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.

Policy Whistleblowers

Introduction

This document defines the policy and procedure for reporting breaches of integrity within the entire Astra Sweets Group and is an appendix to the “Code of Conduct – Global Business Principles (BEL-C-01/0002)” through which Astra Sweets pursues an open and honest corporate culture.
The Directive (EU) 2019/1397 of October 23, 2019 on the protection of persons reporting breaches of Union law was transposed into the Belgian Law of November 28, 2022 on the protection of reporters of breaches of Union or national law established within a legal entity in the private sector.
Belgian legislation provides that every private sector company with at least 50 employees must, among other things, provide an internal reporting channel for so-called “whistleblowers” and ensure that they are protected, under penalty of sanctions, from reprisals.
To this end, Astra Sweets is setting up an internal reporting channel through the HR director, who is in charge of obtaining and handling the reports.
This procedure for internal reporting and follow-up, set out below, has been established after consultation and in consultation with the social partners.
In addition to this internal reporting channel, the reporter can also make an external report to the competent authorities or a disclosure. These two channels are also explained below.

Who can report?

Any person who is or has been employed by Astra Sweets or has performed work in any capacity whatsoever: employee, self-employed, interim or consultant, director, manager, as well as volunteers and paid or unpaid trainees and anyone working under the supervision and direction of contractors, subcontractors and suppliers of Astra Sweets may make a report and benefit from the protection offered by the law to that effect.
Reporters whose working relationship has yet to commence (in the event that information about violations was obtained during the recruitment process or other pre-contractual negotiations) may also make reports.

What can you report?

The report concerns information, including reasonable suspicions, about actual or potential violations listed below that have occurred or are highly likely to occur, as well as attempts to conceal such violations.

1) Violations related to the following areas:

• Public procurement;
• Financial services, products, and markets, prevention of money laundering and terrorist financing;
• Product safety and compliance;
• Transport safety;
• Environmental protection;
• Radiation protection and nuclear safety;
• Food and feed safety, animal health, and animal welfare;
• Public health;
• Consumer protection;
• Protection of privacy and personal data,
• Security of network and information systems;
• Combating tax fraud;
• Combating social fraud.

2) Violations that harm the financial interests of the Union, as referred to in Article 325 of the Treaty on the Functioning of the European Union and further explained in relevant Union measures and, where applicable, in national implementing provisions;

3) Violations related to the internal market, as referred to in Article 26(2) of the Treaty on the Functioning of the European Union, including breaches of Union rules on competition and state aid.

What protection does the whistleblower have?

The reporting procedures described below are organized to ensure maximum security and to protect the confidentiality and secrecy of the whistleblower’s identity, the report, and any mentioned third parties.

1) The whistleblower is protected against retaliation, threats, and attempts at retaliation. In the case of an anonymous report, you will be protected if you are identified.

The prohibited retaliatory actions are:

1. Suspension, temporary dismissal, termination, or similar measures;
2. Demotion or denial of promotion;
3. Reassignment of tasks, change of workplace location, salary reduction, change of working hours;
4. Denial of training;
5. Negative performance evaluation or employment reference;
6. Imposition or application of a disciplinary measure, reprimand, or other sanction, such as a financial penalty;
7. Coercion, intimidation, harassment, or exclusion;
8. Discrimination, adverse or unequal treatment;
9. Failure to convert a fixed-term employment contract into a permanent contract when the employee had a legitimate expectation of being offered a permanent position;
10. Non-renewal or early termination of a fixed-term employment contract;
11. Harm, including reputational damage, particularly on social media, or financial loss, including loss of revenue and income;
12. Blacklisting based on an informal or formal agreement within an entire sector or industry, preventing the person from finding employment in that sector or industry;
13. Early termination or cancellation of a contract for the supply of goods or services;
14. Revocation of a license or permit;
15. Psychiatric or medical referrals.

If such measures are taken, Astra Sweets must be able to demonstrate that the measures taken are not related to the report made.

2) The whistleblower also receives supportive measures through the Federal Institute for the Protection and Promotion of Human Rights, such as technical, psychological, media-related, and social support; full and independent information and advice that is easily accessible and free of charge regarding procedures; reminders of their rights concerning personal data; information on whistleblower protection and procedures; and financial assistance for whistleblowers in the context of legal proceedings.

3) The whistleblower receives protective measures against retaliation, including full exemption from liability for reporting or disclosing information; partial exemption from liability for obtaining or accessing information; and the right to appeal in case of retaliation.

The persons who actively support the whistleblower during the reporting procedure (e.g., a colleague or a member of an employee organization) or the whistleblower’s family members are entitled to the same protection.

Conditions for protection

The following conditions must be met in order to benefit from this protection:

• The whistleblower had reasonable grounds to believe that the reported information about violations was accurate at the time of reporting and that this information falls within the scope of the law;

And

• The report was made in accordance with the legislation.

Every whistleblower must act in good faith. Knowingly reporting or disclosing false information is punishable under the criminal code.

INTERNAL REPORTING PROCEDURE

How can you report?

Reports should be described as specifically as possible: who, what, where, and when, with any attachments or supporting information.

1) Reports can be submitted by completing the form on the Code of Conduct page on the Astra Sweets website via the following link: www.astrasweets.com/code-of-conduct/. This can also be done anonymously.

2) Reports can be submitted in writing via email to the following address: privacy@astrasweets.com, which is accessible only to members of the HR or Quality Department at Astra Sweets.

3) Reports can also be made verbally (a meeting will be scheduled) with one of the members of the Executive or HR Department.

For this, the whistleblower can contact one of the following persons:
HR Director

After a conversation with one of the above-mentioned persons, a report of the meeting may be made with the whistleblower’s consent. The whistleblower will have the opportunity to review, correct, and sign the report for approval.

4) By post to the following address:
Astra Sweets
TAV HR director
Bleukenlaan 15
2300 Turnhout

5) For employees working at Astra Sweets, it is also permitted to submit a report using the designated NCS form, which can be found in the company care system under document number AFP-GUHF-02. This form can be handed over to a supervisor or HR department staff, but it can also be anonymously deposited in the red HR mailbox (1st floor, Bleukenlaan 18).

When reporting a violation, the whistleblower is free to choose whether or not to disclose their identity.

Acknowledgement of receipt

The whistleblower will receive an acknowledgment of receipt from the Legal Department within 7 days of submitting the report.

Follow-up

The follow-up on reports is carried out by members of the HR Department, hereinafter referred to as report managers.
The report manager is responsible for following up on the report and maintaining communication with the whistleblower. If necessary, the report manager may request additional information from the whistleblower.
The report managers verify the accuracy of the statements made in the report and assess whether the reported violation can be addressed, including through measures such as an internal preliminary investigation, a full investigation, or legal action.
The report manager is required to provide feedback to the whistleblower within a reasonable timeframe, and no later than 3 months after the acknowledgment of receipt.

What are the responsibilities of the report managers?

• Trust is the core value. To ensure this, all members of the Human Resources Department are bound by a strict confidentiality obligation in the interest of the whistleblower.
• Report managers are required to analyze and investigate reports and must provide the whistleblower with feedback within a reasonable timeframe.
• The report managers prepare an anonymous annual report once per year. The governing body receives this annual report for informational purposes.
• All processing of reports is carried out in compliance with the GDPR. Unauthorized persons do not have access to the data.
• The report managers are required to record reports in a register. This register complies with confidentiality requirements. Reports are not stored longer than necessary for the investigation and resolution of the report.

The government also provides an external reporting channel. Additionally, the whistleblower can submit a report via public disclosure. The procedure for these two additional reporting channels is outlined below.

EXTERNAL REPORTING PROCEDURE

What is an external report?

The whistleblower may also report violations related to the areas listed above to the Federal Ombudsman or the competent authorities responsible for overseeing legislation.

An external report is recommended in the following cases:

• It is not possible to effectively address the violation through the internal reporting procedure; or
• The whistleblower believes they are at risk of retaliation through the internal reporting procedure; or
• EU law or national law requires the whistleblower to report the violation to the competent national authorities.

How can you report?

• Via the reporting form available on the website: www.federaalombudsman.be
• Via email: integriteit@federaalombudsman.be
• Verbally: The whistleblower can schedule an appointment via email at: integriteit@federaalombudsman.be or call the number 02 289 27 04 (Monday to Friday, from 9:00 AM to 12:30 PM and 1:00 PM to 5:00 PM).
• By post to the following address:
  Centrum Integriteit Federale Ombudsman
  Leuvenseweg 48 bus 6
  1000 Brussel

What are the responsibilities of the federal ombudsman?

• Receiving external reports and assessing their admissibility;
• Forwarding the report to the competent authorities if it meets the legal requirements;
• Ensuring follow-up of the external report in the absence of a competent authority and maintaining contact with the whistleblower to provide feedback or request additional information if necessary;
• Ensuring the protection provided by law;
• Providing the whistleblower with complete and independent information about the legal protection offered;
• Keeping the whistleblower’s identity confidential;
• Ensuring that all processing of the report complies with the GDPR;
• Recording reports in a register that meets confidentiality requirements.

PUBLIC DISCLOSURE

What is public disclosure?

Public disclosure refers to making information about the violation publicly accessible.

Specific conditions for the protection:

A whistleblower who makes a public disclosure is eligible for legal protection if the following conditions are met:

• The whistleblower first made an internal and external report, or immediately submitted an external report in accordance with the conditions described above, but no appropriate measures were taken within the legally prescribed timeframe;

Or

• The whistleblower has reasonable grounds to believe that the violation poses an imminent or real threat to the public interest;

And

• Due to the specific circumstances of the case, an external report could result in retaliation or the violation is unlikely to be effectively addressed.

Protection does not apply in cases where the whistleblower directly provides information to the press based on specific provisions that establish a system for the protection of freedom of expression and information.