Corporate Responsibility at Orkla

Approved by the Board of Directors of Orkla ASA on 15th December 2011.

1.0 Introduction
Orkla defines corporate responsibility as achieving commercial profitability in a way that is consistent with fundamental ethical values and with respect for individuals, the environment and society. Through profitable, responsible operations our companies create positive economic, environmental and social ripple effects. Orkla companies shall respect human and labour rights, establish good environmental, health and safety (EHS) standards, facilitate good dialogue with stakeholders and generally operate in accordance with applicable regulatory frameworks and good business practice.

In line with Orkla’s decentralised corporate structure, each company has an independent responsibility for exercising corporate responsibility in accordance with Orkla’s principles, but is free to design its own activities and instruments to this end. Orkla endorses the United Nations Global Compact’s ten principles, the Universal Declaration of Human Rights and the OECD Guidelines for Multinational Enterprises, and Orkla’s principles are established with these principles as a basis.

The document is applicable for all fully owned companies and joint ventures where agreed to as part of the ownership contract.

2.0 Main principles for corporate responsibility
Orkla has identified nine main corporate responsibility topics. The general principles underlying the Group’s approach to these topics are described below. There shall be emphasis on continuous improvement, and priority shall be given to areas where the need for improvement and the potential for making an impact are greatest. Priorities shall be based on an assessment of the needs of both the business and its stakeholders, and as an integral part of day-to-day operations.

2.1 A strong corporate culture
Orkla companies shall strive to promote an open corporate culture that fosters interaction and is based on Orkla’s Goals and Values. In promoting Orkla’s principles for good business operations, we shall respect local values and norms, and achieve success by bridging the divide between different cultures and interests. Orkla companies shall always comply with local regulatory requirements in the countries in which we operate.

Responsible operations require vigilance and the exercise of good judgement on the part of management and employees. The Group’s standards and expectations as regards employee attitudes and conduct are described in Orkla’s Code of Conduct.

2.2 Respect for human and labour rights
Orkla companies shall promote corporate conduct that reflects respect and consideration for others. We are committed to respecting fundamental human and labour rights, both in our own internal operations and in our relations with business partners, customers and others who are directly affected by the company’s activities. Companies shall work systematically with important issues as non-discrimination, the right to privacy, the right to negotiate, employment contracts, protection against harassment and management-employee collaboration. Orkla’s standards and expectations as regards company conduct in this area are described in further detail in Orkla’s Policy for Human Rights.

2.3 Environment, health and safety (EHS)
Orkla companies shall strive to achieve a vision of zero harm to people, the environment and society, and work purposefully and systematically to prevent negative effects in all areas of their operations. The companies’ products and services shall always be subject to strict requirements in terms of quality, product safety and impacts on personal health and the environment. Orkla’s standards and expectations as regards company conduct in this area are described in further detail in Orkla’s EHS Policy.

2.4 Anti-corruption
Orkla does not tolerate corruption, and expects that local management promotes a strong anti-corruption culture in their own company. The companies shall make active efforts to prevent undesirable conduct, and ensure that their employees are capable of dealing with difficult situations. Orkla’s standards and expectations as regards company and employee conduct in this area are described in further detail in the document Anti-Corruption at Orkla.

2.5 Responsible marketing practices
The sale and marketing of Orkla products and services shall be carried out with respect for local regulatory requirements, and in accordance with the principle of free and fair competition. Companies shall observe good business practice, and respect the established rights of competitors. When selling in new markets, an assessment of political and legal risk should be carried out, and necessary steps shall be taken to ensure sound and responsible practices. Orkla does not tolerate any agreement on price fixing, market sharing or other activities that limit free competition. Orkla’s standards and expectations as regards company conduct in this area are described in further detail in the document Competition Law at Orkla.

Orkla attaches great importance to product safety, good customer service and responsible marketing, and is committed to exercising due diligence with regard to consumer interests. Since issues and legislation relating to these issues vary across product categories, each business area shall draw up its own guidelines for its work in this area.

2.6 Responsible sourcing
Orkla companies shall actively promote good work and environmental standards in their supply chains. This means setting ethical standards for their suppliers, assessing the risk of potential supplier violations of these standards, and engaging in dialogue with risk suppliers concerning necessary improvements. Efforts to influence suppliers should be based on an ambition of continuous improvement, and should focus on the suppliers and product categories where the risk is deemed to be greatest. Orkla’s standards and expectations as regards company conduct in this area are described in further detail in Orkla’s Responsible Sourcing Policy.

2.7 Responsible investments
The risk of encountering breaches of Orkla’s corporate responsibility requirements shall be assessed as part of the due diligence process carried out in connection with the acquisition of companies. A risk assessment shall also be made in connection with the investment in shares, among others based on the publicly available assessments made by the Norwegian Government Pension Fund Global. An introduction to corporate responsibility and ethics shall be included in the integration programme for companies that are incorporated into the Group.

2.8 Community engagement
In order to achieve long-term, profitable operations, we are dependent on retaining public trust. We seek to be responsive to society’s needs, and engage in active dialogue with important stakeholder groups. All the companies in the Group shall identify relevant issues in the relationship between business and society, and facilitate good, effective ways of dealing with complaints and other inquiries from external stakeholders. In areas that present special challenges, the company shall consider the need to initiate improvement projects. Many Orkla companies are important for their local communities, and should consider how they can support their community.

Orkla is dependent on good collaboration with public authorities irrespective of party affiliation, and will not provide financial support for political parties nor participate in parties’ election campaigns. This principle shall not in any way prevent our employees from engaging in political activities.

2.9 Whistle blowing
The Group has established a world-wide whistleblower service through which employees can report concerns related to possible breaches of law or of Orkla rules. Companies shall ensure that the employees of the various businesses are well informed about this system. The whistle blower service is further described in Orkla’s Code of Conduct

3.0 Requirements relating to implementation and ongoing monitoring
Orkla companies shall provide for a sound, effective implementation of the principles described above. Activities shall be adapted to the size of the company and an assessment of the issues that are most relevant, but shall always include:

  • Internal training on Orkla’s corporate responsibility standards.
  • Annual assessment of risks related to the company’s corporate responsibility.
  • Procedures for receiving and processing complaints and other inquiries from customers and other external stakeholders.
  • Procedures for internal handling of concern from employees
  • Procedures for distribution and communication of the Orkla Employee Code of Conduct to all employees.
  • More detailed requirements are set out in the attached policy documents. Orkla will monitor the companies’ efforts through the business area boards, internal reporting and internal audits.

4.0 Roles and responsibilities
The CEO of Orkla companies is responsible for ensuring the proper implementation of these guidelines. Each company shall appoint one or more contact person(s) to report on issues relating to corporate responsibility and EHS. Orkla will support the companies’ implementation efforts by providing guidance and appropriate tools.

Orkla strives to foster open dialogue on difficult dilemmas. As a general rule, this should take place in the form of discussion and assessments within individual companies, but guidance can also be obtained from Orkla’s CR function and other relevant functions.

Orkla and its companies are jointly responsible for promoting the Group’s corporate responsibility principles in respect of companies in which the Group has an ownership interest, as well as other business contacts.

Orkla’s Guidelines for Corporate Responsibility do not give customers, suppliers, competitors, shareholders or other persons or entities any legal rights beyond those that follow from applicable legal regulatory frameworks.

Approved by the Board of Directors of Orkla ASA on 15th December 2011.