Code of Conduct

Introduction
At Nutreco, our strong values guide what we doand how we do it. We always aim to treat otherswith care, integrity and openness, and expect
colleagues throughout the company to live theseprinciples in our day-to-day work. Every one of us
is required to make thousands of decisions eachday as we go about our business – big and small,straightforward and sometimes more complex.
It’s these complex decisions that this Code of
Conduct will help us to manage in a thoughtful
way by making the company policy clear andproviding practical guidance.
I’m committed to ensuring that we all have thetools we need to help us act not only in line withthe law but honestly and ethically. The Code will
help us hold ourselves and each other accountablefor both our results and how we achieve them. It isaligned with SHV’s Ethics & Compliance ambitions
and outlines what our company stands for, how
we do business and how we should behave
towards each other. It also points us towards moredetailed policies, procedures and tools we mayneed to consult on certain topics mentioned in the
Code and tells us where to find them.

Part of acting ethically is also having the courage
to speak up when we see behaviour that we know
or suspect is wrong. You can consult the samecolleagues who will help you handle dilemmas, or
use our whistleblower line “Speak Up” to reportany violations of our Code. Be assured that we
do not tolerate any retaliation against those whoreport violations in good faith.
This Code is intended to help each of us act in acompliant and ethical way, and for that reason,
it is an important part of your employment
relationship with Nutreco. Please read it carefully
and ask questions if anything is unclear, as it isimportant you fully understand the Code. I expect
you to follow its principles and rules in everything
you do.
Fulco van Lede
CEO Nutreco

Even with clear guidance, we will always
encounter dilemmas, when it is difficult to tellright from wrong. If you encounter a dilemma,
remember you are not alone – always make sure
to discuss and resolve it with the help of others.
Bring your dilemmas to management at theappropriate level, to Human Resources, to Ethics &Compliance (E&C) or to Legal, and your colleagues
will help you determine the best way forward.
2 | Nutreco Code of Conduct

What is the Code of Conduct?

Who is the Code of Conduct for?

Our Code defines what we believe is the right way to do business. When you
act consistently with this Code, you know you are behaving in accordance with
our values and company policies and in compliance with the law.

Our Code applies to all employees of Nutreco worldwide, regardless of
their job or seniority level. It also applies to all employees working in
joint ventures over which Nutreco has management control.

LE

C

ING
AR

CAPA
B

How does the Code fit with our purpose, values and policy framework?

INNOVATIVECOL
E
LAB ATIVOR

INTEGRITY

Our purpose
What we see as our goal

3 | Nutreco Code of Conduct

LOYALTY

Our values
How we behave toachieve our goal

Our Code of Conduct
Our standards for businessand personal conduct

Our policies
Detailed instructions and processes
that help us adhere to our Code

What is expected of me?
This Code sets high standards of integrity
and conduct for everyone who works at
Nutreco. All employees must comply withthis Code and the policies and procedures
connected with it.
As an employee you must be
knowledgeable and aware• Understand and practise therequirements of the Code.
• Learn the details of the policies relevant
to your job.
• Acknowledge that even when somethingmight be a common practice in yourlocation or within your cultural norms, therequirements of our Code must prevail.
• Speak-up if you notice or suspect any
breaches of this Code.

Someone else’s direction or approval is
no excuse for wrongdoing• If you are asked or receive management
approval to do something that violates
our Code or policies, this is wrong andyou must report it immediately.

4 | Nutreco Code of Conduct

As a leader you should drive a culture of
ethical behaviour• Demonstrate your commitment tointegrity, not just through your words, but,
more importantly, through your actions.
• Make sure your team members
understand that business results arenever more important than compliancewith the law and our policies.
• Create an open environment where
every employee feels comfortable raisingconcerns.
• Handle employee concerns appropriately
and promptly.
• Engage with your teams on theimportance of compliance, with sincerity
and conviction, whenever you have an
opportunity.
• Look out for business processes in which
compliance risks may not be adequately
mitigated and report these to E&C.
• Act promptly when complianceweaknesses are detected.

Compliance withlaws and regulations
We comply with the laws, rules and regulations of thecountries where we operate. If a conflict exists between a
law and this Code, the law prevails over this Code.
If this Code sets higher standards than local law, cultural
norms or business practices, this Code prevails.
5 | Nutreco Code of Conduct

Contents
Business
conduct

Personal
conduct

Workplaceenvironment• Fair competition• Trade sanctions• Financial records• Corporate Sustainability• Gifts, hospitality andentertainment− Gifts and hospitality for
public officials− Gifts for or from business
partners− Hospitality for or frombusiness partners− Exception in extreme
situations− Third parties− Sponsorships andcharitable donations• Politics and governments− Political support− Lobbying• Conflicts of interest• Product Safety• Diversity and inclusion• Non-discrimination / equal
opportunities• Anti-harassment• Freedom of association• Compulsory and childlabour• Minimum wage
• Alcohol, drugs, weapons
and tobacco• Health and safety• Travel Security

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Protectionof assets andinformation• Company property andconfidential information− Protect our property
and systems− Protect our confidential
information including
intellectual property− Social Media− Personal use ofcompany property• Personal dataYour
commitment• If in doubt: ask• Raise your concerns andSpeak Up!

Business conduct

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Fair competition
Our business success is based on
the quality of our products, services
and people. We support free and faircompetition and abide by the lawsthat protect it. We will only enter
into agreements, understandings orengagements that are permitted underapplicable competition laws.

Dealing with competitors• As a rule avoid contact with competitors asmuch as possible.
• If contact is unavoidable, never exchange any
commercially sensitive information such as:− Pricing or pricing policy− Market share− Production, sales capacity or volume− Costs, profits or margins− Customers, suppliers and sales territories− Terms and conditions of sale
− Sales, marketing or development
strategies− Promotion, loyalty or rebate programs− Strategic processes or plans such as M&A
activity, plant extensions or closures• If a competitor attempts to communicate on
any of these topics, stop the conversation
immediately, actively remove yourself fromthe situation (by leaving the meeting) andreport the incident to E&C or Legal.

8 | Nutreco Code of Conduct | Business conduct• There may be legitimate reasons tocommunicate or meet with competitors,
for instance to discuss potential formsof cooperation or M&A transactions. On
these occasions commercially sensitive
information may need to be exchanged.
Before communicating or meetingwith a competitor for this purpose, youneed written approval from next level
management. E&C will advise in writing
before a decision is taken.
Dealing with suppliers and customers• Seek advice from E&C or Legal when you
wish to enter into exclusive or restrictive
agreements with suppliers or customers.
• Understand that resale price maintenanceis illegal in most countries and stick torecommended resale prices only.
• Nutreco’s suppliers or customers may also
be competitors or part of larger companies
that compete with Nutreco. In these cases,
you must only exchange informationthat is required for the existing business
relationship. You do not need prior approval
to interact with this type of supplier orcustomer as long as you understand what
is appropriate to discuss. If in doubt consult
E&C or Legal.

Trade associations• Take extra care at trade associations, industry
meetings and fairs. While attending these isa perfectly legitimate activity, they also offer
competitors a place to meet and improperlyalign businesses, particularly at pre- or postevent meetings.
• You need to obtain written approval fromnext level management to join and attend
meetings of a trade association. E&C will advise
management in writing on the conditions foryou to participate.
Care in communication• Take great care in communicating, by email,letter or memo.
• Avoid language that could convey the wrong
suggestion of anti-competitive conduct.
• If what you write could be misinterpreted, give
more context or choose different words.
• Remember that electronic communications suchas email may be retrievable for an indefinite
period of time, even if you think you havedeleted them permanently.
• Bear in mind that everything you communicate
may become evidence in case of a lawsuit.
Market intelligence• Obtaining information about the competition
can have a pro-competitive effect as it enables
us to better understand where we can improve
our offering.
• Use publicly available resources to obtainmarket intelligence, such as media reports, trade
journals, annual reports and market reports
made by third parties.

• You may also use information on competitors
provided by customers or suppliers in thecontext of meeting competitive offers, but
caution is required.
• You may never directly or indirectly (via a third
party) obtain sensitive information from acompetitor. If in doubt, consult E&C or Legal.
Q&A
I have a friend who is a sales person working at acompetitor. Sometimes we talk about marketing
plans. Is this a problem?
Yes it is. In a conversation like this it is easy for you
to reveal commercially sensitive information andviolate competition laws that forbid discussions onmarketing and pricing.
I want to meet with a company to determine ifthey can become a Nutreco supplier. This company
however is also a competitor. Am I allowed tomeet with them?
There may good reasons to meet with thiscompetitor. However authorities are generally
suspicious of such meetings. Take care, and makesure the meeting is allowed by competition law.
If in doubt consult E&C or Legal.
For further guidance please refer to:
Nutranet > Policy House > E&C > Fair competition

9 | Nutreco Code of Conduct | Business conduct

Trade sanctions

Financial records

As a global company, we may produce, sellor export our products in or to countries thatare subject to trade sanctions. We comply
with all applicable trade compliance laws andregulations.

We keep clear, complete and up-to-date records
that accurately reflect our business transactions
and company assets.

Our policy• Only OpCos that have been authorized by the
Nutreco Management Board may do businesswith parties located in sanctioned countries.
A list of sanctioned countries is available on
Nutranet.
• Authorized OpCos must meet certain
compliance requirements.
• All OpCos are forbidden from doing businesswith certain heavily sanctioned countries. A listof these countries is available on Nutranet.
• For further details, contact E&C or Legal.

Our policy• We comply with applicable laws, generally
accepted accounting principles and our internal
accounting procedures.
• We don’t keep “off the books” or secretaccounts.

For further guidance please refer to:
Nutranet > Policy House > E&C > Trade Sanctions& Export Controls Policy

10 | Nutreco Code of Conduct | Business conduct

Q&A
I am not working in a financial role. Is accounting
integrity still my responsibility?
> Yes, proper record-keeping is a responsibility
we all share. You may work with expense reports,
test data and sales invoices: all of these must be
accurate, complete and properly recorded.
For further guidance please refer to:
Nutranet > Policy House > Finance > Nutreco
Accounting ManualCorporate
Sustainability
We contribute to greater sustainable protein
output in the feed-to-food chain. Our businesses
look for opportunities to create shared value forthe benefit of our entire industry and society as
a whole.

Our sustainability program• Nuterra is our comprehensive sustainability
program.
• It is aligned with and contributes to eight of
the United Nations’ Sustainable Development
Goals.
• The Nuterra Sustainability Roadmap sets
clear targets, measures progress and assesses
the environmental impact of our nutritional
solutions.

Your role
Each of us has a role to play in making Nutreco
a more sustainable business. You can help by:• Ensuring that all of Nutreco’s direct
suppliers sign a procurement contract. This
contract refers to our Code of Conduct for
Business Partners which includes Nutreco’s
sustainability criteria.
• Driving transparency in sustainability byreporting progress and challenges to the
Nutreco Sustainability Platform.
• Actively promoting and engaging in the
Nutreco Global Community Day in your local
community.
• Actively working on reaching the
Sustainability Roadmap targets within yourworkplace and community.
• Encouraging customers, suppliers and otherexternal stakeholders to read Nutreco’s
Annual Sustainability Report to help us
create shared value on the sustainability
challenges we face.
• Advocating for responsible and sustainable
activity in your workplace and local
community.
For further guidance please refer to:
Nutranet > Policy House > Sustainability >Nuterra11 | Nutreco Code of Conduct | Business conduct

Personal conduct

12 | Nutreco Code of Conduct

Gifts, hospitality
and entertainment
Gifts and hospitality can help build business
relationships, but may become bribes if offeredor accepted in return for a favour or businessadvantage. We do not allow bribery or
facilitation payments to be offered or acceptedin any of our business dealings around theworld, with both governments and the private
sector.

Use common sense
Always ask yourself if offering or accepting a
gift or invitation could (be seen to) improperly
influence you or someone else in making businessdecisions.
What you should know
Bribery means giving, offering or promising
anything of value to influence a business decision.
A gift can be an object, cash payment, voucher,gift card, favourable loan or anything else of value.
Hospitality may involve lunches or dinners,
entertainment, sports events, travel or lodging.
Facilitation payments are small amounts
paid to public officials to expedite routine oradministrative actions such as issuing licenses orvisas.

13 | Nutreco Code of Conduct | Personal conduct

Gifts and hospitality for public officials• Do not offer any gifts, apart from Nutrecobranded promotional materials of limited value,
to public officials or their families.
• Hospitality must be of reasonable value andpermitted under local laws and regulations.
Gifts for or from business partners• Never offer, ask for or accept a gift to obtain an
improper business advantage.
• Ensure that you don’t violate the national laws
or the known policy of the recipient.
• Take extra care during sensitive periods suchas negotiations, a tender phase, or legal
proceedings.
• Gifts in the form of cash or cash equivalents(such as gift cards, vouchers and securities) are
not allowed.
• Gifts offered or accepted may not exceed €100in value. Per business partner, gifts may not be
offered or accepted more than four times peryear.
• If a gift that does not comply with these rules
cannot reasonably be refused, you may accept it
if it does not immediately trigger any return giftor action. However, you must inform next level
management promptly and you may not keep
the gift yourself.

Hospitality for or from business partners• Offering or accepting hospitality is allowed
if it is of reasonable value, fosters business
relationships, displays good taste, does not
violate the known policy of the recipient and isextended as a matter of courtesy.
• Business partners visiting Nutreco facilities
or events may be offered reasonable,
proportionate travel and lodging. Only offer thesame to spouses and family members if this isappropriate.
Deviations require approval• Any deviation from these rules requires priorwritten approval from next level management
following written advice from E&C.

Exception in extreme situations
If you need to make a payment to avoid animmediate and genuine threat to the health, safety
or illegal detention of yourself or a colleague,
you are allowed to do so. Report the payment
immediately to next level management and E&C.
Third parties• In addition to not paying or accepting bribes
ourselves, we also need to make sure thatthird parties do not pay or accept bribes on ourbehalf. For this reason we have adopted theThird Party Due Diligence Policy that helps us
assess the risks related to certain categories ofthird parties and take precautionary measures
to manage these risks.
• This policy applies to the following third parties:− Sales agents− Customs agents− Advisors representing Nutreco− Intermediaries− Joint venture partners− Participations (non group companies in which
Nutreco holds shares)− Third-party lobbyists• Relationship owners must ensure that properrisk mitigating actions as set forth in the Third
Party Due Diligence Policy are taken. E&C can
support executing these actions.

14 | Nutreco Code of Conduct | Personal conductSponsorships and charitable donations• Sponsorships involve supportingorganizations or events to promote the
Nutreco brands and businesses.
• Charitable donations (in cash or in kind) are
given to non-profit organizations with noexpectation of direct corporate benefit.
• Sponsorships and charitable donations must:− Meet the requirements set out in the
Nutreco Anti-Bribery and Corruption Policy− Be approved in writing by next level
management following advice from E&C
For further guidance please refer to:
Nutranet > Policy House > E&C > Anti-Bribery& Corruption Policy
Nutranet > Policy House > E&C > Third Party
Due Diligence Policy

Q&A
One of our vendors offers me tickets
to a concert that she can’t attend.
Can I accept them?
> No. Even if the tickets fall within the €100
limit, the event doesn’t offer an opportunity
to enhance your relationship with the vendor,
since she will not be attending with you.
A consultant I regularly work with asks me tojoin him at a sports event. Can I accept?
> Yes you may, provided the arrangement is ofmodest value and is not intended to influence abusiness decision.
A government employee asked if I can help his
daughter get an internship at Nutreco. He says
this would facilitate our relationship.
> Be careful. You can provide the government
employee with information about the internshipand allow his daughter to apply in the same
way that other candidates do. Don’t give her
any form of preferential treatment.
While stranded at the border, a customs officer
offers me a fast-track entry in return for somecash. Is this OK?
> No. This appears to be a facilitation payment.
The situation would be different if there was an
official fast-track service for which you would
get an official receipt.

15 | Nutreco Code of Conduct | Personal conduct

Politics & governments
Political support• We observe neutrality with regard to politicalparties and their candidates. As a company,
we do not make contributions to local, regionalor national political fundraising events.
• However, Nutreco recognizes your right as anindividual to participate in the political process
on your own time and at your own expense.
Lobbying• Lobbying activities seek to influence a politicaldecision-maker or legislator on a certain issue.
They must be done openly and truthfully andnever involve gifts, entertainment or donations.
• Lobbying activities by employees require priorwritten approval from next level management
following written advice from E&C.
• Lobbying activities involving a third party
require prior written approval from the Nutreco
management board following written advice
from E&C.
For further guidance please refer to:
Nutranet > Policy House > E&C > Anti-Bribery &Corruption Policy

16 | Nutreco Code of Conduct | Personal conduct

Conflicts of interest
The business decisions we make should never
be based on our own private interests. We
must always seek to avoid real or perceived
conflicts between our private interests and our
professional responsibilities. Conflicts of interest
must be reported immediately.
ExamplesConflicts of interest may arise when personal
interests affect (or appear to affect) our ability
to make impartial business decisions. Typicalexamples include:• Having a financial interest in one of Nutreco’s
business partners or competitors• Doing business on Nutreco’s behalf withsomeone you have a close personal relationshipwith• Taking for yourself a business opportunitythat is meant for Nutreco, or passing it on tosomeone else
• Recruiting or supervising family members orclose friends

17 | Nutreco Code of Conduct | Personal conduct

Your role• Avoid situations of (real or perceived) conflictsof interest as much as possible.
• Do not engage in decision-making that creates a(real or perceived) conflict of interest.
• Do not give preferential treatment to family
members or close friends.
• Disclose (potential) conflicts of interest in
writing to your next level management.
Management will provide you with a written
decision, following witten advice from E&C.
(Supervisory) board positions
Seek approval from your next level managementfor (supervisory) board positions or advisory roles
that could conflict with your responsibilities asa Nutreco employee. A written decision will betaken after written advice of E&C.
Romantic relationships
Romantic relationships can become an issue if theemployees concerned work in the same reporting
line. In these cases, both employees must disclose
their relationship to HR or next level management
so the possible implications can be assessed andany necessary arrangements made.

Remember
A conflict of interest is not necessarily a breachof this Code, but failing to promptly disclose aconflict is a violation.
Q&A
I am looking for a new supplier. A friend of mineowns a company that is well-positioned to supply
Nutreco. May I engage with her?
> No, you may not engage with her personally. You
may introduce your friend to a colleague, who cantreat her as any other possible supplier. You may
not be involved in the decision-making process.
I have been offered a role in the supervisory boardof another company. Am I allowed to accept thisrole?
> Before you accept, you should first disclose thisoffer to next level management. You may only
accept this role after your manager has approved,
following written advice from E&C.
For further guidance please refer to:
Nutranet > Policy House > E&C > Anti-Bribery andCorruption Policy

Product Safety
Nutreco’s sustainable development is basedon product safety, quality and integrity.
By complying with regulatory requirements
and our internal standards we protect people
and animals from hazardous substances.
Our safety and quality program• Nutrace is our company-wide proactive program
to ensure feed-to-food quality and safety.
• It safeguards the quality of Nutreco products
and services and complies with legislation. It
helps us meet customer demands.
• We inform our customers through clear
labelling and product-documentation so thatthey can safely apply our products.
• We handle any safety related complaints
seriously and ensure that they are properly
investigated. If required we report to theappropriate regulatory authorities.
• We share information on food and feed safety
matters both internally and externally.
Your role• Be alert for situations that could lead to our
products being compromised.
• If you see or suspect something that could
negatively affect the safety or quality of our
products, speak up and report it immediately.
For further guidance please refer to:
Nutranet > Policy House > Product Safety

18 | Nutreco Code of Conduct | Personal conduct

Workplaceenvironment

19 | Nutreco Code of Conduct

Workplaceenvironment
We are committed to providing a safe,
collaborative and inclusive workplaceenvironment where employees and business
partners are respected and appreciated.

Diversity and inclusion• We attract, develop and retain a workforce thatis as diverse as the markets we serve.
• We promote diversity and inclusion by:− Respecting the mix of each other’s talents,
abilities and experiences− Valuing each others’ input− Fostering an atmosphere of trust, openness
and sincerity
Non-discrimination / equal opportunities• We recruit, treat, promote and compensate
employees and job applicants based on merit,
qualifications and job-related performance.
• We do not discriminate with regards to gender,
race, religion, age, disability, sexual orientation,nationality, political opinion and social or ethnic
origin.

20 | Nutreco Code of Conduct | Workplace environment

Anti-harassment• We seek to provide a working environmentthat is free from harassment and disrespectful
conduct.
• Harassment includes unwelcome verbal,
visual or physical behaviour that creates anintimidating or offensive environment.
• Examples include:− Rude language or jokes− Intimidating or threatening behaviour− Degrading comments− Hostility towards others because of individual
characteristics− Unwelcome sexual advances or remarks• You can help by always treating others the way
you would like to be treated.
Freedom of association• We respect every employee’s right to join a
trade union or to have recognized employee
representation in accordance with the law.
• We recognize the right to engage in collective
bargaining.

Compulsory and child labour• We will not use child labour or any other formof compulsory labour.
• The minimum age for entering into employment
or working should not be less than the age forcompletion of compulsory schooling as provided
by national law and, in any case, should not be
under 15 years old.
• We comply with the International Labour
Standards.
Minimum wage
All employees are entitled to the legal minimum
wage, as published by the government in the
countries where we operate.

Alcohol, drugs, weapons and tobacco• We do not tolerate working under the influenceof drugs or alcohol.
• You are expected to perform your job freefrom any substance that could impair your job
performance.
• We do not permit firearms or any otherweapons on our locations without prior written
approval of OpCo management following
written advice of E&C.
• Smoking is prohibited in all our working areas,
offices and plants.
Q&A
My manager often loses his temper and yells at
people. Is that harassment?
> It depends, but, in any case, the situation createsa negative working environment and should be
addressed. Share your concerns with HR or E&C
or leave a message with Speak Up.
One of my colleagues emailed an inappropriate
joke to me and some teammates. I find it offensive.
What should I do?
> Offensive behaviour is not acceptable. If you
feel uncomfortable speaking with your colleague
directly, contact your manager, HR or E&C or leavea message with Speak Up.
For further guidance please refer to:
Nutranet > Policy House > HR > Global Human
Resources Policy

Health, Safety and Environment
We strongly believe that zero harm is possible.
We are committed to:- Safeguarding the health and safety of ouremployees, contractors and visitors.
- Caring for the environment by not wasting
finite resources.
Your role• Be trained and adhere to the Nutreco HSE
Policy, standards and procedures.
• Address gaps and engage with colleagues onsafety matters.
• Take a minute to evaluate the risks and ensurethat the work can be executed safely.
• Keep the work area safe, clean and tidy, toprevent slip, trip and fall accidents.
• Strictly respect the Life Saving Rules on site
• Adhere to traffic rules.
• Do not text or read emails on your phone whiledriving. Only call handsfree.
• Use the personal protective equipment as per
job requirements.
• Use the correct equipment and tools to performthe task safely.
• STOP a task if you feel that safety is notadequate, report and wait until a competentperson takes appropriate risk control measures.
• Act with respect and challenge any unsafe
conditions and unsafe acts you see or perceive.
• Report any incident, including near miss or
hazardous situations, and leverage it to learn
and avoid recurrence.
• Recognize and report positive behaviors.
For further guidance please refer to:
Nutranet> Policy House > HSE Policy

21 | Nutreco Code of Conduct | Workplace environment

Travel security
When travelling for work, Nutreco wants its
employees to be as safe as possible. The Travel
Policy provides clear instructions to limit risks.
• Travel only if essential and if other means ofcollaboration (such as online meetings) are notsufficient.
• All flights must be approved as provided in the
Global Travel Policy.
• All flights must be booked via Nutreco
Procurement approved travel agencies.
• Travellers must consult the country/regional
information and risk ratings provided by externalsources (International SOS, BCD TripSource andlocal health authorities).
• Travelling to countries or regions with a high (red)or extreme risk rating (dark red) as defined byInternational SOS must be approved as provided in
the Travel Policy.
• Travellers must comply with country entry
restrictions, local governmental rules and healthinstructions.
• Take medical precautions such as vaccinations.
• Download the International SOS App. In case of an
emergency use the contact details provided there.
For further guidance please refer to:
Nutranet > Policy House > HR > Travel Security
Policy22 | Nutreco Code of Conduct | Workplace environment

Protection of assets
and information

23 | Nutreco Code of ConductCompany property
and confidential
information
Our property consists of real estate andequipment, IT systems (such as laptops,
mobile phones), intellectual property(patents, trademarks and brands) andconfidential information (know-how,formulations, business plans and supplieror customer details), among other things.
We are all responsible for protecting company
property.

A. Protect our property and systems• Keep the IT equipment that is assigned to you insecured places.
• Immediately report any property that is lost,
stolen, damaged, unsafe or in need of repair.
• Only install software and applications thatcomply with the Nutreco IT User Instructions.
B. Protect our confidential information including
intellectual property• Confidential information is information that is
not available to the general public and might beof use to competitors or harmful to Nutreco, if
disclosed.
• Safeguard Nutreco’s confidential informationfrom unauthorized disclosure and misuse.
• Confidential information may only be accessed,
used or shared to the extent necessary to fulfill
your job duties.

24 | Nutreco Code of Conduct | Protection of data and information

C. Social media• In social media, refer to Nutreco in a
professional way. Do not share pictures orvideos of the inside of our premises.
• Obtain permission from colleagues before
posting any images of them.
• Do not speak on behalf of Nutreco unless you
have been authorized to do so.
D. Personal use of company property• Limited personal use of our company IT
resources is permitted if it does not have anegative impact on the day-to-day operations of
the business.
• Personal use must not involve illegal,
sexually explicit, discriminatory or otherwise
inappropriate material and/or activities such asgaming.
• Nutreco reserves the right to monitor the useof our IT systems and information without priornotice and to the extent permitted by law.
• Personally owned devices (BYOD) used toprocess and/or store Nutreco information mustcomply with the Nutreco IT User Instructions.
For further guidance please refer to:
Nutranet > Policy House> IT> IT Users Instructions
Nutranet > Policy House > Communications >Social Media Policy

Personal data
We respect the privacy of our employees,
customers, suppliers and business partners. We
only collect and use personal data that we needfor our business. We treat personal data withcare and process it safely. Nutreco has appointed
a Group Privacy Officer, who oversees our data
privacy programme.

Processing of personal data
• For data privacy the key concept is “processingof personal data”.
• Personal data is any information that relates
to a person who can be identified - such as aname, address, email, etc.
• The processing of personal data covers all of
the actions you take with this data, includingcollecting, storing and deleting data.
Your role
Always ask yourself if the data you are processing
is personal data. If so, keep the following in mind:• Only collect and process personal data that you
really need.
• Only share personal data with people who needit to perform their jobs.
• Keep the personal data that you process up-todate.
• Delete any personal data that you no longer
need.

25 | Nutreco Code of Conduct | Protection of data and information• Make sure that individuals whose personal data
we collect are well-informed about how thisdata is processed.
• Take appropriate (IT) security measures toprotect the personal data you process, from themoment you collect it until the moment you
delete it.

Q&A
I would like to send a newsletter to all mycustomers. Is this OK?
> Yes, as long as it is sent exclusively to existingcustomers. For prospective customers, you would
need to ask them first before sending them anewsletter or other information.

Be aware• Always report possible data breaches atprivacy@nutreco.com. A data breach occurs
when personal data (1) is permanently lost or(2) ends up in the hands of the wrong person
outside the company in a way that could lead tomisuse.
• Individuals have the right to access theirpersonal data and have it corrected or removed.
Any requests must be forwarded to privacy@
nutreco.com.
• When a third party processes personal data
on behalf of Nutreco, ensure that a proper dataprocessing agreement is in place.

To celebrate the successful completion of amajor project, a supplier would like to send a
personalized thank you gift to the home addressesof the project team members. Can I share thenames and home addresses of the project teammembers with the supplier?
> In a situation like this, please contact the Group
Privacy Officer at privacy@nutreco.com. Although
the gesture is well-meant and the project teammembers may like to receive the gift, just sharing
the details could be problematic. The Group
Privacy Officer can help you determine the best
approach.
For further guidance please refer to:
Nutranet > Policy House > E&C > Privacy Codes
for Employee and Customer Data

Your commitment

26 | Nutreco Code of Conduct

If in doubt: ASK
While our Code and policies are well-defined, everyday life is not always as straightforward. You may face challenging situations in which the right thing
to do is not immediately obvious. If you are unsure about what to do or what decision to make, ask yourself the following questions:

If the answer to any of these questions is “no,” do not proceed.
If the answer is “maybe,” seek guidance – here are a few ways you can do this:
1. Talk to your manager; he or she knows your business and your situation best.
2. Talk to a higher level manager.
3. Contact E&C or Legal.

SEEK GUIDANCE, THEN EVALUATEMAYBE

Is it legal?

NO

MAYBE

MAYBE

YES

Does it comply
with this Code?

NO

YES

Am I being
thruthful andhonest?

NO

MAYBE

YES

Will it protect
Nutreco’s
reputation?

MAYBE

YES

NO

STOP, LOOK FOR BETTER ALTERNATIVES

27 | Nutreco Code of Conduct | Your commitment

Would I feel
comfortable if it
was published?

NO

YES

Raise yourconcerns andSpeak Up!
Our business is built on the trust we earnfrom our stakeholders. Any violations of ourCode and policies erode this trust. Failingto follow the Code can put your colleagues
and our business at stake. Because of this,
it is important that you report suspectedviolations of our Code. There are several safe
ways for you to do this.
“Good news may travel slowly, bad news
should travel fast”
In keeping with this principle embraced by
SHV, you must report possible Code violations
as soon as you become aware of them. This
will help us to solve them before they havea negative effect on Nutreco. As a manager
stimulate Speak Up: talk about it, listen
carefully and act in a fair and reliable way.
Where can you raise your concerns?
There are multiple ways:• Talk to your manager or a higher level
manager.
• Talk to HR.
• Talk to E&C or Legal.
• Send a message to compliance@nutreco.com• Leave a report with our whistleblower line
Speak Up.

28 | Nutreco Code of Conduct | Your commitment

Speak Up
• Speak Up is the central whistleblower programof SHV.
• Information on Speak Up can be found on
special display boards in almost all of our
locations.
• Speak Up can be reached online (www.
shvspeakup.com) or by telephone using the tollfree national number found on the display board
in your location.
• Reports can be made by name or anonymously.
Investigation process• Reports will be investigated by one or moreinternal and independent investigators.
• The facts of the situation will be establishedby reviewing relevant documents and throughinterviews.
• We will respect the privacy and confidentialityof everyone involved in the process to thefullest extent possible.
• Employees under investigation will be notified
and have the right to be heard as soon as
possible during the process.
• The reporter (if known) will be provided withfeedback on the outcome of the investigation.
Non-retaliation policy
We will not tolerate any retaliation against anyone
who, in good faith, reports a potential violationof our Code or internal policies. Any form of
retaliation may result in disciplinary action, up to
and including termination of employment.

Corrective action
If we determine that there has been a breach of
our Code or policies, corrective action against
the involved employee(s) will be considered.
This may range from sending the employee(s) aconfirmation of our rules or a formal warning letterto terminating their employment and will depend
upon:• Whether the conduct was accidental ordeliberate• Whether the conduct involved a violation of thelaw• Whether the conduct involved dishonesty, theft,
fraud or personal gain
• Whether the conduct was repetitive or systemic• Whether the employee cooperated fully or tried
to conceal things• The employee’s level in the organisation• Whether the employee self-reported or not.
Q&A
I suspect – but am not certain – that someone isviolating our Code. Should I keep my concerns tomyself until I am sure?
> No. If you suspect a violation, raise yourconcerns. Reporting in good faith means thatyou can also share concerns you believe are true,
but which may, after investigation, turn out to be
unsubstantiated.

29 | Nutreco Code of Conduct | Your commitment

Nutreco
Stationsstraat 77
3811 MH Amersfoort
The Netherlands
T +31 (0)33 422 6100
compliance@nutreco.com
www.nutreco.com
Trade Register no 16074305 Eindhoven (NL)
30 | Nutreco Code of Conduct | 2022