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Code of Conduct for Employees

Heuschen & Schrouff Foods Group BV

Version: September 2024

Message from the Board

At Heuschen & Schrouff Foods Group BV, we believe that responsible and sustainable business practices are the foundation of a successful company.

This also includes caring for everyone who contributes to the success and growth of our company.

That’s why we adhere to this Code of Conduct for Employees, which is based on the laws of the International Labour Organization (ILO). The Code of Conduct must form the basis of all our business activities and guarantee fair cooperation and the protection of our employees' rights, regardless of the contractual nature of their employment.

We consider these the most important principles of our company and will continuously strive to meet and exceed this Code of Conduct. In addition, we aim to establish and maintain long-lasting and good business relationships.

This Code of Conduct serves as a guideline to foster identification with our mission "One winning team, connecting People and Cultures" and core values. Moreover, this Code of Conduct provides clarity on the required behavior.

We expect our employees to accept this Code of Conduct and comply with the demands placed upon them.

Introduction

Heuschen & Schrouff Foods Group BV, including its subsidiaries and affiliated (Heuschen & Schrouff) entities, consider social and ecological sustainability to be of great importance. As an employee of this company, you are aware of your responsibility throughout the entire supply chain, particularly the responsibility to respect human rights and comply with social and environmental standards.

This Employee Code of Conduct therefore describes the basic principles for collaboration with colleagues and outlines what Heuschen & Schrouff Foods expects of you regarding human rights and environmental issues. We expect you to endorse all the standards and rules outlined in this Code.

The principles described in this Employee Code of Conduct are minimum standards for all our employees, including temporary workers, seasonal workers, and on-call workers.

All national, international, and other relevant laws and requirements applicable in the countries where business is conducted, as well as the principles in this Employee Code of Conduct, must be adhered to. The applicable rules or regulations most suited to achieve the protected interests will always prevail.

The standards are discussed below. We expect these standards to be proactively implemented and monitored through corresponding internal company procedures.

We also refer to our company's Employee Handbook, where the standards below are further explained. By signing an employment contract with Heuschen & Schrouff, you acknowledge and agree to this Code of Conduct. We expect you to comply with all the provisions in this document and the Employee Handbook.

Furthermore, you must adhere to all professional standards relevant to your field of work.

1. Work

1.1 Prohibition of Discrimination

No one should be discriminated against or disadvantaged based on age, disability, ethnic background, marital status, gender, skin color, membership in employee organizations, nationality, political beliefs, religion or ideology, sexual orientation, pregnancy, social background, other personal characteristics, or other objectively unlawful reasons. You must ensure equal treatment and equal opportunities in your work and avoid any form of discrimination.

1.2

Fair Treatment and Respect in All Relationships

You ensure that no one is subjected to harsh or inhumane treatment in the workplace. This includes, but is not limited to, sexual harassment, mental and physical coercion, insults, verbal abuse, forced labor, and child labor.

The right to terminate one's employment is respected.

1.3

Compensation and Working Hours

You will receive clear and regular information regarding the composition of your compensation. The obligations arising from the employment relationship must be documented in written form and provided to you as part of the employment contract.

Employees do not work beyond the legally permitted working hours and take the legally prescribed breaks. Official holidays are observed.

1.4

Safety and Health

Safety always comes first. You remain safe, fit, and healthy to work by avoiding involvement in situations that could negatively affect your ability to perform your job safely and responsibly. You take responsibility and report unsafe situations and conditions that could endanger the health or safety of colleagues or stakeholders. You also follow the applicable instructions at all times, such as safety guidelines, the wearing of personal protective equipment (PPE), and taking rest breaks.

If you are a supervisor, you ensure a safe work environment and compliance with relevant safety standards, and you provide sufficient protective measures to prevent excessive physical or mental exhaustion. Workplaces and equipment must comply with applicable laws and requirements, particularly fire safety standards and emergency response protocols.

1.5

Conflict of Interest and Secondary Employment

We respect employees' privacy and do not interfere directly with what you do in your free time. However, conflicts of interest can arise if your relationships, personal, social, and/or financial activities influence your business decisions and conduct. You are expected to perform

your duties objectively and effectively, avoiding secondary employment that could compromise your objectivity.

1.6 Works Council

Heuschen & Schrouff has a Works Council with the number of members appropriate to the size of the company. In the event of a vacancy, every employee (provided they meet the legal requirements) has the right to apply for an open Works Council position, which will be filled according to the election procedure.

1.7 Gifts, Entertainment, and Hospitality

Gifts and entertainment must always be modest and appropriate to the circumstances. They are used to strengthen business relationships and build goodwill. We offer and accept gifts and entertainment in a transparent manner. We will not offer or accept them if they could harm or damage the company’s reputation or interests, your own reputation or interests, or those of the recipient.

Accepting or offering reasonable business entertainment (lunch, dinner, theater, events) within the scope of business activities is only acceptable when done moderately, infrequently, and with the right intention and timing.

Special attention must be paid to government officials and employees of companies where the government is the majority shareholder. We do not give any gifts or entertainment to government officials. More information on accepting gifts can be found in Appendix 1 'Flowchart for Giving and Accepting Gifts.'

1.8 Company Resources and Private Use

You are responsible for the proper use and protection of Heuschen & Schrouff's resources. Treat these resources as you would your own. These resources include office and workplace furnishings but also company information, computers, mobile phones, financial resources, data, software, innovations, brands, and intellectual property rights, among others. Private use of a phone, computer, or other company equipment is permitted as long as the use, content, and amount do not impede, delay, or harm business activities and do not incur additional material costs for the company. If you're unsure whether private use is allowed, consult your supervisor.

1.9 Environmental Protection Laws

You strive to comply with applicable environmental laws and regulations and minimize the negative impact of your work on the environment. You embrace our sustainability and ESG strategy, ensuring that environmentally friendly and sustainable business practices are integrated into existing processes and procedures and followed. You also contribute to the development and dissemination of environmentally friendly technologies and strategies.

2. Compliance

2.1 Choosing Business Partners and Implementing Our Code of Conduct

In our company, we engage in fair and trusted business relationships with suppliers, customers, subcontractors, agents, and other business partners. Our business partners must adhere to the same or similar integrity values as defined in this Code of Conduct and help us achieve our goals and integrity commitments. When selecting a business partner, ensure that they at least meet the business integrity requirements outlined in our Supplier Code of Conduct.

You make every effort to ensure that the provisions of this Employee Code of Conduct and the Supplier Code of Conduct are adhered to throughout the supply chain.

2.2 Following the Code of Conduct and Responsibilities

Every employee is responsible for understanding and adhering to this Employee Code of Conduct. If any part is unclear, it is an individual’s duty to ask questions to fully understand this Code. Every employee is expected to support a culture of transparency, openness, and honesty. Failing to speak up in the event of a potential violation can only worsen the situation and erode trust. Therefore, we encourage you to report any suspected violation of laws, this Code of Conduct, or any of our policies to your direct supervisor.

Supervisors have additional responsibilities: you must communicate and promote the Code of Conduct and the underlying policies in your department(s). If you have questions about this Code of Conduct as a supervisor, contact our Corporate Compliance Officer. This role is held by the CFO within Heuschen & Schrouff.

2.3 Reporting a Situation or Unwanted Behavior

You must report any situation or behavior that:

May endanger the health or safety of a person or product;

Appears to violate laws and regulations for which Heuschen & Schrouff could be fined (such as fraud, theft, corruption, anti-competitive behavior, and similar matters) or result in significant financial or reputational damage.

2.4

Corrective Measures

In cases where a violation of this Employee Code of Conduct has occurred or is likely to occur, either in your discipline or in the supply chain, you will make every effort to end the violation as quickly as possible without delay, and to prevent or at least minimize its scope.

2.5 Audits

We expect every employee of Heuschen & Schrouff Foods Group BV to fully cooperate with all external and internal (risk-based) audits. You are required to provide all necessary information and transparency to conduct the audit.

2.6 Breach of Your Obligations

Any breach of the obligations under this Employee Code of Conduct gives Heuschen & Schrouff the right to take action. In the case of a serious violation, the sanction may be the termination of your employment contract, in accordance with the labor laws of the country where the employment contract is based.

3. Contact, Reports, and Complaints

If you become aware of violations of this Code of Conduct, please contact your supervisor and provide as many details as possible about the potential violation.

If reporting to your supervisor is not possible due to circumstances, report the incident to your supervisor's superior. If neither is available, you can report the issue to HR, the Compliance Officer, the Management/ELT, or our external confidential advisor, Cindy Schroeten (via email: c.schroeten@cssolutions.nl or phone: +31 (0) 6 46357772).

3.1 Address

Heuschen & Schrouff Foods Group BV

Sperwerweg 1

6374 AG Landgraaf (The Netherlands)

3.2

Declaration of Consent

By signing an employment contract with Heuschen & Schrouff, you confirm that you acknowledge and adhere to the Employee Code of Conduct of Heuschen & Schrouff Foods Group BV, to ensure a fair and responsible foundation for cooperation between myself and my colleagues.

Appendix 1: Flowchart for Giving and Accepting Gifts

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