the csk code of good business conduct · csk believes in respectful, honest business relations, and...

THE CSK CODE OF GOOD BUSINESS CONDUCT

THE CSK CODEOF GOOD BUSINESS CONDUCT

TASTE CAN BUILD A BRIDGE

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A PROMISE TO THE WORLD AND OURSELVES

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At CSK we believe that everybody should be enjoying great taste in Dairy. This is our vision

supported by our strategic choices, our core values, and drive to further professionalize.

In taking care of good taste, CSK must consciously demonstrate responsible behavior to

maintain its reputation in the market, a workplace of choice and its trust from stakeholders.

The behavior of CSK is our combined behavior. The success and reputation of our company

therefore depends on our good business conduct every day again. And while doing our

work, we may all be confronted with obstacles, difficult choices and dilemmas. For these

moments, we have developed this code to serve as our guide. It is the responsibility of each

and every employee to act in line with this code. This means that all of us are required to

make sure we know and understand the CSK code of good business conduct.

It also means that you ask and discuss in case of doubt and speak up when you have a

concern.

Living our core values and following this code is pivotal in realizing our strategy and our

aspiration, and all of us can contribute in a meaningful way. Let us show the outside world

that we commit to and care for good taste. Not just in words, but in our actions.

Be part of the team, follow the code and apply it in your daily work.

Sanne Melles

Managing Director

CSK Food Enrichment

OUR PLEDGE

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BEING AWARE, UNDERSTANDING AND APPLYING

Text: Sanne Melles

CSK november 2016

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CONTENTS

OUR CODE OF GOOD BUSINESS CONDUCT 6We are authenticWe are entrepreneurialWe work togetherWe are responsibleWe are open

OUR PEOPLE AND OUR PLANET 101. Rights of our people2. Food safety and safety of our people3. Public activities 4. Legislation

OUR BUSINESS RELATIONS 165. Business relations6. Conflicts of interest7. Communication8. Gifts and entertainment9. Competition10. Bribery and corruption

OUR COMPANY 2011. Resources12. Protection of confidential information13. Data protection14. Integrity of financial reporting15. Prevention of fraud

WALK THE TALK! 24Common sensePersonal responsibility to understandQuestions regarding the CSK code of good business conduct

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OUR CODE OF GOOD BUSINESS CONDUCT

CSK believes in respectful, honest business relations, and in showing respect for the world in which we operate. In the following sections you will find the main rules of good businessconduct.

We take care of good taste, in existing as well as

in new markets. Good taste does not only refer to

the taste of cheese, but also to being honest and

transparent about our product towards consum-

ers and partners, and also to our conduct

in the market, towards our customers, as well

as our suppliers. Good taste is our aspiration

and passion, and we all contribute to, and have

responsibility in CSK’s success in the market

place.

Our success depends on the behavior of all of

us, living the core values that are the fundament

of all we do. That is the compass that makes CSK

and its people so recognizable. It enables us to

achieve an open partnership culture and stay

true to ourselves.

WE ARE AUTHENTICWe are the taste makers. We are true and real

and we are not seduced by big and glossy. We

are genuinely interested in our customers and

we want to help and add value. It’s all in the

genes of our people that are realizing good

taste.

WE ARE ENTREPRENEURIALWe are continuously developing and striving

to improve ourselves and our environment. We

measure and we know how well we are per-

forming and we share this. We are open towards

challenge.

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WE WORK TOGETHERWe strive for sustainable long term relationships,

both within our company as well as with our

business partners. We feel responsible to share

our expertise with our partners and we strive

for a sustainable place for each and every one

within the value chain.

WE ARE RESPONSIBLEThe impact of our products is enormous as with

few ingredients a large volume of dairy products

can be produced. This requires us to operate

strongly regulated with respect to quality and

safety and to act along this strong sense of

responsibility.

WE ARE OPENWe think it is important to share information in a

safe environment where we can learn from our

mistakes. We listen and we treat each other with

respect and we appreciate different points of

view.

CSK IS REAL AND AUTHENTIC

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OUR PEOPLE AND OUR PLANET

1. RIGHTS OF OUR PEOPLEWe believe our employees are our most

valuable asset. We embrace open communica-

tion with all employees and we encourage all

employees to develop themselves both profes-

sionally and personally. We believe in motivated

and well-trained employees to reach our

goals. At CSK, employees do not discriminate

or harass others based on, for example, race,

colour, gender, sexual orientation, age, religion,

political opinion, national, ethnic or social origin.

We expect every employee to directly address

any form of discrimination or harassment.

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2. FOOD SAFETY AND SAFETY OFOUR PEOPLEOur customers and ultimately consumers expect

us to deliver safe and high-quality products.

Therefore, our products must meet our strict

standards for product quality, consumer health and

food safety. Our focus on safety also includes the

safety of people: we are committed to a safe

working environment in which everyone takes

responsibility for their own safety as well as the

safety of others. Safety always comes first, both for

our products and our people.

3. PUBLIC ACTIVITIESWe do not support any political parties, political

organisations or their representatives, and make

no contribution, financial or otherwise, to groups

whose activities are intended to promote the

interests of a political party.

4. LEGISLATIONIn our efforts to realise our objectives, we

comply with the laws and regulations of the

countries in which we operate and the applica-

ble cross-border laws and regulations. In doing

so, we not only follow the letter, but also the

spirit of laws applicable to our activities.

PEOPLE ARE THE MOST VALUABLE ASSET

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ATTENTION

HEALTHCONFIDENCE

STABILITY

AWARENESS

TEAMWORKOWNERSHIP

BE SAFE

PROTECT

FIRST PRIORITY

THIS IS WHATSAFETY MEANSTO US

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OPEN

AGREEMENTS

HAPPINESS

STRUCTURE

CAREFUL

RESPONSIBLE

TOGETHER

TRUST

SAFE

PAY ATTENTION

PROTECTION

PEOPLE

FAMILY

COMMON SENSE

COMMITMENT

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OUR BUSINESS RELATIONS

5. BUSINESS RELATIONSWe want to establish and maintain fair and

mutually challenging relations with reliable

business partners that apply standards similar

to ours and contribute to our goals and integrity

commitments. We regularly evaluate business

partner relations in order to ensure this.

Furthermore, we monitor and adhere to trade

sanctions and we expect our business partners

to do this as well.

6. CONFLICTS OF INTERESTWorking at CSK means working and acting

impartially in the best interest of our company.

Sometimes this duty towards CSK can be in

conflict with more personal interests towards

family, friends or even ourselves. In such cases,

we talk about this in a transparent way with our

colleagues and manager. We are open, honest

and avoid even the appearance of a possible

conflict of interest.

7. COMMUNICATIONDirect or indirect communication about our com-

pany, for example on social media may affect

our reputation. For this reason, employees are

expected to be aware of the effect of communi-

cating about CSK, for example via social media

and to refrain from making statements that may

harm CSK or others.

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8. GIFTS AND ENTERTAINMENTWe only use gifts and entertainment to develop or

strengthen business relations, to show appreciation

or to create goodwill when appropriate. Appropriate

here means well-timed, moderate, infrequent and

not in excess of locally acceptable business

practices. We do not offer or accept gifts or

entertainment to put the recipient under pressure to

return a favour or to influence a business decision. In

relations with government officials we are even more

careful,especially because most of these officials are

not allowed to accept any gift or entertainment at all.

In all cases we only offer and accept gifts or enter-

tainment in conformity with the law and policy of the

recipient’s organisation as well as our own policy.

9. COMPETITIONWe perform our activities in an honest and

competitive manner within the framework of

applicable laws and regulations. No agreements

are made with competitors that hinder trade. We

compete based on independence, whereby the

performance of our products, the skills of our

employees, our services and performance are

decisive.

10. BRIBERY AND CORRUPTIONWe will not get involved in bribery or any other

form of corruption. Our employees will not

directly or indirectly accept or promise any

inappropriate advantage, financial or otherwise,

or provide the same to any person, company

nor government officials nor government

controlled entities, for the purpose of obtaining

or retaining orders or services.

WE WANT FAIR RELATIONS

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OUR COMPANY

11. RESOURCESOur resources are only used for work. These

company resources include cars, tools,

computers, office supplies and machines as well

as business related know-how and intellectual

property rights. We use the resources in a

careful way, for its intended business purpose

and such that our company is not at risk.

12. PROTECTION OF CONFIDENTIALINFORMATIONWe properly handle all confidential information

of our company and others and protect it

against unauthorised disclosure. Confidential

information such as know how, is a valuable

asset that provides a competitive advantage.

We only reveal our company confidential

information to anyone outside the company for

an allowed business purpose. Even within our

company, we only share confidential information

with people who have a “need to know”. We use

confidential information of others (for instance

our competitors) only in a legal and honest way.

Confidential information may not be provided

to anyone outside the organisation without

approval of the responsible Management Team

member.

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13. DATA PROTECTIONWe respect the privacy rights of employees,

members, consumers, customers, suppliers and

other business partners and therefore we treat

personal data confidentially. We only collect,

process, transmit and use personal data insofar

as reasonably required for communicated

business purposes. We respect the confidential

nature of any personal data and we take

responsibility to keep such data accurate,

complete, relevant and secure.

14.INTEGRITY OF FINANCIAL REPORTINGOur financial records and corresponding

documents must accurately reflect the nature

of the underlying transactions in accordance

with the established accounting & reporting

standards. Decisions relating to all business

transactions must be properly and timely

documented, and recorded and reported in an

accurate and complete manner.

15. PREVENTION OF FRAUDWe do not accept any behaviour intended to

deceive or mislead others. We expect each

employee to contribute to preventing fraud

within our company.

CONFIDENTIAL INFORMATIONIS VALUABLE PROPERTY

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WALK THE TALK

This code of good business conduct applies to all our employees. The responsibility of our Management Team is to ensure that the code is communicated, understood and complied with.

The general rules of good business conduct that are included in this code are the foundation; where necessary, compliance with this code is being secured in more detail in specific policy documents and procedures.

COMMON SENSEThis code of good business conduct describes

how we want to do business in a responsible

way and what is expected from all of us.

However, this code can never cover all situa-

tions we are confronted with in our daily work.

Common sense and professional personal

judgment remain necessary to make sure that

we daily demonstrate our company values, and

follow the spirit of the code.

TO PROTECT OUR REPUTATIONAND INCREASE SUCCESS

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PERSONAL RESPONSIBILITY TO UNDERSTANDEach of us is responsible for understanding the

letter and spirit of this code and to follow it. If

any part of this code is unclear, it is our personal

responsibility to ask for an explanation until we

fully understand it. Of course, our code also

applies to our managers, our Management

Team and Supervisory Board. Actually, all staff in

management positions have even more respon-

sibility, as they must lead by example, make

sure all employees have access to the code and

follow trainings. Next to this, a key responsibil-

ity of management is to create an open environ-

ment in which the employees can raise their

concerns or suspicions without fear of a

negative reaction.

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QUESTIONS REGARDING THE CSK CODE OF GOOD BUSINESS CONDUCTWe encourage our employees who have

concerns about a (suspected) violation of the

code, to speak up and express concerns. If you

are worried that something wrong or dangerous

is happening at work, it is your duty to report

and give CSK an opportunity to improve.

We understand that it takes courage to speak

up. That is why we want a safe company culture

without fear of punishment or unfair treatment

for raising such concerns.

If you have any questions or wish to raise an

issue, please discuss it with your manager. If it

is not possible to discuss a particular concern

with your manager, or if you feel uncomfortable

doing so, CSK has a ‘Speak Up policy’ that

allows you to raise the issue with a qualified

external professional. For the avoidance of

doubt, CSK will not tolerate negative conse-

quences for anyone who raises a concern in

good faith!

For more detailed guidelines on addressing

(alleged) violations of this code of conduct, we

refer you to the Speak Up policy.

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SPEAKUP!

INTRODUCTION

In taking care of good taste CSK aims to consciously demonstrate responsible behavior to maintain its reputation in the market, to remain a workplace of choice and to maintain its trust from stakeholders. For this purpose, we have developed the CSK code of good business conduct to serve as our guide. It is the responsibility of each and every employee to act in line with this code.

However, a situation may occur where you are

confronted with a violation of the code, or where

you are in doubt.

In such case we ask you to speak up!

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Speaking up is difficult, but equally an oppor-

tunity for CSK to professionalize, to resolve

non-compliance if applicable. Speaking up

therefore is important and requires a well-de-

fined process to ensure integrity of the process

and protect, if applicable, the people involved.

This Speak Up policy is implemented in order

to provide guidelines for expressing concerns

about an (alleged) violation of our CSK code of

good business conduct, without fear of discipli-

nary measures or unfair treatment.

Sanne Melles

Managing Director

CSK Food Enrichment

SPEAKING-UP IS IMPORTANT TO US

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THE SCOPE

The scope of this policy is to report all concerns

relating to conduct that conflicts with the

principles of the CSK code of good business

conduct, such as:

• Non-compliance with laws and regulations;

• Financial malpractices;

• Violation of integrity;

• Discrimination;

• Health and safety risks for the public or the

employee;

• Non-disclosure of malpractices.

It will not always be very clear whether any

particular action or conduct is contrary to the

principles of the code. Everyone will have to

form their own opinion in this respect. In such

events, CSK asks you to report your concerns in

good faith rather than keeping these to yourself.

If you have doubts as to whether a particular

action or conduct is contrary to the principles

of the CSK code of good business conduct,

you are requested to first discuss this with your

manager or the Compliance Officer ‘without

naming names’.

This policy may not be used for frivolous

accusations or personal grievances. In addition,

any employment disputes must be handled by

the employee’s line manager and/or the HR

department as these are not covered by this

Policy.

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REPORTING A POSSIBLE VIOLATION AND INVESTIGATION

In this section, the process of reporting and discussing a possible violation is described. In this

process, the following parties are important:

• You, the person reporting or seeking advice

about a possible violation

• Your manager, the person responsible for

compliance in your department, and respon-

sible for reporting noncompliance to the CSK

management team

• The Compliance Officer, a formal position

at CSK, responsible for overall compliance

at CSK. This role is assigned to the Finance

Director. The Compliance Officer is responsible

for the well-functioning of the Speak Up policy.

• The Integrity Committee, a formal body at CSK

to ensure possible violations of the CSK code

of good business conduct are objectively

discusse d. The committee consists of the

Compliance Officer, the HR Director, the QESH

manager, and the chair of the workers council..

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1. FIRST STEPIf an employee has a concern about non-

compliance with the CSK code of good business

conduct and this concern cannot be resolved

through the existing procedures, this employee is

requested to first discuss the matter with his/her

manager.

We believe this is the quickest way to clear up

any misunderstandings, the best way to ensure

a proper and transparent working environment

throughout the organisation, and finally the best

way to ensure continuous improvement at CSK.

2. OPTIONAL ESCALATIONIf you believe it is not possible or inappropriate to inform your manager or if you believe that a previous re-

port was not dealt within CSK’s interests, you are requested to contact CSK’s Compliance Officer.

• It is best if you discuss your concern in erson.

This is a confidential meeting that allows you

together to assess the scope of the issue,

as well as the level of confidentiality and

sensitivity. Alternatively, you may contact the

Compliance Officer by email or post.

• The Compliance Officer will discuss the issue

with the Integrity Committee. At your request,

your identity will be known only to the

Compliance Officer.

• CSK may choose to initiate an investigation to

confirm the noncompliance and to determine

measures to prevent re-occurrence.

• The Compliance Officer will notify the reporter

in writing of the status of the reported violation

within a period of eight weeks of submitting

the report. In cases in which it is not possible

to provide information about the status of

the case within eight weeks, the Compliance

Officer will so inform the reporter. A new date

will then be set on which the reporter will be

informed about the status.

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3. FINAL ESCALATIONIf the concern relates to CSK’s Compliance

Officer, you are requested to report directly to the

Managing Director of CSK. In case the concern

relates to the Managing Director, the report can

be made either to the CSK Compliance Officer or

the chairman of the Supervisory Board.

4. REPORT AND RESPONSETry to make the information you provide as

detailed and fact-based as possible to enable

your manager or the Compliance Officer to

assess the matter. This includes the back-

ground, history and the reason for your concern,

as well as names, dates, places and other

information.

5. CONTACTYou can contact the Compliance Officer via:

Email [email protected]

Post Compliance Officer CSK food enrichment

Pallasweg 1 8938 AS Leeuwarden The NetherlandsIf needed, CSK will always make it possible

for reports to be made in the reporter’s own

language.

The Compliance Officer will confirm receipt of

a report by sending back a reply to the reporter

within 5 (working) days.

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ASSURANCES FOR THE POSITION OF THE REPORTER

1. CONFIDENTIALITY AND ANONYMITYAll reports are handled confidentially. When you

report a violation to the Compliance Officer, your

identity will be known to him. The Compliance

Officer may not reveal your identity without your

permission, except in the following cases:

• in the event of a statutory obligation to that effect;

• if the report was not made in good faith;

• if this is required with a view to a serious

public interest.

When not revealing the reporter’s identity hinders

or complicates the investigation or forms an obsta-

cle to taking appropriate measures, the reporter

will be asked to agree to his identity being

revealed. If the reporter’s identity is revealed,

the relevant information will only be entrusted to

the persons who need this information to assess

the report.

2. PREVENTING DISCIPLINARYMEASURES OR UNFAIR TREATMENTCSK will not tolerate any disciplinary measures

or unfair treatment in response to any concerns

expressed in good faith. Employees who report

a violation will be protected and in no event will

they be prejudiced as a result of their report.

If the reporter is being punished or treated

unfairly by a particular person, this will have

consequences for that person.

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3. ABUSE OF THE SPEAK UP POLICYCSK presumes that employees will

express their concerns in good faith.

If the investigation does not reveal any

confirmation of specific concerns or if

these do not prove to be real, no action

will be taken against employees who

expressed their concerns in good faith.

4. ASSURANCES FOR THE POSITION OF THE PERSON / PERSONS TO WHOM THE REPORT RELATESThe Compliance Officer will inform the person

/ persons to whom the reported matter relates.

This will be done as soon as possible after

the relevant report, unless this would lead to a

serious hindrance of the investigation.

To protect the privacy of the persons involved,

CSK undertakes to the best of its ability and

in accordance with the applicable law. All

personal data obtained within the context of

the policy will only be used for the objectives

described in this policy and will only be

provided to the persons who need these data

for these objectives or in compliance with the

law or if this serves a serious public interest.

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EVALUATION

This Policy will be part of the annual compliance cycle in relation to the CSK code of good business

conduct. Each year, the Compliance Officer will submit an evaluation report on his activities to the

Supervisory Board.

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