Aller Holding A/S – Code of Conduct •
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Introduction and purpose Legislation Terms of employment Environment and security Conflicts of interest Corruption and bribery Freedom of speech Distribution Consequences of violation Contact person Sphere of application Effective date and period of application Introduction and purpose One of the most important values of the Aller group is respect of the environment, society, competitors and the customers and not least each other. This has been a part of the company foundation since it was casted by the pioneers of the Aller family in 1873. By outlining this Code of Conduct the Aller group wishes to facilitate responsible conduct. At the same time the Aller group underlies that this Code of Conduct shall also be complied by the business partners of the Aller group. It is important to the Aller group to respect and support human rights and workers standards both internally and externally in relation to business partners. Legislation Companies within the Aller group must comply with all national laws, regulations and international treaties. If there are differences between the terms of this Code of Conduct and national laws etc., the companies in the Aller group shall furthermore adhere to the higher and more stringent requirements according to this Code of Conduct. This Code of Conduct is not and should not be considered a means to circumvent or undermine the national laws or national working environment authorities. Also this Code of Conduct is not and should not be interpreted as a replacement for free labor unions and nor should it be used as a replacement for collective bargaining. Terms of employment 1. Forced labor Companies in the Aller group must not participate in or profit from any kinds of forced labor. Companies in the Aller group must treat all personnel with dignity and respect and must not participate in or tolerate the use of corporal punishment, mental or physical coercion and verbal abuse of personnel. 2. Child labor and young workers Companies in the Aller group must not participate in, benefit from or make use child labor. The minimum age for employment shall not be less than the age of completion of compulsory school, and in any case, shall not be less than 15 years or 14 years where established by national laws in accordance with the ILO developing‐
country exception. Children and young people under 18 must not be employed in night time or hazardous work. 3. Discrimination Companies in the Aller group shall not engage in or support discrimination on the basis of race, color, sex, language, religion, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, health status, age, or disability or other distinguishing characteristics. Hiring, remuneration, benefits, training, advancement, termination, retirement or any other employment‐related decisions shall be based on relevant and objective criteria. 4. Freedom of association Companies in the Aller group shall respect the workers’ rights to form and join unions or other associations of their own choosing and to bargain collectively legally. 5. Work conditions and remuneration Violence on the place of employment, including abuse, harassment and threats Companies in the Aller group shall protect the workers against any form of physical, verbal, sexual or mental harassment, abuse or threats on the place of employment, whether it is committed by managers or colleagues, also when deciding and carrying through disciplinary measures. Remuneration As a minimum companies in the Aller group shall comply with existing laws and signed agreements concerning remuneration and benefits. In the same way overtime shall be remunerated according to the laws in force and signed agreements. Vacations and breaks According to existing laws and signed agreements the companies in the Aller group shall allow vacations and breaks during illness and parental leave to workers who must take care of a new born or a newly adopted child. Parents on parental leave cannot be dismissed or be threatened to be dismissed and must be able to return to their work in their previous employment at the same remuneration and benefits. Work time No worker shall be required to work more than 48 hours a week on a regular basis and all workers must averagely have one day off per every seven‐day period. Overtime (exceeding 48 hours) shall not exceed 12 hours per worker per week and can only be requested under specific business conditions. Environment and security Companies in the Aller group shall secure that their workers have a secure and not an unhealthy working environment. This should include, but is not limited to, protection against fire, accidents and toxic substances. Adequate security and procedures must be established and followed. Companies in the Aller group must give their workers the protective equipment and education necessary to do their work securely. Companies in the Aller group must strive to minimize the adverse environmental and climate impacts of its activities, products and services through a proactive approach and responsible management of its environmental aspects, including (but not limited to): • Use of scarce natural resources, energy and water • Emissions to air and releases to water • Noise, odor and dust emission • Potential and actual soil contamination • Waste management (hazardous and non‐hazardous substances) • Product issues (design, packaging, transport, use and recycling/disposal) Companies in the Aller group shall maintain awareness of current environmental legislative requirements which are relevant to the environmental impacts of its activities, products and services. Also the companies in the Aller group must ensure legal compliance through training, awareness, operational control and monitoring. Conflicts of interest Workers in the companies of the Aller group are expected to work in the interests of the companies. Workers and their family members must not make personal gain at the expense of the Aller group without previous written permit from the company. Workers must not work for the customers and suppliers of the Aller group without written permit from the company. Presents and representation may in some cases be part of the business conditions but must be given and received with caution and only to a limited extent determined in the internal guidelines of the companies in the group. Corruption and bribery Companies in the Aller group must refrain from bribing and the use of other illegal methods. Freedom of speech Companies in the Aller Group shall respect every person’s right to freedom of speech; this right includes the freedom to speak one’s mind without interference and to seek, receive and give information and thoughts by any means of communication and regardless of borders as long as it is done according to the laws in force and signed agreements and in respect of confident information and of course, provided that all the usual obligations according to the employment law loyalty concept are observed. Distribution Companies in the Aller group shall make sure that a copy of the ethical guidelines is communicated to all workers and is available to all the business partners of the group. Consequences of violation It is important to our credibility and our reputation in business that everybody with a relationship to the Aller group are acting according to local laws and internal guidelines as described in this present Code of Conduct. Lacking in observation of the Aller group’s Code of Conduct will result in consequences such as a warning, termination etc. Contact person Questions to the present Code of Conduct can be addressed to CFO Morten Krüger, Aller Holding A/S. Area of validity All business units in the Aller group must comply with this Code of Conduct. Effective date and period of application The present Code of Conduct enters into force on January 1st, 2013 and will be applicable in the above mentioned version until the Aller Group may decide to adjust its content or to terminate it. Governing text The Code of Conduct has been translated from Danish. The Danish text shall govern for all purposes and prevail in case of any discrepancy with the English version.