Introduction

Feeding the world’s growing population in a responsible andsustainable way is at the core of Nutreco’s mission. Our own people
and operations are governed by our Code of Conduct for Employees
and supporting policies and processes. Our Code of Conduct for
Employees can be found here.
We recognise that our mission can only be achieved with the cooperation of our business partners. Therefore, we havedeveloped this Code of Conduct for Business Partners. It enables us to engage with our Business Partners on sustainability,
compliance and integrity issues, and we will only conduct business with companies or individuals that comply with thestandards set out in this Code of Conduct.

If a Business Partner fails to comply with this Code of Conduct, Nutreco may take corrective measures,
including termination of the business relationship.

Our mission can only be achieved withthe cooperation of our business partners.

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The Codeof Conduct

The term “Business Partner”
in this document refers to any
company, organisation or,individual engaging inbusiness with Nutreco.

• In addition, our Business Partners shall not provide financial
or other support to political parties or candidates toinfluence transactions with or for Nutreco.
• Business partners shall comply with relevant privacy andinformation security laws and regulations for the collection,

Labour practices

Supply chain responsibility

Business Partners shall:Business Partners shall endeavour to ensure that the principles• Provide safe and healthy working conditionsof this Code of Conduct including applicable supplements isfor its employees.

processing, storage, transmission and deletion of personal• Have a Health & Safety Policy that is freely available fordata. Business partners shall protect the reasonable privacy

all employees to access at any time, if and to the extent

expectations of all stakeholders and ensure appropriate

required under local laws.

levels of data security.

Legal compliance• Continuously strive to minimise accidents and risks.
• Provide a working environment that is free fromharassment and disrespectful conduct.

• Business Partners shall abide by all applicable laws
and regulations that govern their business activities.

Environment• Business Partners shall comply with applicable trade
sanctions and regulations. Nutreco does not accept any

Business Partners shall:materials or services from persons, entities, governments• Respect all relevant environmental laws and regulations.

or countries if doing so violates applicable sanctions.

• Ensure the efficient and sustainable use of resources and• Nutreco has a zero-tolerance approach to corruption.

strive to minimise their negative impact on biodiversity,

Business Partners shall not be involved in any form of bribery,
kickbacks or facilitation payments. Business Partners are
expected to observe Nutreco’s standards concerning gifts
and hospitality involving employees and representatives
as included in our Code of Conduct for Employees(see link above).
• Nutreco promotes and supports fair competition. Our
Business Partners shall compete fairly and comply withantitrust and competition laws in the countries in which they
operate. Business Partners shall not make agreements orengage in practices that are illegal, such as price-fixing,
market allocation or abuse of a dominant position.
• We expect our Business Partners to immediately declare
any potential conflict of interest before starting a businessclimate change and water scarcity.

Human rights
Business Partners shall:• Respect laws and regulations regarding wages
and working time in the country concerned.
• Not engage in child labour1.

• Manage waste responsibly and implement steps toreduce, reuse or recycle waste as much as possible.

• Not use prison, indentured, or bonded labour 2, or use

age for hazardous work at 18 (16 under certain strict
conditions). It provides for the possibility of initiallysetting the general minimum age at 14 (12 for light work)where the economy and educational facilities are
insufficiently developed.
2 According to ILO Forced Labour Convention (no. 29),
forced labour is any work or service performed underthe menace of penalty, and for which the said persons
have not offered up themselves voluntarily. There arethree common forms:
Prison labour: Work performed by individuals
requirement of their sentence and usually withoutcompensation.

for impact control.

Indentured labour: Work performed by an individual
contractually bound to an employer for a specific time

Product safety
be safe for their intended use.

• Respect and support the free association of labour
allowable by law.

work at 15 years (13 for light work) and the minimum

company operations and implement procedures

coercion as a form of discipline.

business relationship.

which sets the general minimum age for admission to

incarcerated by either the state or military that is a

All products and services delivered to Nutreco shalland employee rights to join a trade union where

1 We uphold the ILO Minimum Age Convention (no. 138),

operate, manage community impact resulting from

corporal punishment or other forms of mental and physicalrelationship with Nutreco and/or during theand partners.

• Engage responsibly with the communities in which they

• Support equal opportunities and fight discrimination
at the workplace.

communicated and fulfilled by their relevant suppliers

period, which is usually in return for payment of travel
and living expenses.
Bonded labour: An illegal practice in which
employers give high- interest loans to workers whoeither individually or as an entire family then labour at

Records

low wages to pay off the debt.

Business Partners shall keep accurate, complete and up-todate records of their business activities with Nutreco. These
records shall be retained in accordance with applicable laws.

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An ongoing dialogue

Nutreco welcomes dialogue about this Code of Conduct andexpects all Business Partners to actively address and mitigate
non-conformities. Business Partner gives Nutreco the right to audit,
at reasonable notice and during office hours, Business Partner’s
compliance with the requirements set forth in this Code and agrees
to provide all reasonable assistance to Nutreco (and our advisors)for obtaining the required information during such audit.

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The Code of Conduct
Supplement for supplierof Agricultural Products

We believe all agricultural
products should be produced ina responsible way. We work withrecognised organisations andplatforms to address outstanding
issues such as deforestation in a
pragmatic and effective way.

Some of the criteria can only be fulfilled by the suppliers ofSoils: Recognised best agricultural practices shall be adopted

to natural light, fresh air, fresh water, and a healthy diet.

agricultural products following up on and checking theseto maintain and improve soils, taking into consideration soil

Animals should be sheltered from extreme temperatures andcriteria with their own suppliers. This can for example be

structure, fertility and erosion.

be provided with adequate space and opportunity to engage

agricultural farmers of plant crops (soya, rapeseed, wheat…)

Water: Farm management practices shall ensure waterin natural behaviours, including social contact with otheror livestock farmers (dairy).

is used in the most efficient way and its quality assessed

animals. Animal stress during handling, transportation andand protected.

slaughter shall be minimised.

Deforestation and land use change: Suppliers shall act in

Responsible use of antibiotics: Best practices in farm healthaccordance with national laws, industry commitments andmanagement shall be adopted to avoid, reduce and, where

guidance to ensure deforestation and land use changes takeindispensable, guarantee the prudent and appropriate use ofplace in a responsible way. In geographical areas with aantibiotics. For its own operations Nutreco will work towards

high risk of illegal deforestation or land use change, Nutreco

no prophylactic usage and no use of antibiotics for growth

will insist on assurance that crops do not originate frompromotion. Nutreco will for its own operations ensure the useof antibiotic medication can only be used under direct andto the country of origin.

areas of illegal deforestation2. Nutreco will together with our
stakeholders support work towards agricultural value chainsapproved medical supervision by a veterinarian. By 2025

sourcing of agricultural crop and dairy products. Please note

Certification: Nutreco encourages suppliers to obtainthat are deforestation free, and will define geographicalNutreco will for its own operations will ensure no use of any

that these criteria are an addition to, and not a replacement ofrecognised third-party certification or any other means

sector specific deforestation cut-off dates3.

antimicrobials listed on the World Health Organization’s list of

the generic principles.

of independent verification that demonstrate compliance

Agricultural land expansion: Conversion of natural habitats

Criteria for sustainable sourcingof agricultural products:
Traceability: Suppliers shall implement traceability systems
that enable the products supplied to Nutreco to be traced

That is why in addition to the generic principles laid down in
our Code of Conduct for Business partners, we set additional
minimum criteria in regards to the sustainable production andback to their source. For crops, this would ideally go backto the farm where the crops were grown, but as a minimum

Although there are clear differences in the magnitude of thespecific challenges involved, these additional criteria address
the major issues that influence the sustainability of crop andlivestock production systems. This supplement is not intended
to be an exhaustive guide to sustainable agricultural practices.
More detailed sustainability criteria may be required andagreed upon between Nutreco and a supplier, which willthen be included in a separate agreement.

Scope• This supplement to the Code of Conduct for Business partners

Nutrient efficiency: Suppliers shall provide livestock with adesignated as degraded lands. Crops must not originate frombalanced diet targeted at the anticipated production level.

Supply Chain Responsibility (fortraders, agents or processors)

valuable natural habitats made into new agricultural land

Milk production per cow should be optimised and measures

after 2008.

should be implemented to increase the longevity of cows,

Suppliers shall make reasonable efforts to engage withawareness of potential adverse effects of their businesstheir own suppliers on the criteria for sustainable sourcing
and production of agricultural products presented inthis supplement.

Criteria for sustainable productionof agricultural products

is valid for all agricultural products supplied to Nutreco. This

Agrochemicals and organic fertilisers1: Recognised best

includes conventionally grown, organic and genetically

agricultural practices shall be adopted with regards to themodified (GM) crops and products derived thereof as well as

storage, use and application of agrochemicals and organic

products from the dairy industry.

fertilisers with the aim to reduce the need for agrochemicals,• Nutreco expects suppliers of agricultural products to ensurethat the criteria described in this supplement are fulfilled.

“Critically Important for Human Health.”

into new agricultural land should be encouraged in areas

with the criteria specified in this supplement.

minimise environmental pollution and avoid negative impacts
on human health and well-being and ecosystem services.

Protection of biodiversity: Suppliers shall demonstrate

resulting in minimised carbon (including methane), nitrogen,phosphorus and other nutrient losses.

activities on biodiversity and ecosystem services, and havemeasures in place to avoid, minimise, rectify or, as a last resort,compensate for these.

1 Agrochemicals includes crop protection products,

Greenhouse gas emissions: Suppliers shall demonstrateother pesticides and synthetic (inorganic/mineral)awareness of the activities in their direct operations andfertilisers; organic fertilisers include manures,

supply chains that are important sources for emissions ofcomposts, etc.

greenhouse gases and strive to reduce these.

2 Certification schemes fulfilling the FEFAC Soy Sourcing

Land use rights: Property and land use rights shall be

Guidelines are accepted as documentation of soy

respected, particularly with regards to indigenous people
and populations.

coming from areas of no illegal deforestation. For more
information, see here.
3 De-forestation, land use change and geographicalFor dairy products, the following
criteria for sustainable production
apply additionallysector specific de-forestation cut-off dates definedaccording to the principles developed by the
Accountability Framework Initiative(AFI) https://accountability-framework.org/

Animal welfare: Animals shall be treated with care andrespect. Living conditions for livestock should provide access
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The Code of Conduct
Supplement for suppliersof Marine Products

The ocean provides a rich habitat
for many marine animal and plant
species and therefore requires
careful protection. A crucial partof this is ensuring that those fishstocks that are caught for direct orindirect human consumption are
fished responsibly – within clearly
defined sustainable limits.

Fishery Management Framework and Procedures:

fulfilled. Some of the criteria can only be fulfilled by the

Criteria for marine products
from fish processing for humanconsumption (by-products):

suppliers of marine ingredients following up on and checking

Threatened species: Suppliers shall not process species

consider all fishery removals and the biology of the species.

these criteria with their own suppliers. This can for example be

or by-products from species that are classified as Critically

Stock Assessment Procedures and Managementfishing boats, fish processors or fish farms.

Endangered or Endangered in the IUCN Red List. Species that

Advice: There shall be scientific information available on

are listed as Vulnerable are not eligible for use as by-products,

the characteristics of the fishery relevant to the long-term

unless for fisheries from a discrete sub-population that haveconservation of the fishery and ecosystem, including its

been assessed and determined to be responsibly managed.

geographic distribution, stock assessment of target species

Nutreco expects suppliers processing industrial fisheries orby-products or trimmings from wild or farmed fish processing
to ensure that the criteria described in this supplement are

Criteria for sustainable sourcingof marine products – applicablefor all marine products
IUU fishing activity: Fishery materials shall not be fromillegal, unreported and unregulated (IUU) fishing activities.

Overfishing of wild fish stocks for fishmeal and fish oil
production is detrimental to the marine ecosystem. Therefore,
in addition to the generic principles laid down in our Code of
Conduct for Business Partners, we set additional minimum criteria
in regards to the sustainable sourcing of marine products and the
responsible management of the fisheries where these products
originate. Please note that these criteria are an addition to,and not a replacement of the generic principles.

Traceability: Suppliers shall implement traceability systems
that enable the original material used in the products sold to
Nutreco to be traced back to fishery/fisheries of origin, or the
farmed species and country of origin.
Certification: Nutreco subscribes to, and promotes, thefishery management principles of the FAO Code of Conduct
for Responsible Fisheries. Nutreco expects its suppliers to work
towards complying with the principles specified in that code.
Skretting also supports the MarinTrust Programme and regards
the criteria related to marine ingredients to be met when theThis supplement is not intended to be an exhaustive guideprocessor and the fishery is part of the MarinTrust programme

to sustainable management of fisheries. More detailed

Marine Stewardship Council certified fisheries meets thesustainability criteria may be required and agreed uponrequirements of the MarinTrust programme. Nutreco also

between Nutreco and a supplier, which will then be included

accepts suppliers and fisheries that are part of the MarinTrustin a separate agreement.

improvers programme.

Scope
This supplement to the Code of Conduct for Business partners
is valid for all marine raw materials used in Nutreco products.
This includes fishmeal and fish oil processed from fish andcrustaceans caught for the primary production of marine
ingredients, by-\products from fishery processing and byproducts from aquaculture.

9 CODE OF CONDUCT FOR BUSINESS PARTNERS - VERSION 3.0 SEPT 2020

be concerned with the whole stock over its entire distribution andCriteria for marine products
from aquaculture (by-products):

The Precautionary Principle: The fisheries management

Responsible use of antibiotics: Best practices in farm healthtarget species and for the conservation of the wider ecosystem.

management shall be adopted to avoid, reduce and, whereindispensable, guarantee the prudent and appropriate
use of antibiotics. The use of antibiotics shall be supervisedby an animal health specialist. Antibiotics of significant
human medical importance, particularly antibiotics listed as
critically important for human medicine by the World HealthOrganization (WHO), shall not be used if the principle intent is
to improve performance.
Mortalities: Material shall not originate from natural mortalities.

sustainable sourcing and responsible fisheries management
presented in this supplement and ensure that the products sold

These criteria are valid for fisheries where the whole fish is

to Nutreco are in compliance.

processed to produce fishmeal and/or oil.

Suppliers shall engage with their suppliers on the criteria forconservation of the fishery and ecosystem. Management shalland, where applicable, impacts on non-target species.

Criteria for material from wholefish. The term ‘whole fish’ is used
to describe fisheries where theprimary purpose of the fishery is
to produce fishmeal and fish oil
and where the catch is delivered
directly to a marine ingredient
processing unit:

Supply chain responsibility (fortraders, agents or processors):

Fishery management actions shall be based on the long-term

framework shall apply a precautionary approach to theconservation of the target fishery resource, associated nonManagement Measures: The level of fishing permitted shallbe set according to scientific advice and, where available,
a recommendation from an officially recognised body.
Reporting and Recording of Fishery Raw Materials: Fisherymaterials shall be traceable to a species and fishery/fisheries
assessed as compliant to the criteria for responsible fishery
management set forward in this Code of Conduct.
Fishery Improvement Programmes: Many importantfisheries are not currently managed well enough to comply
with the key requirements of the FAO Code of Conduct for
Responsible Fisheries. Therefore, Nutreco encourages its
suppliers that source materials from such fisheries to engage
with relevant stakeholders (fishmeal processors, fishermen,
traders and agents, authorities, NGOs etc.) to assist thesefisheries to improve their management practices so they areable to comply with the fishery management requirementsof the FAO Code of Conduct for Responsible Fisheries.

CODE OF CONDUCT FOR BUSINESS PARTNERS - VERSION 3.0 SEPT 2020 10

Nutreco N.V.
Stationsstraat 77, P.O. Box 299, 3800 AG Amersfoort, The Netherlands
T +31 (0)88 053 2405

W www.nutreco.com

Trade Register no 16074305 Eindhoven (NL)