money or cash
equivalents, or allow any member of their immediate family to accept anything
from any person with whom Bunge has a business relationship.
• Common sense and good judgment must be exercised when accepting
business-related meals or anything of token value to avoid any perception of
 impropriety or conflict of interest.
v. Confidential Information. Except as required in the performance of the regular
corporate duties of a director, officer or employee, disclosure or use without authorization
of any confidential information relating to Bunge, whether proprietary or privileged, is
prohibited. Confidential information includes all non-public information that might be of
use to competitors, or harmful to Bunge or its customers, if disclosed. This prohibition
applies specifically (but not exclusively) to inquiries made by the press, investment
analysts, investors or others in the financial community. This prohibition also applies to
information relating to third parties that Bunge has obtained under an obligation of
confidentiality, or as a result of a commercial relationship. The obligation to safeguard
confidential information continues after employment with Bunge ends. The obligation to
maintain the confidentiality of information may be subject to legal or regulatory
requirements to disclose that information. In such cases, the Legal Department will assist
in determining what disclosure is required.
vi. Acquisitions, Loans and Gifts from a Bunge Company. Except with the prior written
approval of the Bunge Limited Executive Committee member responsible for the
appropriate Bunge Company, a director, officer or employee (or any member of his or her
immediate family) may not acquire Bunge property or receive gifts from Bunge. Except
with the prior written approval of the Bunge Limited Executive Committee member
responsible for the appropriate Bunge Company, an employee (or any member of his or
her immediate family) may not receive loans from Bunge. No director or executive officer
may receive loans from Bunge under any circumstances.

B. Compliance with Laws. Bunge is committed to being a good corporate citizen of all the
countries in which it conducts business. Because of these commitment directors, officers and
employees must comply in all respects with all the laws, rules and regulations, including insider
trading, in each jurisdiction in which it does business, as well as comply with Bunge's policies
governing business activities abroad.
C. Fair Dealing and Integrity. One of Bunge's most valuable assets is its reputation for fairness
and integrity. Each employee, officer and director should deal fairly with Bunge's customers,
suppliers, competitors and employees. Employees, directors and officers should not take unfair
advantage of anyone through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts, or any other unfair-dealing practice. No actions shall be
taken by a director, officer or employee who could undermine that reputation in dealings with its
employees, customers, suppliers or governmental officials.
Bunge's policy is not to hire immediate family members of a Bunge officer or director without
required approvals by the Legal Department. Immediate family members cannot be employed
in jobs where one Bunge employee has effective control over any aspect of the related Bunge
employee's job. Related Bunge employees may not share responsibility for control or audit of
significant Bunge assets.
D. Protection and Proper Use of Bunge Assets. All employees, officers and directors should
protect Bunge's assets and ensure their efficient use. Theft, carelessness and waste have a
direct impact on Bunge's profitability. All of Bunge's assets should be used for legitimate
business purposes.

2. All transactions shall be properly approved and accurately reflected on Bunge's books and
records. Falsification of transactions and Bunge records or off-the-record trading or cash accounts
or other off-the-record business transactions is strictly prohibited and subject to disciplinary action
or dismissal.
3. All directors, officers and employees are responsible for ensuring the accuracy, completeness and
timeliness of Bunge's public disclosure. Any information which would be considered material to
Bunge's security holders, the SEC or the investment community must be reported to the
Disclosure Committee. Employees who come into possession of this information must report it to
their manager, who must report the information to the Disclosure Committee or a member of the
 Disclosure Committee. Directors and officers who come into possession of this information must
report it directly to the Disclosure Committee or a member of the Disclosure Committee.
4. Bunge actively promotes ethical behavior in all its business activities. Directors, officers and
employees are encouraged to speak to their managers, the Legal Department or other
appropriate personnel at any time if there is any doubt about the best course of action in a
particular situation. Directors, officers and employees are required to report violations of law,
rules, regulations and this Code to their managers, the Legal Department, senior management or
the Board, as appropriate. Every reasonable effort will be made to ensure the confidentiality of
those furnishing information. Bunge will not tolerate retaliation in any form against any person for
complaints or reports made in good faith.
S. Each member of the Bunge Limited Executive Committee who is aChief Executive Officer of a
Bunge operating division shall annually certify that he or she has implemented and monitored
compliance with this Code for all Bunge companies under his or her supervision and has reported
each material violation thereof to the Legal Department.
6. A waiver of this Code for executive officers or directors of Bunge will only be granted by the Board
of Directors or a committee of the Board and must be promptly disclosed to shareholders.
7. All directors, officers and employees of Bunge are required to adhere to this Code. Directors,
officers or employees who violate this Code will be subject to disciplinary action and possible
dismissal.