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Supplier Code of Conduct

Supplier Code of Conduct

PREAMBLE

As part of the Nordzucker Sustainability Strategy, we are committed to working in partnership with our suppliers
to follow specific standards in respect of business integrity, people and society, as expressed in this Supplier Code of Conduct ("Code").

The Code is based on the Nordzucker Code of Conduct.*

Scope of the Supplier Code of Conduct

The purpose of this Supplier Code of Conduct is to ensure that suppliers to Nordzucker operate in accordance with internationally recognised minimum standards for conducting business. Nordzucker adheres to the principles of this Code and expects the same of its suppliers.

Commitment to the terms of this Supplier Code of Conduct is a condition of any agreement or contract between Nordzucker and a supplier.

The terms of this Code extend to all employees, regardless of their status or relationship with a supplier.

It is the responsibility of each supplier to ensure that its sub-suppliers do not violate the standards of this Code.

Business Integrity

LEGAL COMPLIANCE

Nordzucker expects suppliers to conduct their business in accordance with all applicable laws and regulations. Where a local law or other applicable standards (e.g. collective bargaining agreements) set higher standards than those set out in this Code, these takes precedence and must be adhered to. If conflicts are detected between the provisions of this Code and national laws or other applicable standards, suppliers are expected to inform Nordzucker immediately.

BRIBERY AND CORRUPTION

Suppliers must compete fairly for our business, without offering, giving or receiving bribes or improper payments, or participating in any kind of corrupt activity, either directly or through a third party.

GIFTS AND HOSPITALITY

Suppliers must make sure that jobrelated gifts, meals or entertainment are reasonable and do not influence a business decision improperly or impair independence or judgement of the recipient. Specifically suppliers must not offer any Nordzucker employee gifts or entertainment or make donations on the behalf of or for the benefit of any Nordzucker employee, unless Nordzucker expressly permits this. Any meals given by a supplier to a Nordzucker employee must be of reasonable value and provided only in the course of the supplier's business with Nordzucker.

CONFLICT OF INTEREST

Suppliers must disclose any situation that may appear to be a conflict of interest. Each supplier should also disclose if any Nordzucker employee or family member might have an interest in or any kind of economic tie with the supplier.

COMPETITION

Suppliers must commit to competition based on price, quality and service and only seek competitive advantage through lawful means.

COMMUNICATION AND REPORTING

Suppliers must communicate information relevant for Nordzucker in a timely and accurate way. Suppliers' financial and other reports and records must be complete and accurate and in accordance with legal requirements.

CONFIDENTIAL INFORMATION

Suppliers must take appropriate steps to safeguard and maintain confidential and proprietary information and only use such information for purposes authorised by Nordzucker.

People

DIVERSITY, FAIR TREATMENT AND LABOUR STANDARDS

We expect suppliers to treat everyone equally and embrace difference.
We expect suppliers to respect labour standards and the freedom of organisation.

Discrimination and fair treatment: Suppliers must not engage in or support discrimination in respect of race, colour, sex, language, religion, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, health status, family responsibilities, age, and disability or other distinguishing characteristics. Hiring, remuneration, benefits, training, advancement, discipline, termination, retirement or any other employment-related decisions shall be based on objective criteria.

Freedom of association and collective bargaining: Suppliers must respect the right of employees to freedom of association and organisation and collective bargaining in accordance with applicable laws. Workers' representatives must not be subject to discrimination and must be given access to employees at the workplace. If trade unions are not allowed in the area of operation, or only state authorised organisations are allowed, then suppliers shall facilitate, and not prevent, alternative measures that allow employees to gather independently to discuss work-related matters and a forum to present work-related concerns to management.

Wages: Suppliers must comply with legal minimum standards or industry benchmark standards concerning wages and benefits, whichever is higher. Overtime shall be remunerated at a premium rate. Wages shall be paid in
legal tender and on a regular basis. Deductions from wages shall be transparent and must never be used as a disciplinary measure. All workers shall be provided with a written, understandable and legally binding labour
contract.

Work hours and overtime: Suppliers must ensure that their employees work in accordance with all applicable laws and mandatory industry standards pertaining to the number of hours and days worked. In the event of conflict between a statute and a mandatory industry standard, suppliers must give precedence to compliance with national law.

HUMAN RIGHTS

We expect suppliers to respect and protect human rights, not to tolerate forced labour and be against child labour.

Forced labour: Suppliers must treat their employees with fairness, respect and dignity and promote a work environment free of any form of forced labour, corporal punishment or other forms of physical coercion, including bonded labour, forced prison labour, slavery, servitude and human trafficking.

Child labour: Suppliers must not engage in or benefit from the use of child labour. Child labour refers to work that is mentally, physically, socially or morally harmful to children or interferes with their schooling needs.

PRIVACY

We expect suppliers to respect and protect everyone's privacy and comply with data protection and privacy laws.

HARASSMENT AND DISCRIMINATION

We expect suppliers not to tolerate any kind of harassment or discrimination against any employee or work partner.

Suppliers must protect workers from any acts of harassment, abuse or threats in the workplace, whether direct or indirect, physical or psychological, verbal
or non-verbal, and whether committed by managers or fellow workers. This also applies when determining and implementing disciplinary measures.

HEALTH & SAFETY

We expect suppliers to prioritise the health and safety of every employee and work partner.

Suppliers must provide employees with a safe and healthy working environment and, where relevant, safe housing conditions. This should include but not be limited to protection from fire, accidents and toxic substances. Adequate health and safety policies and procedures must be established and followed.

Suppliers must provide employees with personal protective equipment and the necessary training to perform their tasks safely.

Suppliers must provide a suitable, clean and sanitary infrastructure, including access to toilets and potable water in accordance with the needs and number of employees. Accommodation, if provided, shall meet the same requirements.

Role in the Society

ENVIRONMENT

We expect suppliers to protect the environment and recognise their responsibility to improve their environmental performance continuously.

Suppliers must strive to minimise the adverse environmental impacts of their activities, products and services - including packaging - through a proactive approach and responsible management of environmental aspects, particularly in relation to water use, energy use, carbon dioxide and other emissions, waste disposal and biodiversity.

Energy and environmental performance is part of our procurement selection procedure.

QUALITY, FOOD AND FEED SAFETY

We expect suppliers to follow high quality and product safety standards.

Suppliers must provide Nordzucker with high-quality products, ingredients and services that meet our specifications and comply with all applicable legislation.

Suppliers of raw materials, process aids, ingredients, direct contact packaging materials or products for direct consumption must demonstrate that they have robust food safety and quality management systems based on HACCP principles and have implemented a well functioning traceability and recall system.

We expect suppliers to report any concerns about product safety to Nordzucker immediately.

COMMUNITY

We expect suppliers to respect the community around them, demonstrate social responsibility and engage actively in local community issues.

Implementation of the Supplier Code of Conduct

We expect suppliers to develop, implement and document appropriate internal business practices to ensure awareness of and compliance with this Code.

Suppliers are responsible for ensuring that their respective
sub-suppliers comply with the terms and standards of this Code. This includes sub-suppliers classified as home-based workers
or small farmers.

Suppliers are responsible for educating their employees, agents and subcontractors accordingly.

MONITORING

Nordzucker reserves the right to verify the compliance of individual suppliers with the Supplier Code of Conduct through audits carried out by Nordzucker and/or a third party. Suppliers must agree to such audits, make employees and contract workers available for the audits and not discriminate or retaliate against workers for their comments to the auditors.

If a supplier fails to comply with any aspect of this Code, the supplier is expected to implement corrective actions.

In the event of material breaches of the terms of this Code, Nordzucker reserves the right to terminate any supplier agreement.

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