COMPANY POLICY

Comprehensive Business Practices are at the Heart of our CSR Policies

The success of our business and CSR strategies is inextricably linked to how we are perceived by our stakeholders and our ability to uphold the highest ethical standards in our business practices.

Nuts & More Code of Ethics

Created in 2021 and regularly updated, the Code of Ethics establishes the foundation of the company’s core values. It requires all employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities – based on the following basic principles:

• Respect for individuals & our stakeholders
• Respect for the environment
• Valuing Integrity
• An appreciation of creativity

The Code of Ethics details specific rules to guide employees in their day-to-day activities. Several additional key policies – including a Whistleblower Policy; Anti-Corruption Policy and Manual; and Ethical Sourcing Policy – underline our reputation for uncompromising integrity.

Financial Charter

Nuts & More has published an Ethics Charter specific to financial personnel and activities, as an extension of the Company’s Code of Ethics. The Financial Ethics Charter was first published in January 2021, is signed by the Chief Executive Officer and the Chief Financial Officer, and is distributed to key individuals within the finance department.

This policy promotes the following rules:

• acting honestly and with integrity and avoiding conflicts of interest;
• providing accurate, complete and objective information;
• compliance with all rules and regulations, public and private, to which the company is subject;
• acting in good faith without misrepresenting material facts or allowing one’s judgement to be unduly influenced;
• respecting confidentiality of information;
• sharing and maintaining appropriate knowledge and skills;
• promoting ethical behaviour in one’s working environment;
• using and controlling responsibly assets under one’s supervisions; and
• reporting known or suspected violations of the Charter.

Compliance Committee

The company also set up an Ethics Compliance Committee in 2021, which is responsible for all ethical issues related to Nuts & More’s activities and which is governed by the Code of Ethics and the Charter for the Ethics Compliance Committee. This includes implementing any new policies if needed, training on existing policies, and investigating any and all reports of unethical behaviour. It meets at least four times per year and more frequently when required.

As of November 1st, 2023, the Ethics & Compliance Committee comprises of:

• Sushil (Chair)
• Lucy (Secretary)
• Ethel
• Vasan
• George

Programmes and Initiatives

The company regularly holds training on ethics. Several training sessions have been launched to educate employees on various ethical rules and obligations, including bribery, competition and fraud.

Whistleblower Policy

The Nuts & More Whistleblower Policy, launched in 2021, is designed to make it easier for employees and partners to share questions, concerns, suggestions or complaints about financial, accounting, banking or anti-bribery matters. The whistle blowing system enables all Nuts & More employees and partners to report anything that they suspect to be unethical, illegal or unsafe, through a dedicated email address or by phone.

Anti-bribery Policy

The Nuts & More Anti-Bribery Policy, launched in 2021, provides practical examples showing employees how to do the right thing when faced with a dilemma. Our commitment to prevent corruption is formalized in our Anti-Bribery policy, which seeks to not only comply with recent anti-corruption and anti-bribery regulations, but to avoid any appearance of questionable conduct in connection with Nuts & More operations.

Data Protection Policy

A formal Data Protection Policy issued by the Nuts & More Ethics Compliance Committee governs legal compliance aspects. This policy ensures that Nuts & More, its staff, contractors, suppliers and other people working on its behalf comply with any applicable provisions of the European General Data Protection Regulation (GDPR) where and when appropriate, as well as with any applicable other legislation when processing personal data.