This Code of Conduct provides ethical working principles for the daily business in HKFoods Group (“HKFoods”).
1. INTRODUCTION
This Code of Conduct provides ethical working principles for the daily business in the HKFoods Group (“HKFoods”). The principles in this Code of Conduct provide a general framework that guides HKFoods on what constitutes appropriate business conduct and working behaviour. This Code of Conduct also represents HKFoods’ values - Inspire, Lead, Care, Deliver - and is integrated into our overall management as the basis for our policies and to foster our corporate culture.
HKFoods expects each of its employees, including management at all levels, to comply with these principles in their work and to take personal responsibility for following this Code of Conduct. The Code of Conduct covers HKFoods’ value chain from farm to fork, and HKFoods requires all its producers, suppliers, subcontractors and business partners to operate responsibly based on these principles. HKFoods expects all its suppliers to sign and commit to HKFoods Group’s Supplier Code of Conduct, which includes requirements of the same international conventions* and same guiding principles as this Code of Conduct.
HKFoods is committed to conducting its business in a sustainable and responsible manner and understands the long-term benefits and responsibilities of HKFoods and its stakeholders. HKFoods strives to ensure that all stakeholders will have confidence in that the entire Group operates responsibly, making an impact on its material sustainability matters. As part of its responsible conduct, HKFoods follows applicable laws and regulations in all areas of its operations, respects international conventions* and utilizes impact assessments and due diligence processes to address potential and actual adverse impacts.
* International Bill of Human Rights; UN Guiding Principles on Business and Human Rights; UN Convention on the Rights of the Child; UN Convention on the Elimination of All Forms of Discrimination against Women; OECD Guidelines for Multinational Enterprises; International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work; The ten principles of the UN Global Compact (UNGC)
2. HUMAN RIGHTS
HKFoods Group acknowledges its responsibility for managing adverse human rights impacts through its operations and products as well as adverse human rights impacts in its supply chain through its business relationships. HKFoods Group’s business and operations have a material impact on human rights of its personnel, customers, consumers, suppliers, producers, and communities in its operating countries. HKFoods respects international conventions* and is committed to continuously improving processes and practices to identify, prevent and mitigate human rights impacts that it may cause, contribute or be directly associated with, covering both its own operations and its value chain.
2.1. No Forced Labour
HKFoods does not accept any form of forced or compulsory labour, wage slavery, involuntary labour, modern slavery or human trafficking. HKFoods employees shall not be required to pay a deposit or be forced to hand over their identity documents to their employer. HKFoods employees are free to terminate their employment in accordance with applicable local laws and collective agreements.
2.2. No Child Labour
HKFoods does not allow the use of child labour. This means, for instance, that children under the age of 18 are not allowed to engage in tasks that are harmful to their health and safety, including night work. Children under the age of 15, the local legal minimum age for employment or the age of completing compulsory education, whichever is higher, must not work in a way that would hinder or adversely affect their schooling. HKFoods does not accept any employment that is contrary to the above.
2.3. No Discrimination
HKFoods is committed to acting against any form of discrimination and unfair or prejudicial treatment of people and groups based on characteristics such as race, gender, age or sexual orientation. All employees shall be treated with integrity, equality and respect, regardless of the type of employment contract. HKFoods takes measures to protect employees from discrimination, to advance diversity and inclusion and strives to acknowledge vulnerable groups in its operations and value chains.
2.4. No Harsh or Inhumane Treatment
Physical abuse or discipline, including the threat of such abuse, sexual or other harassment and verbal abuse or other forms of intimidation are prohibited at HKFoods. HKFoods takes measures to protect employees from all forms of bullying, harassment and other inhumane treatment, such as mental or physical coercion or abuse.
2.5. Freedom of opinion and expression
Freedom of opinion and expression is the cornerstone of a democratic society. Freedom of expression is a necessary condition for the realization of the principles of transparency and accountability that are, in turn, essential for the promotion and protection of human rights. HKFoods strives to ensure that all stakeholders have the right to voice and be heard as part of the engagement, and also secures opportunities for personnel to influence the company's decision-making in accordance with the requirements of local legislation, agreements and established practices.
3. EMPLOYEE RIGHTS
While human rights are universal rights that every individual is entitled to, employee rights are specific human rights that employees have in the workplace. More information and main principles are available in the Group Human Resource Policy.
3.1. Terms of Employment
At HKFoods, all work is performed on the basis of recognized employment relationship established through national laws and practices. All HKFoods employees are entitled to make and sign an employment contract in a language they understand, containing all mutually agreed terms and conditions of employment. Information provided to employees about their rights in the workplace shall follow local legal requirements and established practices.
3.2. Discriminatory Practices
All HKFoods employees are treated equally regardless of race, religion, national origin, age, disability, gender, marital status, pregnancy, parenthood, sexual orientation, union membership, political affiliation or any other personal characteristics. Discriminatory practices regarding recruitment, job assignment, training and development, promotion, remuneration and other benefits, or general conduct in the workplace, are not tolerated. Discrimination is mitigated and addressed if detected.
3.3. Wages
HKFoods pays its employees wages and benefits that meet national legal standards, including the existing statutory minimum wage, or industry benchmark standards. HKFoods recognizes that wages enable employees to meet basic needs in their country of residence. Regarding wages and payment methods, HKFoods employees are informed of the conditions of employment before employment begins. The conditions are also written into the employment contract.
3.4. Disciplinary Measures
All disciplinary measures against employees are recorded. Disciplinary measures may take the form of verbal or written warnings. However, deductions from wages as a disciplinary measure is not permitted at HKFoods. Deductions from wages are possible only if so provided by the relevant national law or with the express permission of the employee concerned. The manner and type of disciplinary measures to be used is described in more detail in the HR related guidelines and instructions.
3.5. Working Hours
HKFoods promotes the compliance of working hours with national legislation, applicable collective agreements and existing international conventions*. Overtime is voluntary at HKFoods and used in exceptional circumstances, such as during unexpected production peaks or other similar situations, provided that appropriate safeguards are in place to protect the health and safety of employees. Employees are paid overtime in accordance with applicable national legislation and collective agreements.
3.6. Health and Safety
HKFoods provides a safe and health-promoting working environment, taking into account general knowledge of the industry and specific risk factors for work-related injuries and illnesses, including possible exposures to substances and working conditions hazardous to health. Clear rules and procedures for health, safety, security, fire protection and emergency preparedness are established and followed. Access to occupational health care services is ensured for all employees according to local practices.
HKFoods takes work safety seriously and consistently takes steps to prevent accidents and injuries to health at workplace. Employees participate in the development of a healthy and safe workplace. This participation includes the involvement of health and safety committees and employee representatives, where they exist. Our commitments and operational programmes are set out in more detail in the Group Health and Safety Policy.
3.7. Right to Trade Union Freedom and Collective Bargaining
HKFoods respects the employees’ right to freedom of association and collective bargaining. HKFoods’ employees are free to join trade unions to represent them and choose their official representatives, in accordance with the applicable legislation and collective bargaining agreements in each country. Employees who act as official representatives are not to be discriminated against or disadvantaged in any way.
4. RESPONSIBILITY FOR ENVIRONMENT, ANIMALS AND PRODUCTS
4.1. Environmental impact mitigation
HKFoods aims to increase the positive and prevent or reduce the negative environmental impact of its operations in accordance with national and international regulations and environmental permits. Environmental incidents shall be prevented, and consideration is given to environmental aspects throughout the value chain, not only in HKFoods’ own activities.
HKFoods aims to reduce its climate-related impacts, such as greenhouse gas emissions, and to enhance its energy and material efficiency through a circular economy approach. HKFoods actively supports continuous measures to protect biodiversity and ecosystems and to improve water and waste management. The company takes care of chemicals and other hazardous substances and the treatment of emissions. The main principles of environmental management are defined in the Group Environmental Policy.
HKFoods recognizes that the environmental impact of meat products traces back to the farm level and HKFoods evaluates and takes actions to contribute to sustainable animal primary production in cooperation with producers.
4.2. Animal Health and Welfare
HKFoods requires the whole value chain to follow relevant laws and regulations, applicable standards and company policies and guidelines concerning the health and welfare of production animals. Engagement of the primary production community is the cornerstone for the health and welfare of production animals.
At HKFoods, the health and wellbeing of production animals is promoted throughout the value chain, including genetics, feeding, rearing conditions and animal care on farms, live animal transport and slaughterhouse operations. HKFoods closely follows the health of production animals from producers’ farms to production plants and provides guidance and support to stakeholders to prevent animal diseases.
At HKFoods, the welfare of animals is taken into account throughout the value chain by applying the internationally recognized Five Freedoms principles. Animals are kept and handled with due care and HKFoods does not tolerate harsh handling causing fear or stress to animals. Our main principles are set out in more detail in the Group Animal Welfare Policy.
4.3. Product Quality and Product Safety
HKFoods aims to ensure that all food produced for consumers and customers is safe. This means that HKFoods works constantly to secure the quality of HKFoods’ manufacturing processes and products. HKFoods has product safety and risk management systems in place in its production plants in accordance with the HACCP (Hazard Analysis and Critical Control Points) system. HKFoods continuously improves measures to secure consumer protection and product safety. HKFoods expects every HKFoods employee to follow the applicable product safety and hygiene rules. Our commitments and operational programmes are outlined in more detail in the Group Food Safety and Quality Policy.
HKFoods is committed to improving consumer and customer satisfaction and meeting consumer and customer expectations with high-quality, tasty, convenient, healthy and safe products. HKFoods is committed to fair and easy claims handling. It should be easy for customers and consumers to give and receive feedback on products and services.
HKFoods has tracing systems in place for raw materials and ingredients to provide information on the origin of products and to ensure timely action in the event of a product recall. When developing new products, HKFoods takes into consideration nutrition recommendations and the impact of products on consumer health.
5. ETHICS IN BUSINESS
5.1. Compliance with Laws and Regulations
HKFoods follows applicable laws and regulations in all areas of its operation and monitors changes in legislation. All employees must comply with the laws and regulations that apply to HKFoods’ operations and their own work.
5.2. Fair Competition
HKFoods supports fair competition and does not tolerate unfair practices to compete and win business. HKFoods competes within the framework of applicable competition laws.
HKFoods employees must not take part in any illegal practices that restrict competition.
5.3. Anti-corruption and Gifts
HKFoods does not tolerate any form of corruption such as bribery. HKFoods’ employees shall not accept, directly or indirectly, gifts, gratuities or other benefits or hospitality that may influence business decisions to promote or secure business. Employees may only give and receive personal gifts or hospitality of nominal value, provided that giving or receiving of gifts and hospitality is in compliance with applicable statutory rules and regulations. For instance, accepting travel tickets or accommodation costs from third parties is not allowed. More guidance on the giving and receiving of gifts is provided in a separate Group Approval Guideline.
5.4. Conflicts of Interest
Employees are expected to be business loyal to HKFoods. Employees must avoid all situations that could create or lead to a conflict of interest between HKFoods and the employee or other stakeholders, their family members, relatives or companies controlled by them. Conflicts of interest can take many forms and may involve financial interests and other personal interests.
5.5. Prevention of Fraudulent Activities
All fraudulent behaviour or activities are prohibited at HKFoods. Such violations will be assessed internally and reported to the authorities if the matter so requires.
5.6. Dealing with Stakeholders
HKFoods operates fairly and in co-operation with its employees, customers, suppliers and other stakeholders. This means that HKFoods respects its contractual commitments and business arrangements. HKFoods regularly audits or reviews its business partners and stakeholders in order to ensure compliance. Our main principles are outlined in more detail in the Group Purchase Policy.
6. COMMUNICATION AND INFORMATION SHARING
6.1. Transparency and Open Communication
Communication within the HKFoods and with stakeholders and authorities shall be open, transparent and factual. However, in some situations other considerations may restrict such openness and transparency, for example stock exchange rules, competitive considerations or the protection of confidential information. Sales, marketing and product information to consumers and end-users must be professional, comprehensive, accurate and never misleading.
6.2. Confidential Information, Information Security and Data Privacy
HKFoods pursues to carefully protect and handle confidential material and information. HKFoods also recognizes the importance of protecting and handling the confidential information exchanged with suppliers or stakeholders.
Employees must not disclose or use confidential information (e.g. business secrets or confidential private data) for the personal benefit of an employee or anyone other than HKFoods.
HKFoods has established a set of guidelines, procedures and controls for information security and data privacy to be followed. HKFoods takes information security and data privacy seriously and takes steps to prevent related incidents. Our main principles are outlined in more detail in the Group Information Security Policy and Group Data Privacy Policy.
6.3. Financial Information
HKFoods’ financial statements and communication are made accurately and in accordance with established procedures and legislation, as required by the corporate governance recommendations for listed companies issued by the Securities Market Association. HKFoods provides investors and other stakeholders with truthful, complete, up-to-date and accurate information about its business and operations.
7. ADDITIONAL INFORMATION AND NOTIFICATION OF BREACHES
In case HKFoods employee, business partner or other stakeholder suspects that a breach of this Code of Conduct has taken place, they are encouraged to share their concerns anonymously through HKFoods Fair Way, a grievance mechanism channel for possible breaches, if reporting through normal reporting channels is not possible. HKFoods Fair Way is available at https://report.whistleb.com/fi/HKFoods.
Concerns can be submitted without threat of retaliation or any other negative consequences. In the event of a breach of the Code of Conduct, either in HKFoods’ own business or in the supply chain of a business partner, HKFoods undertakes to take appropriate actions to end or prevent the breach, or at least minimize the extent of the violation.
If an HKFoods employee breaches this Code of Conduct, appropriate sanctions will be imposed, including possible termination of employment, and the breach may be reported to the relevant local authorities if HKFoods suspects that the employee’s conduct also violates relevant legislation. HKFoods sees that it and all its employees have an obligation to stop or prevent actions that could harm consumers, HKFoods’ customers or the reputation of HKFoods’ brands, and therefore employees are expected to report them.
If HKFoods employees have questions regarding the interpretation of or compliance with the Code of Conduct, employees should contact their supervisor or the HKFoods Group Legal function. Additional instructions of the application of this Code of Conduct may also be provided in separate policies and guidelines.
HKFoods Group’s Board of Directors has approved this Code of Conduct in February 2024. The Board may review and update the Code of Conduct whenever necessary.
8 February 2024
HKFoods Plc
Board of Directors
