Business Partners Code of Conduct

In GBfoods we firmly believe that we must conduct our business and interact with third parties in compliance with the highest standards of Business Integrity & Ethics, Human Rights, Environment and Sustainability.

Our Business Partner Code of Conduct (hereinafter referred to as the “Code”) contains all the essential principles and values that must rule and inspire the business relationship with GBfoods. We are committed to work with those that agree to follow these principles in their own company, group and throughout their whole value chain.

This Code has been developed in line with the best practices, relevant legislation and internationally recognized conventions and guidelines, such as the UN Sustainable Development Goals, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the International Bill of Human Rights, the Declaration on Fundamental Principles and Rights at Work of the International Labour Organisation (ILO), the United Nations Convention against Corruption, among other international standards, as well as with our internal Codes of Ethics.

This Code applies to all suppliers of goods and services, their subcontracted suppliers (hereinafter referred to as “Suppliers”) as well as to any company in their corporate Group (including subsidiaries and the parent company), and extends across the entire supply chain. Likewise, this Code applies to all the companies that distribute or sell our products (hereinafter all of them referred to as “Business Partners”).

Compliance with this Code is a contractual requirement, and Business Partners are expected to commit to and act in accordance with its principles.

The following Rules and Principles set out the minimum requirements for maintaining a commercial relationship with us. However, in addition to them, Business Partners must observe the laws, regulations and specific mandatory standards applicable in the countries in which they carry out their activities, supply goods or services, or do business in. This is a mandatory requirement of our Code. Should there be any discrepancies between the applicable regulations, those that best safeguard the relevant rights shall always prevail.

GBfoods is committed to ethical and lawful business practices across our entire value chain, partnering with Business Partners Business Partners who share our commitment in the following areas:

•  Compliance with laws: All laws and regulations are complied with and required permits are held, for the countries where the Business Partner operates, as well as for all other applicable international laws and regulations.

• Anti-bribery & Corruption: All forms of corruption, including bribery, embezzlement and extortion are not tolerated. Bribery of public officials or private organization officials and intermediaries, as well as facilitation payments and other forms of corruption (for example fraud or theft) are all covered by this prohibition.

• Gifts & hospitalities: Business Partners must not offer or promote, in any way, any personal or inappropriate benefits prohibited by law, either directly or through intermediaries and should refrain from offer any kind of gifts or hospitality to GBfoods employees that could improperly influence or affect the business relationship.

•  Conflicts of Interest: Any Conflict of Interest of which the Business Partner is aware, shall be declared to GBfoods through our communication channels (see section Commitment on reporting breaches) to allow us the opportunity to take appropriate action.

• Free competition: Business Partners must compete fairly and in full compliance with the applicable competition and antitrust laws. This includes avoiding price-fixing, market allocation, abuse of dominance, or any other anticompetitive behavior. The Business Partner is also expected to maintain fair business and advertising practices.

•  Money laundering: The Business Partner shall refrain from any fraudulent activity or money laundering.

• Tax compliance: The Business Partner shall exercise responsible taxation by complying with applicable tax obligations.

• Export/import controls and sanctions: Business Partners shall comply with applicable export/import control rules, regulations and restrictions. In addition, they shall avoid doing anything that would position themselves or GBfoods in violation of applicable economic sanctions or export/import rules during the export/import transactions in any country.

• Intellectual and industrial property: GBfoods’s know-how and intellectual property should be respected and safeguarded. The transfer of technology and know-how of GBfoods or third parties will be carried out in such a way that intellectual and industrial property rights are protected.

• Privacy, confidentiality, IT security and data protection: In the event that GBfoods shares confidential information or any personal data with the Business Partner during the relationship, the Business Partner will be responsible for upholding its confidentiality obligations as well as the integrity of information in line with applicable laws and with respect for the protection of privacy as a human right. Business Partners shall neither misuse confidential information for their own benefit because of the relationship with GBfoods. The confidentiality obligation shall survive the termination of its relationship with GBfoods.
In addition, the Business Partner must have effective information security and cybersecurity measures in place to manage risks, respond to cyber threats and to properly manage and protect information and assets.

• Responsible use of Artificial Intelligence (AI): If the Business Partner uses Artificial Intelligence (AI) systems during the course of its relationship with GBfoods, it shall disclose this to GBfoods, ensuring their responsible and ethical use. AI must be used in a transparent, secure and non-discriminatory manner, in line with applicable laws and fundamental rights, especially in relation to personal data, decision-making and privacy.

• Quality & Food Safety: Our Business Partners are expected to adhere to the highest standards of quality and food safety, as well as to internal policies related to these areas, as communicated or made available by GBfoods. They must ensure that all products supplied to us comply with all applicable food safety and quality laws and standards — whether supplying goods or services directly or through a subcontractor. Business Partners must immediately inform GBfoods of any information or suspicions relating to food safety.

When applicable, a food safety and quality management system shall be also implemented and a certification of the management system under a recognised certification will be desirable. Above all cases, Business Partners must ensure that all products are safe for consumption, free from contaminants, and consistently meet our specifications. Regular audits and inspections should be conducted to verify compliance, and any issues must be promptly addressed.

• Animal welfare: Business Partners shall promote compliance with best practices in animal welfare, including aspects such as proper feeding, appropriate housing, good health, and behavior suited to the characteristics of each species. These practices should align with the principles of the Five Freedoms as defined by the WOAH (World Organization for Animal Health).

• Traceability and transparency: Business Partners are encouraged to foster transparency and traceability throughout their whole supply chain. This includes knowing the geographical origin of raw materials, the source of services, and the roles of suppliers and subcontractors, including the logistics operations.

GBfoods is committed to respecting and promoting Human Rights throughout its operations and supply chain. Business Partners shall take appropriate measures to ensure respect for Human Rights and fair treatment within their organisation, fostering safe and inclusive working environments.

The Business Partner shall treat its employees with dignity, respect and integrity throughout the employment relationship (including hiring, any aspects of training, personal and professional development, compensation, employment termination and retirement). The Business Partner may not use discriminatory practices or make discriminatory decisions based on ethnic origin, religion or belief, gender, age, physical fitness, nationality, disability, sexual orientation, political or trade union affiliation, medical evidence, marital status, social origin, or on the basis of pregnancy or other personal characteristics. Business Partners shall prevent and take active measures against discrimination within their organization.

The Business Partner shall treat its employees with dignity and respect and commits to providing a workplace free of harassment and abuse. Physical, sexual, verbal or psychological abuse, any form of harassment, hate speech, intimidation, violence and corporal punishment are not engaged in or tolerated.

All forms of forced or compulsory labor are strictly prohibited. Business Partners shall ensure that employment is freely chosen, and that workers are not subject to any form of coercion, threat, intimidation or any type of modern slavery. Employees must have the freedom to leave employment at any time, with reasonable notice, without fear of penalty or retaliation. Disciplinary measures taken shall comply with applicable national law and Human Rights.

GBfoods expects Business Partners to provide its employees with fair and legally mandated benefits and wages, including minimum wages and overtime. When local minimum wage rules are absent, Business Partners should provide wages that meet employees’ essential and basic needs as well as dignity.

GBfoods also expects Business Partners to provide paid regular and overtime working hours, annual leave and holidays as required by law or the local industry standard avoiding unsafe, unhealthy, or excessive working conditions for workers.

All forms of child labor are prohibited, and the Business Partner and their subcontractors shall comply with national laws and international standards regarding the protection of minors. Under no circumstances should individuals be employed under the age of 15 or under the local legal minimum age for work or mandatory schooling, whichever is higher. Business Partners must keep all necessary records, including those about recruitment, proof of age documents, parental permission, wages, hours worked, overtime and working conditions. No young worker below the age of 18 shall be employed in hazardous work, for work that can harm their health, or night work

Business Partners should respect the right of employees to freedom of association and collective bargaining and to form or join trade unions and workers’ associations, in accordance with applicable laws. Workers shall also have the right to strike, as provided by applicable law.

Business Partners shall provide their employees with a healthy and safe working environment. In addition, their premises shall comply with applicable health and safety laws and regulations of the countries in which they operate. Furthermore, it shall ensure adequate cleanliness at workplaces and, if provided to workers, of accommodation areas.

The Business Partner must promote the adoption of preventive measures that minimize the health and safety risks associated with the performance of their activities, providing workers with adequate individual and collective protection measures and equipment to prevent occupational diseases and accidents at work. Additionally, the Business Partner must train their employees on physical and mental health, safety, and workplace well-being, as well as provide information relating to exposure to chemical, biological and physical hazards, ensuring their safety and that of the people in their surroundings who might be affected during the activity.

The Business Partner shall be prepared for emergency situations. This includes evacuation and worker notification procedures, emergency drills and training, adequate first aid supplies, appropriate fire detection and extinguishing equipment and adequate emergency exits.

Business partners must respect the rights of individuals and communities to land, natural resources, and access to livelihoods. Any form of land grabbing or unlawful forced eviction, whether directly or through third parties, in the context of land acquisition, leasing, or development, should not be tolerated.

GBfoods is committed to reducing our environmental impact across our operations and supply chains, aiming to minimize negative effects and create positive environmental outcomes. Our procurement practices commit toward greater sustainability and transparency and, therefore, we work closely with our Business Partners to responsibly and sustainably source ingredients, packaging materials, and other goods and services.

GBfoods expects its Business Partners to actively contribute to climate change mitigation efforts and comply with legal requirements related to environmental protection and necessary permits. This includes, when applicable, measuring and reducing greenhouse gas (GHG) emissions in line with the goals of the Paris Agreement. Thus GBfoods encourages Business Partners to set science-based GHG emission reduction targets and have them validated by the Science Based Targets initiative (SBTi).

Business Partners are expected to contribute to the transition towards a low-carbon economy by using energy efficiently, minimizing the fossil energy sources where possible, ensuring deforestation free commodities in their supply chain, and progressively promoting more sustainable agriculture and farming practices (such as regenerative agriculture and farming that reduces GHG emissions and fosters carbon sequestration in soils).

Business Partners shall optimise the consumption of natural resources, including energy and water, and comply with legal requirements regarding the generation and management of waste, emissions and water while making every effort to prevent and minimize waste generation, with special attention to food waste prevention, across their operations and adopt practices that promote the circular economy. Systems and measures must be put in place to prevent and minimize noise, odors, and other emissions into the air, prevent effluents to soil and water, deforestation or forest degradation, as well as ensure the safe use, handling, transportation and storage of raw materials, chemicals, products, waste and wastewater. It is also expected that Business Partners prevent impacts on biodiversity in their operations.

It is recommended to follow an environmental management system, such as ISO 14001 or EMAS certification, to support continuous improvement and ensure compliance with environmental regulations and standards.

When applicable and upon GBfoods request, certain Business Partners should carry out corresponding environmental assessments or commitments (such as EcoVadis, SBTi, Sedex or any other related to Sustainability).

Business Partners are responsible for communicating the contents of this Code and ensuring its implementation among throughout the supply chain, applying them to their Business Partners through the relevant contractual provisions. They must take proactive steps to educate relevant personnel, promote ethical practices, and ensure that all third parties acting on their behalf also comply with the standards outlined in this Code.

GBfoods reserves the right to monitor and verify compliance of its Business Partners with the Rules and Principles set out in this Code through internal or external assessment mechanisms. To this end, Business Partners will provide the necessary information/documentation and, with sufficient notice, allow GBfoods to audit and inspect their premises, practices and records. GBfoods will respect the legal provisions on trade and business secrets and data protection of the Business Partners and may subcontract a third party subject to a corresponding confidentiality obligation.

Business Partners shall report any suspected non-compliance with the rules of this Code or applicable law through the following channels:

– E-mail: raiseyourhand@thegbfoods.com
– Postal address: GBfoods, Plaza Europa 42, 08902 Hospitalet de Llobregat, Barcelona. For the attention of the Legal & Compliance Department

In turn, Business Partners undertake to make available to their employees and/or third-parties appropriate means to confidentially (or even anonymously) report any potential irregularities or illegal activities in the workplace, without risk of retaliation. The Business Partner shall manage the reports received in compliance with applicable laws and regulations, ensuring the confidentiality of the identity of the whistleblower and the content of the reports, investigating the reports received and adopting appropriate measures, if necessary.