MICREOS FOOD SAFETY STANDARDS OF BUSINESS CONDUCT POLICY
1. Policy Statement
i. MICREOS Food Safety is committed to ensuring that its business is conducted in all respects according to rigorous ethical, professional and legal standards.
ii. MICREOS Food Safety's standards of business conduct (the standards) are based on:
• Commitment to fair business practices
• Commitment to transparent business practices
• Commitment to honest business practices
• Respecting the confidentiality of information entrusted to the company
• Obeying the rule of law
• Commitment to accurate and honest reporting to our stakeholders.
iii. Guidance on the standards of business conduct policy can be found in the appendix below
i. The purpose of this policy is to set out the standards which MICREOS Food Safety will support and be guided by in the conduct of its business. It determines the responsibilities of group functions and business units in supporting those principles.
i. This policy applies to all members of MICREOS Food Safety worldwide. Further, MICREOS Food Safety expects equivalent standards of conduct from its business partners.
ii. Failure to comply with the standards of business conduct will be taken seriously and, depending upon the circumstances, could result in dismissal or other disciplinary action for employees and termination of relationships with business partners.
4. Underlying philosophy
i. The standards are intended as a statement of "how we do things around here". Upholding our standards of business conduct is one of the primary means by which we at MICREOS Food Safety live our core values. The standards are particularly applicable for the integrity value.
ii. Supporting the standards of business conduct is important for MICREOS Food Safety which seeks to conduct its business in a socially responsible manner. Moreover, a company's reputation is one of its most valuable assets. Maintaining high standards is one of MICREOS Food Safety's hallmarks, ensuring continued customer trust in us.
5. Corporate objectives
i. To ensure that all business units around the world manage and conduct their business in line with the standards of business conduct and, within the scope of the company's influence, expect its business partners to do the same.
6. Corporate principles and practice
i. All business units will determine how the standards of business conduct impact on their operations.
ii. Business units will inform the group's Chief Executive Officer and Chief Financial Officer about material standards of business conduct issues and will report on performance against this policy annually.
i. The Chief Executive Officer and Chief Financial Officer are the main sponsors of the policy.
ii. The group management team will monitor adherence to this policy (within the broader corporate social responsibility program), will support, the Chief Executive Officer and Chief Financial Officer in the discharge of their responsibilities and will provide guidance to the business units.
iii. The business unit heads will establish appropriate responsibilities within their unit for embedding and monitoring compliance with the standards.
Appendix to Micreos Food Safety's standards of business conduct policy
1. Policy Statement
• Staff are encouraged to make suggestions or raise serious business concerns.
• No one will be criticised or penalised for any loss of business which may result from adherence to these standards of business conduct.
ii. Examples of what MICREOS Food Safety's principles mean in practice include:
• Fair business practices. Eg in our relationships with our customers
• Provide our customers with a service hallmarked by integrity, quality and care.
• Deal with customer complaints seriously and promptly.
• Do not make misrepresentations to anyone.
• Promptly correct any misunderstandings if they are thought to have taken place through unclear communication. Eg in our relationships with our employees
• The group's human resources policies
• The group gives equal respect, consideration and opportunities to all its employees.
• Treat colleagues, customers and suppliers in the same manner.
• Do not tolerate sexual, physical or mental harassment.
• Select individuals for employment and promotion based on ability and experience, free from discrimination.
• Comply fully with the group's high standards in security, safety and occupational health. Any workplace hazards should be brought to management's attention.
• Protect the group's electronic communication equipment (including email, internet, bulletin boards, fax machines, file storage) from unauthorised external access or use. They must never be used for sending or receiving illegal, offensive or obscene materials (Group Security policy). Eg in our relationships with our suppliers
• The Group Purchasing policy applies.
• Respect and comply with business partners' contracts eg where possible, pay business partners within the timeframe agreed in the contract, comply with non-disclosure of information, comply with terms of licence to use products such as the prohibition of unlicensed copying of computer software, etc.
• Do not give or accept money, gifts, entertainment, loans or any other benefit or preferential treatment from any existing or potential customer, supplier or business associate of the group, other than occasional gifts of a modest value and entertainment on a modest scale as part of customary business practice.
• Gifts and entertainment should not place the recipient under any obligation and they should not be capable of being misconstrued. If in doubt, consult with a relevant senior manager who will decide on the action to be taken. Procedures for recording hospitality and gifts offered to and taken by employees should be maintained.
• Do not make agreements to purchase goods or services from a prospective supplier on condition that the supplier purchases products or services from the group. Suppliers may be customers of the group should they wish.
• Transparent business practices. Eg avoiding improper payments
• It is the company's policy not to make donations to political organiZations or for political causes.
• Never make any other improper payments such as bribes (whether or not illegal or customary in the territory concerned).
Honest business practices
Eg avoiding conflicts of interest
• Avoid situations in which financial or other personal interests or dealings are or may be in conflict with the interests of the group. When it is impossible to avoid such conflicts of interest, it should be ensured that these are clearly disclosed.
• Seek advice from a relevant senior manager in cases where a potential conflict of interest might occur eg any business or financial arrangements with a family member, an associate, a friend or close acquaintance who conducts business with the group. Another example would be holding shares in excess of 1% in a competitor or a company which introduces business, or supplies goods or services, to the group.
Eg anti-money laundering
• The Group Anti-money Laundering policy applies.
• Comply with all procedures required by local legislation to prevent money obtained through illegal means entering the legitimate economy.
Confidentiality of information
Eg customer data and "price-sensitive" information
• Unless proper authority is given, do not access, modify, disclose or make use of any confidential customer data, group, personal or supplier data for any purpose other than legitimately carrying out work-related duties.
• Do not disclose unpublished "price-sensitive" information to any other person except where it is necessary to do so to carry out your duties. If it is necessary to disclose this information, that person must first be advised that the information is confidential and that he or she will become subject to the same dealing and disclosure restrictions.
• Act with integrity upon information obtained and held on behalf of the group and be on guard to avoid careless or inadvertent disclosures which may damage the group's business or that of its customers or suppliers.
• Obey the rule of law Eg comply with relevant laws and agreements. In all of the countries in which we conduct business the Group Compliance policy applies.
• Accurate and honest reporting. Eg accounting standards.
• Record all transactions in a timely manner in the accounting records of the group according to generally accepted accounting principles.
• Provide supporting documents for all payments and transactions, clearly identifying and describing their nature and purpose.
• Reflect all group funds and bank balances of any kind in the books and records of the group. Accounting practices that suppress records, misstate operating results, obscure the nature of transactions or otherwise alter the substance of any transaction must not be adopted.
Mark Offerhaus CEO & Hans Veldhuyzen van Zanten CFO