Mondelez Global Master Defined Contribution Trust

The trust is governed by Mondelez International's internal benefits team and an Investment Committee composed of company officers and appointed fiduciaries. A third-party recordkeeper — typically one of the large retirement platforms — administers daily plan operations, participant recordkeeping, and the fund menu. Investment decisions, including fund additions and replacements, are subject to ERISA fiduciary standards and are documented in the plan's Investment Policy Statement. The specific committee members are not publicly listed, consistent with private corporate plan governance norms.

Manager selection follows an institutional RFP process run through the plan's investment consultant — often a firm like Aon, Mercer, or NEPC — which screens funds on fee structure, track record, capacity, and operational risk. Because 401(k) plans expose fiduciaries to participant litigation risk, the trust's Investment Committee relies heavily on consultant due diligence and ERISA Section 404(c) compliance frameworks. Final fund lineup decisions balance cost, historical performance, and diversification across the style box, with a strong preference for passive and factor-based strategies in the core equity and fixed-income tiers.

As a defined contribution plan, the trust does not pursue direct investments, co-investments, or alternative fund commitments in the style of a family office or endowment. All participant and employer contributions are directed into a predefined menu of regulated investment vehicles — typically mutual funds, collective investment trusts, and commingled pools — managed by third-party asset managers. Certain segments, such as the stable value fund, are structured through institutional separate accounts and wrap contracts negotiated at the trust level by Mondelez's treasury and benefits teams.

Mondelez inherited defined benefit pension obligations from Kraft Foods and continues to administer frozen legacy plans across the US and several international markets, primarily the UK and Canada. The defined contribution trust is operationally and legally separate from these defined benefit pools, with distinct governance, trustee structures, and asset allocations. Mondelez's annual report disclosed roughly $8.9 billion in aggregate global retirement obligations as of year-end 2022, with the defined contribution trust representing a growing portion as legacy DB plans are de-risked and wound down.

The trust files an annual Form 5500 with the US Department of Labor, which discloses total plan assets, participation counts, and a schedule of assets held. Additionally, Mondelez International files an 11-K annually with the SEC, which includes audited financial statements and notes on the plan's investment program. While individual manager holdings are aggregated in these filings, specific fund-level allocations and manager names are typically reported at the investment-option tier, not the underlying security level, in accordance with SEC and FASB guidance for defined contribution plans.