1. LEGAL COMPLIANCE AND BUSINESS ETHICS
We conduct our business within the framework of applicable laws, this Code of Conduct and our internal policies and guidelines.
We must always act in accordance with the legislation in each country where we operate. When this Code of Conduct sets standards that are higher than national legislation, we apply this Code of Conduct as long as our standards do not conflict with national laws. Local customs or practices can never take precedence over our standards, and we will never act in an illegal or unethical way, even if everyone else does so.
Corruption undermines legitimate business activities, distorts competition, ruins the reputation of companies and individuals, entails imprisonment and other civil and criminal liability, and prevents the realisation of human rights. Therefore, we must always comply with applicable anti-corruption laws and must not offer, nor accept, anything that could call into question our professionalism and ethical way of doing business. Orkla prohibits bribery and corruption in every form. We offer and accept only gifts and hospitality of modest value that have a clear professional purpose and that meet the requirements in our Anti-Corruption Manual. Facilitation payments are never accepted, even though they are legal in some countries.
We recognise the importance of personal data entrusted to us by customers, employees and others and must always respect the privacy of all individuals and the confidentiality of personal data. Therefore, we will process personal data honestly, ethically, with integrity and always /in compliance with applicable laws. If you handle consumer, employee or other personal information about individuals as part of your work, you have a responsibility to seek information about Orkla’s procedures for personal data processing.
We must always respect and comply with applicable competition laws, antitrust laws and marketing control laws. If you are involved in marketing, sales, purchasing or logistics activities, you have a responsibility to ensure that you are familiar with and understand applicable laws and the Orkla Competition Manual.
We must not trade, nor give advice to others about trading, in securities issued by Orkla or other companies on the basis of non-public information that we have obtained through our work which, if publicly known, could influence the price of the securities.
We must not take decisions or engage in activities based on personal interests. Employees and board members must notify their superior before accepting assignments outside Orkla, conducting personal affairs or making investments that could be in conflict with Orkla’s interests.
We must never disclose confidential information to anyone outside the company, unless such disclosure is required by law. Confidential information is information which is not, or should not be, known to the public. Examples of such information include business plans, budgets, marketing and sales programmes, recipes, design specifications and customer records.
Orkla is committed to correct and accurate accounting and reporting in accordance with applicable legislation in each country. All transactions must be fully and accurately documented and recorded in accordance with applicable laws and generally accepted accounting principles. False or misleading entries can be treated as fraud and are never acceptable.
2. CARE FOR PEOPLE
Protecting the health and safety of Orkla employees is a top priority and Orkla has a zero-incident vision. Meeting this vision is a responsibility shared by Orkla as an employer and Orkla’s employees. Therefore, we must comply with Orkla’s internal EHS policies and exercise sound judgement in our work. If you notice anything that may be a risk to somebody’s health and safety or the environment, you must share your concerns with your manager. This is not only a responsibility, but in many countries also a legal duty.
Orkla prohibits the use of alcohol and other intoxicating substances while at work for Orkla. Limited amounts of alcohol served as part of corporate hospitality or company events may be permissible, provided that the consumption is duly approved and will not be combined with operating machinery, driving or any other work that is incompatible with the consumption of alcohol.
Orkla aims for an inclusive working environment characterised by diversity and equality. To reach this goal, we must treat colleagues, customers, business partners and others with respect and be sensitive to and respectful of cultural differences. We must not engage in any form of harassment or other behaviour which could be perceived as offensive, threatening or degrading, including any form of unwanted attention of a sexual nature. Discrimination is never accepted. Discrimination includes any unequal treatment, preference or exclusion based on age, gender identity or expression, disability, sexual orientation, ethnicity, political or religious belief or any other characteristic.
The purchase of sexual services supports human trafficking, is a violation of human rights and poses a security risk. Orkla prohibits the purchase of sexual services in connection with work or business trips for Orkla. We must never accept sexual services paid for by others.
3. SUSTAINABILITY AND HUMAN RIGHTS
Orkla is committed to responsible business practices and to contributing to solve global health and sustainability challenges. We perform due diligence to identify, prevent and reduce the risk of being involved in breaches of human rights or environmental legislation within our own operations and value chains. We have established common policies, standards and procedures to manage our responsibility for food safety, environment, health and safety, responsible sourcing and for being a responsible employer. In addition, we have long-term sustainability goals which cover several important topics such as developing products for a healthy and sustainable lifestyle, increasing the use of energy from renewable sources, reducing food waste and contributing to sustainable production of raw materials, with due care for people, animal welfare and the environment.
We respect internationally recognised human rights in our operations, including our supply chain. We are a member of the United Nations Global Compact and support the United Nations Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the International Bill of Human Rights, as well as the core conventions of the International Labor Organization (ILO). Our approach to implementing these principles in our business is described in Orkla’s Responsible Employer and Human Rights Policy.
In an effort to maintain transparency and accountability, we disclose our progress on these matters by reporting our work in our annual Sustainability Report in accordance with the Global Reporting Initiative (GRI).
4. OUR BUSINESS PARTNERS
We expect all of our suppliers and other business partners to comply with applicable laws and our Supplier or Business Partner Code of Conduct and to respect internationally recognised human rights and ethical standards. Our business partners include suppliers, distributors, agents, consultants, contractors, joint venture partners and others we do business with. It is the responsibility of each manager to ensure that our business partners are vetted according to Orkla’s integrity and human rights due diligence procedures and that they are made aware of, and understand, our Supplier Code of Conduct or Business Partners Code of Conduct. Orkla is committed to only working with parties that fulfil these requirements. Failure to do so could result in a termination of the business relationship. All employees must immediately report known or suspected violations by a business partner of applicable laws, our Supplier Code of Conduct or Business Partner Code of Conduct.
5. HOW WE UPHOLD THIS CODE OF CONDUCT
This Code of Conduct is approved by the Board of Directors of Orkla ASA annually. It is the responsibility of the board of directors and CEO of each company to ensure that this Code of Conduct is implemented and complied with. The same applies to all internal policies and guidelines that embody the principles in this Code of Conduct. Managers at all levels have a particular responsibility to ensure that employees and other relevant parties are informed of this Code of Conduct and internal policies and guidelines and that activities in their area of responsibility are carried out in accordance with the foregoing and applicable laws.
Orkla, as employer, is responsible for providing to you, as employee, the information necessary for you to do your job. At the same time, you as employee have a responsibility to ensure that you understand the laws applicable to your work, as well as this Code of Conduct and Orkla’s internal policies and guidelines. It is your obligation to apply these principles in your daily work. You fulfil this obligation by actively searching for information that is relevant to your work and by participating in trainings offered by Orkla. The ability to fulfil these responsibilities will be considered in annual performance reviews of managers and other employees.
6. WE SEEK ADVICE AND REPORT CONCERNS
We all strive to do the right thing but knowing what is right can sometimes be difficult. Please speak to your manager, the Group Compliance Officer or a legal counsel at Group Legal & Compliance if you need advice. For advice on matters related to people, please contact the HR Department, either locally or at Orkla ASA, depending on the nature of your issue. If your question concerns EHS, you should contact the EHS Department at Orkla ASA.
All employees must immediately report known or suspected violations of applicable laws, this Code of Conduct and Orkla’s internal policies and guidelines to their manager or their manager’s manager. Depending on the nature of the violation, the matter may also be reported directly to the HR Department or the EHS Department at Orkla ASA. In addition, employees can report to Orkla’s whistle-blowing channel, which is a multi-lingual web service, available 24/7 and offers the possibility of filing a report anonymously: https://report.whistleb.com/en/orkla.
Orkla prohibits any form of retaliation against an employee for making a good faith report of misconduct. Retaliation can mean any unfavourable action, practice or omission that is a reaction to an employee’s reporting of an issue, for example; threats, harassment, discrimination, social exclusion or other unjust behaviour, warning, change of work tasks, relocation or degradation, suspension, termination, dismissal or disciplinary action. Acting in “good faith” means that you provide all of the information you have and believe to be true. You can report something you suspect and still be in good faith, even if your suspicion turns out to be unjustified.
Any report or suspicion concerning violations will be investigated properly and appropriate remedial measures will be taken. Such measures could include termination of the employment contract and reporting to relevant authorities. This applies not only to employees who violate applicable laws or this Code of Conduct but also to managers who disregard or tolerate such behaviour through negligence or knowledge.
Orkla Code of Conduct has been approved by the Board of Directors of Orkla ASA on 28 October 2020.