Code of conduct

Astra Sweets N.V. stands for a high-quality product, produced in optimal working conditions. We set great store by innovation, safety, the environment, quality and customer orientation, which enables us to offer our customers high-quality sweets. We realise this with respect for our staff as well as the society in which we operate.

Objective of global business principles

Astra Sweets and all its employees propagate these global business principles to ensure that we are a high-quality food-producing company. We inform the general public, including our consumers and suppliers, of our global business principles, which are based on the Astra standards and values. We respect our staff and use these principles to promote fair and correct treatment of all our staff. Astra Sweets also requires its subsidiaries to act in accordance with its business principles, because we are accountable for the principles we have adopted. We comply with these principles so as to be able to continue to evaluate and develop our performance, so that we can safeguard improvement on an ongoing basis.

Scope

Astra Sweets applies the global business principles –tailored to the ETI Code (Ethical Trading Initiative) –to all sites and employees as well as to affiliated companies throughout the world.

Astra Sweets and its principles

1. Employment conditions
   • In all countries where Astra Sweets is active, it respects the local labour legislation. It also sees to it that all its suppliers and other partners respect this legislation too.
   • No employees younger than 16 years are employed at Astra Sweets. If local legislation stipulates a higher minimum age, Astra Sweets will meet these requirements and will also adhere to a higher minimum age. If the local law allows for a minimum age of 15 years or younger, we will still apply the minimum age of 16 years. Employees younger than 18 years shall not perform work at night.
   • Astra Sweets promotes a diverse and varied workforce. We assess our staff based on their knowledge and skills, which means that everyone is given equal opportunity to be employed and gain promotion. Moreover, we conduct an active policy prohibiting illegal discrimination, including bullying, and we record any reporting in respect of this.
   • Astra Sweets does not tolerate any form of physical or sexual harassment or maltreatment of its employees.
   • At Astra Sweets, we respect the freedom of association, which means that every employee is free to join an organisation that is permitted by law. We also comply with the rights of all social partners.
   • Any provisions on working hours per week and per day as well as minimum wages are complied with pursuant to local legislation. At Astra Sweets, all employees work in accordance with the statutory day and week schedules with sufficient breaks. Employees do not work any longer than the statutorily permitted limits and the overtime permitted by law. Sufficient rest entails at least one day of leave per week. Astra Sweets is committed to ensuring that every employee receives appropriate training.
   • All communications at Astra Sweets are in Dutch. Translations will be provided where this is required. Astra Sweets takes appropriate measures to distribute all communications, as well as our global principles, in an accessible way so that all employees can take cognisance of these.
   • Astra Sweets makes every effort for accurate and truthful communication on all its activities, including financial reporting. Astra Sweets fully cooperates with its auditors and does not conceal any information from them.
2. Safety and well-being in the workplace
   • Safety and well-being in the workplace are an integral part of all business activities within Astra Sweets.
   • Astra Sweets complies with all local and national safety laws.
   • Every Astra Sweets production location can call on a dedicated and well-educated safety expert who is accountable to the Operational Manager of the location.
   • All Astra Sweets production locations will develop the capacity to offer occupational medicine, internally or externally.
   • Employees and third parties in the workplace can turn to confidential counsellors and the HR Department if they have questions or comments concerning their well-being at work. The contact details of the confidential counsellors and HR employees are posted at various easily accessible places in the workplace.
   • All Astra Sweets facilities do their utmost to make the workplace as safe as possible. The safety of our staff and our products always comes first. This means there are sufficient drinking facilities, hygienic toilets, sufficient ventilation, emergency exits, the necessary safety facilities, first-aid provisions, and suitable workplaces.
   • Employees frequently attend training in safety and well-being in general as well as specific training on current subjects.
   • All Astra locations and facilities must have plans to address crises, including accidents, natural disasters and crime.
   • Astra Sweets and its affiliated companies have contingency plans in place for evacuations, spills and natural disasters.
   • Crisis plans and contingency plans are documented and practised, and all lists with the main persons responsible and their responsibilities must be up to date and easily accessible.
     All distress signals and plans are explained as clearly as possible.
3. Ethical principles
   • Astra Sweets has its head office in Belgium, but operates all over the world. In all countries where Astra Sweets is active, it respects the local legislation.
   • We treat our stakeholders with respect and dignity, and we expect from our suppliers and partners that they do likewise.
   • Astra Sweets competes in a fair and reasonable manner and sticks to the rules of the game. Our employees should not be carried away by business ambitions that make them violate the principles of fair competition. We do not pay bribes to private individuals or government officials, we do not use other people’s confidential information to gain improper advantage, we do not deceive others, and we do not discredit our competitors. We expect from third parties that act on behalf of Astra Sweets that they act along the same principles, and therefore we impose on them the standards we also impose on our own employees.
   • Astra Sweets and its employees avoid conflicts of interests. Employees are to avoid potential incompatibilities, such as personal or family relationships with suppliers or competitors. Astra Sweets employees are not allowed to perform activities that may cause them or others to gain personal benefit from confidential information concerning Astra Sweets.
   • Employees are neither allowed to accept financial benefits or presents from suppliers or customers, nor to offer these to gain benefits or enjoy preferential treatment. If employees are offered such presents, except customary promotional gifts of a low value, they are to notify their direct MC member or the plant manager.
   • Employees in a position with a higher ethical risk as described in the principles mentioned above are trained in how to deal with those risks.
   • All employees can contact their direct MC member or the plant manager to report practices that violate the aforementioned principles, without any fear of sanctions. All employees are informed about this during their induction programme. The contact’s details are posted on the bulletin boards and on the intranet. Employees also have the option of lodging a report anonymously via the NCS form that can be found in the health and safety system (AFP-GUF-02).
4. Society and the Environment
   • Astra Sweets does its utmost to be fair, honest and accurate in its communication with employees and the public. Employees are not allowed to make false or deceiving statements intentionally to the media or in public forums. Communication with the media or the financial community is reserved to the person designated for the purpose at Astra Sweets.
   • Regarding the environment, compliance with all statutory and other environmental obligations is a minimum requirement. We also commit ourselves to preventing environmental pollution and to improving environmental performance.
   • To reduce any negative environmental impact of our business activities, we use the best possible technical and economically viable measures regarding raw material and energy consumption.
   • Environmental plans are continuously formulated and modified according to new developments and opportunities and as a consequence of anomalies. The investigation of environmental incidents forms a part of this.
   • Employees are instructed so that they understand their role in environmental protection and process improvement, with a view to the avoidance of environmental damage. Important responsibilities must be assigned to trained staff.
5. Control and compliance with the principles
   • In the context of implementing the global Astra principles, these principles will be incorporated in the policy, procedures and activities of Astra Sweets and its affiliated companies. All companies affiliated to Astra, as well as the management and all staff, declare that they will comply with the policy and the established procedures. All these parties will subject themselves to inspections conducted by Astra.
   • Astra Sweets aspires to achieve a culture in which employees commit themselves to ethical behaviour. Employees are encouraged to report unethical behaviour, and Astra Sweets protects employees making such reports against retaliation.
   • This Ethics Code is to be a guideline for employees on how they should treat each other, customers, suppliers and partners.
   • If Astra Sweets is aware of actions or circumstances that are in conflict with these global business principles, the actions and circumstances will be investigated, and the Astra management will take appropriate corrective measures.
6. Astra Sweets’ expectations regarding customers and suppliers

Customers and suppliers of Astra Sweets NV are notified of this code of conduct, of which the 10 principles of the United Nations Global Compact are a part.

The 10 principles of the UN Global Compact:

Human rights

Arbeidsomstandigheden

• Principle 3: businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining.
• Principle 4: businesses should uphold the elimination of all forms of forced and compulsory labour.
• Principle 5: businesses should uphold the effective abolition of child labour.
• Principle 6: businesses should uphold the elimination of discrimination in respect of employment and occupation.

Environment

• Principle 7: businesses should support a precautionary approach to environmental challenges.
• Principle 8: businesses should undertake initiatives to promote greater environmental responsibility.
• Principle 9: businesses should encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

• Principle 10: businesses should work against corruption in all its forms, including extortion and bribery.