Code of Business Principles - shared values - Nomad Foods
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FEATURING
Nomad Foods
shared
values
Code of Business Principles
CLICK TO OPEN
one vision, shared values
our society our employees our business our consumers
partners
Introduction
Dear Nomad Foods is Europe’s leading
frozen food business and our
To help us live and breathe our
values, we have renewed our
We are all accountable to the
values and principles described
Speaking up is essential. We do
not tolerate retaliation in any
Colleagues
portfolio of iconic brands has Code of Business Principles. It in the Code, and to acting on form against anyone speaking
been at the heart of family life for describes what is important to us them every day. up, doing the right thing, or
generations. They represent great when conducting business. We putting our Code before business
tasting food that is convenient, uphold all laws and regulations At the same time, we realise that results in case of conflict. In case
high quality and nutritious with that apply to us, and always real life is not black and white, of misconduct or violation of
the additional unique benefits strive to do things right, globally that we are not perfect, and the Code of Business Principles,
that only frozen can bring, such as and locally. Living by our Code that mistakes can be made. We disciplinary measures may follow.
reduced food waste. of Business Principles is good for will learn from and correct these
our business and creates value mistakes and seek constant It is essential that we all understand
As a purpose-driven company, in many ways: Loyal and satisfied improvement. That starts with our Code and the expectations
focused on “Serving the World with consumers, sustainable business speaking up. We encourage it creates for us. It’s our way
Better Food” we are guided by practices, value in our supply everyone to share any concerns of working and will help us to
our values. They support our vision chain, engaged employees, that they have, with a colleague succeed in the next phase of our
and growth strategy and capture professional and efficient business or manager, a contact in HR, journey as we grow the business
our strengths and opportunities for partner relationships, brand value, Legal, or Audit, or through together. If you have any questions
improvement. We care about what shareholder value, and value for Safecall - our external reporting or suggestions about our Code, Stefan Descheemaeker
we do, but also about how and society at large. line helping employees to raise please let us know. CEO, Nomad Foods
why we do it and have important concerns about unethical, unsafe November 2020
responsibilities to our stakeholders: This Code of Business Principles or unlawful practices across our
our consumers, our employees, applies to all who work for organisation. Safecall is available
business partners and investors - Nomad Foods, without exception, in several languages, 7 days a
and to the planet. We conduct our across all companies and week, 24 hours a day (for more
business operations with honesty, countries, to all Nomad Foods details, please see page 23 or visit
integrity and openness, with employees, contractors, the http://www.safecall.co.uk).
respect for the environment, and in Executive Committee and the
the interests of our consumers, our Board of Directors.
employees, and those with whom
we have business relationships.
2 | NOVEMBER 2020 one vision, shared values
y, we play
nsumers. our society our employees our business our consumers
partners
s Europe
d this
it.
Purpose
we all
Food for all
Serving
s in solving
anet.
Our broad portfolio of brands and products allow
ut our all consumers to enjoy great family mealtimes
with
THE world WITH
every day.
built the
better
We make products that are at the centre of
everyday family mealtimes. They are affordable,
Better Food
available in supermarkets across Europe
and in homes 24 hours a day, ready to
food
cook in a moment.
We continually improve the taste, nutrition
and sourcing of our products – year
Our focus is on ease of use and
our products can be prepared eating for
the planet
after year. using a variety of cooking
methods to suit every culture
At the heart of what we all do every day in Europe.
is making the food we produce better;
better for our consumers and better for In the UK, for example, a With a strong presence in fish, vegetables &
the planet. Our focus is always on better perfectly balanced meal of chicken we can - & will - lead the change to
r taste and better nutrition, underpinned by our products costs €7 for a a sustainable diet.
rkets the quality of our ingredients and recipes. family of four.
We improve the life of our planet through the
way we source and make our food and we
How are we making Our fish fingers are improve the health of our consumers when
our food better? encouraging the they eat our food.
• As much as 88% of our recipes are
a Healthier Meal Choice (HMC) fourth
generation of children
We know that the healthiest diets are the
most environmentally sustainable.
• By the end of 2020, 100% of our portfolio to love and eat fish. More than 95% of our fish and seafood is MSC
will be free of taste enhancers, artificial
or ASC certified, and more than two thirds of
flavours and artificial colourants
our vegetables are grown using sustainable
• 98% of the palm oil we use is RSPO farming practices. In both cases, we will
certified. achieve 100% by 2025.
We are committed to helping our consumers
We removed the reduce redmeatmeat consumption
consumption, and eat
doubling
equivalent of more fish, vegetables
vegetable and plant protein
and fish consumption by 2050
1of salt
elephant
from our
through our brands and products. Green
Cuisine, our new meat free range, is just one
we’re helping
of the ways we’re helping them
them embrace
embrace aa
flexitarian diet.
flexitarian diet.
portfolio last year
3 | NOVEMBER 2020 one vision, shared values
our society our employees our business our consumers
partners
Key Values & Principles
GLOBAL OR LOCAL GREAT PEOPLE ACCOUNTABLE LOVE OUR BRAND
ACT FAST ENTREPRENEURIAL COST CONSCIOUS ALWAYS STRIVING
We respect and protect We provide a safe open and We deal openly and fairly We provide high quality
human rights in all our respectful work environment with all our business partners products manufactured with
operations high levels of safety and
We avoid confl icts of interest We do not give or accept gifts cleanliness
We follow all internat ional We encourage speaking up or events to obtain business
laws and regulat ions that and critical feedback
We respect privacy and treat
We compete fairly and all persona l data with care
apply to us
We hand le information transpa rently
We care about the We are open and truthful in
and personal data sensi bly We hold all our partners to
environment and source our our marketi ng and advertising
the same high standards as
raw materia ls sustainably
ourselves
4 | NOVEMBER 2020 one vision, shared values
our society our employees our business our consumers
partners
Stakeholders, Values
& Business Principles
As Europe’s leading frozen food business, We combine our global scale We inspire each other to be the We do business honestly, with We realise every day that what
Nomad Foods has a responsibility to the and local proximity to consumers best we can be and our teams to integrity and transparency. We we do, we do for our consumers.
world and its people. We feel and share this and customers to build on our be better than ourselves, positively do not offer or accept bribes, We build iconic brands which
responsibility throughout our supply chain and brand heritage, innovate, develop influencing the company’s results and compete openly, fairly are trusted by consumers and
strong retail partnerships and and our future. We provide a and ethically, knowing that produce great tasting, nutritious
towards all of our stakeholders: We source
create fuel for growth. Wherever safe, clean and healthy working only honest and open business food that makes consumers’ lives
our materials globally with respect to the
we operate, we follow all laws environment for our employees. provides long- term value. We are more enjoyable. Our brands also
environment and to human rights. We process and regulations that apply to us. We take pride in our diverse and cost conscious, we only spend represent our image and our
and produce our meals to high standards of We respect and protect human inclusive workplace where there to improve the performance of reputation. Our consumers must
health and safety, for our consumers, customers rights in all our businesses. We is mutual trust and transparency, our business and our people, trust that we will be truthful and
and employees. We buy, market and sell our care about the environment and respect for privacy and protection treating the company’s money clear in our advertising and
products and services from and to our business continually strive to source our of our personal data, and where as our own and making every
partners and customers with honesty, integrity raw materials sustainably. We everybody feels safe to speak up Euro count. We are professional marketing, fair and transparent in
and transparency. We conduct our business share this responsibility with all of about anything. We avoid conflicts in setting our budgets and follow our pricing and respectful of our
in line with our values, which translate into our stakeholders, and empower of interests and put the company’s our guidelines on gifts and consumers’ privacy and personal
principles we apply in our global operations: everyone to act quickly by interest before our own. We want hospitality. We expect everyone data. We are always looking
deploying simple, consistent and people to think like entrepreneurs, to deliver these commitments and for additional opportunities
robust ways of working. challenging the status quo expect the same accountability and are never content
while acting in the interests of of our business partners. We with “good enough”.
the company. Our recruitment will consistently enforce these
is based on fair, objective and standards, together with
transparent decision making the Nomad Foods Supplier
and we support the continued Code of Conduct.
professional development
of our employees.
5 | NOVEMBER 2020 one vision, shared values
our society our employees our business our consumers
partners
Our Society
OUR INGREDIENTS
We operate in many countries, and source, Food and the environment Protecting human rights
produce, process, package and ship our goods of any kind of exploitation).
Many international food As a food business, our activities Nomad Foods is committed to
globally. Nomad Foods is also listed on the New regulations apply to our business – have an impact on the ethical trading, sourcing and Nomad Foods is committed to
York Stock Exchange, has access to capital food quality assurance standards, environment. We realise the procurement, which means transparency in its own business
markets and is involved in financial transactions import and export laws, local importance of sourcing our goods that we uphold and live by and tackling any form of modern
and global permits and licenses, sustainably and with respect to the fundamental international slavery or human rights abuse
worldwide. Many laws and regulations apply to
health, hygiene and safety the environment. We always seek standards that protect human throughout its supply chain,
our business, both global and local. We abide consistent with international
guidelines and procedures. Our to source, manufacture and sell rights. We recognise that the
by these laws and regulations, and respect food products are our bread our food to consumers responsibly supply chain of food production human rights and modern
the cultures and the people of the countries in and butter, and our business can and for the long term. Our and processing is a sector which anti-slavery standards.
which we do business. We uphold international only thrive to the extent that we sustainability and corporate social may be vulnerable to modern
We encourage all of our
Corporate Social Responsibility standards and follow all applicable food safety responsibility programme reflects slavery, particularly due to
employees and business partners
regulations, and, whenever or our commitment and continuous the global nature of suppliers.
always seek opportunities to improve, together to speak up in case of human
wherever necessary, do even more search for improvement – more Together with our suppliers,
with our business partners. than the law requires. details can be found in our annual Nomad Foods’ goal is to respect rights violations. We will act fast
and consistently in case of any
Sustainability Report. and actively protect human rights.
human rights violations, whether in
Modern slavery and human rights our own operations or in our supply
abuse can take many forms: chain, and will take whatever
forced and child labour, sexual measures or sanctions necessary
exploitation, debt bondage in full and open cooperation with
(where victims are forced to work local or global authorities.
to pay off high debts), domestic
servitude and human trafficking
(where people are moved across
or within countries for purposes
6 | NOVEMBER 2020 one vision, shared values
our
our society
society our employees our business our consumers
partners
Our Society
OUR INGREDIENTS
Trade Sanctions & Embargoes How might this apply to our business?
The European Union (EU) and its Trade sanctions and embargoes Nomad Foods will carefully and will take appropriate action if Imagine the following
member states, the UK, the United isolate such countries, companies monitor and uphold any such they are. We ask all our employees, two situations:
States of America and the United and individuals from an economic trade sanctions and embargoes especially in Procurement, Supply 2. Nomad Foods performs
Nations impose trade sanctions and trading point of view, which against countries, companies and Chain, Sales and Finance, to be financial transactions with
and embargoes from time to time helps to reduce or stop the individuals. We will screen new aware of this and contact Group and through banks and
1. Through an agent, Nomad financial institutions. These
against countries, companies illegal activity. Doing business suppliers and customers to check Legal immediately in case of any
Foods accidentally buys fish banks themselves have
or individuals involved in certain with countries, companies or whether they are subject to any doubts or questions.
from a farm in a sanctioned very strict requirements
illegal activity, such as drugs and individuals under trade sanctions is international trade sanctions,
country. While frozen food under international trade
weapons trade, terrorist regimes, an offence that can lead to heavy
itself does not qualify as sanctions, to prevent
civil wars, human rights abuse, fines and even imprisonment.
an embargoed product, financing of illegal
natural resource conflicts, or
if there is a general trade activity. Nomad Foods
financing of such illegal activity.
SUSTAINABILITY PEOPLE PLANET PROFIT embargo against a must comply with these
country, we or any agent requirements as well.
of ours should not do any
business in that country.
7 | NOVEMBER 2020 one vision, shared values
our
our society
society our employees our business our consumers
partners
Our Society
OUR INGREDIENTS
Preventing money laundering
Criminal activity like money Our Procurement and Sales We are vigilant and exercise good
laundering may not always be processes are designed to ensure judgment when dealing with Nomad Foods remains
obvious, so it is important that that we comply with all relevant unusual customer transactions, proactive when it comes to
we work to reduce our exposure anti-money laundering, financial including requests to make spotting financial transactions
and speak up about anything crime and anti-terrorism laws in the payment to, or receive payment that might signal a problem,
suspicious. Money laundering is a countries where we operate, and from a different company than the and requires its employees
process where funds generated these processes must be followed one Nomad Foods is buying from to report any activity or
through criminal activity – such for all purchases of goods and or selling to. We will only conduct transaction that is outside
as terrorism, drug dealing, tax services, and for all sales. business with customers that are of the norm to a manager
evasion, human trafficking or fraud willing to provide us with proper or Group Legal.
– are moved through legitimate information that allows us to
businesses in order to hide their determine whether the payments
criminal origin. We are committed are appropriate.
to conducting business in a way
that prevents the use of our
business in this manner.
8 | NOVEMBER 2020 one vision, shared values
our society our employees our business our consumers
partners
Our Employees
OUR INGREDIENTS
At Nomad Foods, we have great people Health and safety
working together to make great products. We
Nomad Foods takes health and Nomad Foods will keep all
are committed to the health, safety, welfare safety very seriously. Our factories employees involved in the
and engagement of our employees. Our and sites should be a safe development of a successful
working environment and culture, guided by our environment for all employees, health and safety culture,
company values, is one of mutual respect and business partners, consumers including the appointment of
and other visitors, including employee representatives and
trust. We promote inclusion and diversity and
those working, visiting or living inclusion of employees in health
equal opportunity for all. We do not tolerate any nearby. We follow all national and and safety discussions, training
form of harassment, discrimination or retaliation. international health and safety and consultations. Where specific
We feel free to report and discuss any issues or laws, regulations and guidelines local health and safety guidelines
incidents, whether with a colleague or manager, applicable to our business. Nomad and procedures apply, all
Foods will involve all employees employees should be aware of
with HR, Group Legal or into the Safecall*
in health and safety and expect and follow such guidelines and
reporting line. We believe in the power of open all employees to embrace safe know what process to follow and
and constructive feedback, learning from each working practices and prevent who to contact if an emergency
other and from our mistakes, and having an personal injury. This is first and or incident occurs. If anyone is
open mind to new ideas as being key drivers of foremost a responsibility of Nomad concerned that the health and
our entrepreneurial and innovative approach. Foods executives, directors and safety principles, policy or local
managers to our employees and procedure is not being followed,
visitors. It is also a duty of every we encourage them to share their
Nomad Foods employee to take concerns immediately.
reasonable care for the health
and safety of themselves and their
fellow employees and visitors.
* F or more information on how to report issues, please
turn to page 17 of the Code of Business Principles
9 | NOVEMBER 2020 one vision, shared values
our society our employees our business our consumers
partners
Our Employees
OUR INGREDIENTS
Inclusion and Diversity Discrimination and Harassment
At Nomad Foods, a culture of Nomad Foods will ensure that all We are committed to providing
inclusion means having diverse employees work in an environment a harassment-free environment,
thoughts and experience around that promotes mutual trust and in which we all have an
the table. Giving everyone a respect, where everyone is opportunity to contribute at our
voice so that together, we make treated fairly and equally, without highest potential. Harassment
better business decisions and discrimination on the grounds is behaviour that creates an
deliver better outcomes. Our of race, age, role, gender, skin offensive, intimidating, humiliating
brands are focused on people colour, religion, country of origin, or hostile work environment
and real human experiences and sexual orientation, marital status, that unreasonably interferes
as a purpose-driven company disability, social class, political with another person’s work
focused on “Serving the World with views or other characteristics performance. Harassment may
Better Food”, we know that to stay protected by law. be physical or verbal, and may be
relevant to the consumers and done in person or by other means
communities that we serve, we (such as harassing notes or emails).
must attract, develop and retain Examples of harassment include
the best and most diverse talent in unwelcome sexual advances or
every country and at every level. remarks, offensive jokes, bullying,
There must be no barriers to our isolating or not co-operating
people being able to bring their with a colleague, or spreading
whole self to work, to give their malicious or insulting rumours.
best performance and to achieve
their full potential.
10 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Employees
OUR INGREDIENTS
Conflicts of interest A Nomad Foods employee
has a daughter that works
Working at Nomad Foods requires In situations like these, you may for a major compet itor as a
making business decisions in the not be objective and the question quality control inspector. The
best interests of our company. arises whether without the employee has access to sales
That’s why we never allow personal personal interest you would have and forecasting data and
interests to influence our business come to the same decision. That future pricing.What should the
decisions. A conflict of interest may damage both Nomad Foods Nomad Foods employee do?
arises when a personal interest and our employees. The employee should report
can affect a business decision the potential conflict of
over which you have influence. For We make business decisions in
interest internally. Because
example, when you decide to hire an objective and transparent
the daughter does not work in
a relative or friend for a Nomad manner, and always in the best
sales or marketing or pricing,
Foods job without following the interest of our business. We avoid
the conflict of interest is minor
usual selection process. Or when conflicts of interest, and even the
but even so the employee
you contract with family to provide impression of a conflict of interest.
should be reminded of his
services to Nomad Foods, without When we suspect a conflict of
confidentiality obligations.
proper tendering. Or when we interest, we report and discuss
However, if the daughter is in
have an interest in a competitor, this immediately.
charge of the competitor’s
a business partner or a customer pricing strategy, the conflict
of Nomad Foods. of interest is serious. Further
action must be taken to
protect both the employee
and the business, as well as
the daughter, for example, by
putting in place more robust
confidentiality agreements.
11 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Employees
OUR INGREDIENTS
Company assets, insider trading and privacy
We are all responsible for the While working at Nomad Foods, We respect privacy and safeguard One of your team members
Examples of inside
proper use, protection and we may become aware of personal data of both employees is a stella r perfo rmer. You
information include
conservation of Nomad Foods’ material (i.e. price sensitive) non- and consumers, in line with share his latest evaluation
information about: a
assets. Think broadly of assets: It public information about Nomad local laws and the European results with your colleague
significant merger or
includes property, machinery, Foods or other companies with Union General Data Protection in Finance and copy the HR
acquisition; significant
computers, phones and materials. whom we do business. Such Regulation. We will limit use and manager, as you wish to
posit ive or negative
They are the property of Nomad “inside information” is information processing of personal data to furthe r develop this team
earnings’ information or
Foods and intended for business about a company that is not the goals we need it for, and only member’s caree r at Nomad
volume results; gain or loss
purposes only. We take care of known to the general public and with explicit consent, or other Foods. Is that OK?
of a significant customer or
all company assets, and take that a reasonable investor would legal basis. We will be critical,
supplier; pending regulatory
appropriate precautions against consider important when deciding transparent and clear about This seems in the direct
action or significant
misuse, loss, theft or damage. whether to buy, sell or hold that when, how and where we use interest and benefit of your
litigation; or a change in
company’s shares or securities. You personal data. We will follow team member. But evaluation
Company assets also include senio r management.
must not buy or sell the securities of the standards of “privacy by results are personal data that
information like financial data, cannot be shared directly
a company if you have knowledge Play it safe! If you are not design and default”, and assess
company know-how, intellectual under the EU Gene ral Data
of material non-public information. sure whether information is the impact of privacy when
property and trade secrets. Protection Regulation.
Doing so is a criminal offence in material or whether it is non- developing new product or service
We handle such information And while we stimulate
many countries (known as “insider public, treat it as though it is, initiatives. We make sure we do not
with care and common sense. the development of our
trading”) and is a violation of and get in touch with Group retain personal data any longer
That means we make sure that employees and their careers
our Code. If you have any doubt Legal before proceeding. than we have to, and will follow
access to confidential, personal at Nomad Foods, first check
about a potential securities all applicable data retention
or sensitive information is limited with HR and Legal and of
transaction, seek guidance schedules and terms.
to those who need it and that course your team member
from Group Legal who issue and
we share it only when necessary, whether it is OK to share the
maintain the Code of Practice on
and are mindful when discussing evaluation results.
dealing in Nomad Foods Securities.
it with others. We protect digital You must also not reveal any
information and follow all IT and material non-public information to
information security guidelines any other person, including to any
and best practice. family member or friend.
12 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Employees
OUR INGREDIENTS
Communication Financial Integrity
We realise that communication Nomad Foods will maintain We do not tolerate fraud of any
has become much easier, and accurate, complete and timely kind, and any fraudulent activity If you hear comments like:
much more frequent, because records in relation to all aspects by any employee will be subject “Make the numbers work.”
of the internet, and the explosive of our business in compliance to disciplinary action. Fraud
growth of social media and with local laws and regulations. can take many forms including “Hold that sale until next
personal devices. We are able In particular, we will ensure we falsifying expense claims, month so we can meet next
to share information, data and comply with all relevant financial misappropriating assets, falsifying quarter’s target.”
news faster and with more people reporting and accounting sales information or dishonestly “Punch my timecard for
than ever before. That’s why we standards and regulations. altering or concealing company me because I am running
are careful and respectful in all of Employees must only perform records. In particular, it is strictly a little late.”
our communications, internal or transactions (such as buying, prohibited to do anything to
external, written or spoken, digital selling or transferring goods artificially inflate or shift sales or Stop and seek help!
or analogue, as the statements or assets) for which they are profit between reporting periods or
If it sounds illegal or unethical,
and comments we make can authorised, ensure transactions to create or maintain undisclosed
it probably is.
reflect on Nomad Foods and have they approve are legitimate and or unrecorded accounts,
an impact on our organization. We based on valid documentation, funds or assets.
refer any requests for information properly document assumptions
from outside Nomad Foods to that underpin accounting records,
our Corporate Communications and co-operate fully, openly and
department, since only they honestly with internal and external
and members of the Executive auditors, tax authorities and
Committee can speak on behalf other regulators.
of Nomad Foods to press, investors
and other outside parties.
13 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Business Partners
OUR INGREDIENTS
Nomad Foods is a Business-to-Business (B2B) No bribes or facilitation payments
company. That means that we do much of our
Nomad Foods conducts itself If Nomad Foods or its business Gifts are often seen as bribes,
business with and through other companies – fairly, honestly and lawfully in partners are involved in bribery and even the intention to bribe
our business partners. We source, buy, produce, all its business dealings and or corruption, it may lead to may be illegal. Sometimes, a
process, package, distribute, market and relationships globally. We do not What is a bribe? A bribe is criminal and civil liability, and will gift is presented as something
sell through our global network of business tolerate bribery, corruption or anything of value offered to seriously hurt our business and good – for example, a
partners. The international laws and regulations facilitation payments, and follow someone in order to obtain our reputation. We will therefore donation to a charity in the
all anti-bribery and corruption an unfair advantage. It could immediately report any suspicion name of another company.
that apply to us, apply similarly to our business laws and legislation, such as the be cash, but more often it of bribery or corruption. Or funding a playground
partners, and we must hold our partners to US Foreign Corrupt Practices Act is a gift, enter tainment or in a city where we want to
the same high standards as we do ourselves. and the UK Bribery Act. We never a special favour. This can set up a new business. Just
The main principle is that we deal with all of accept or give anything of value include bottles of wine, tickets because there is a good
our business partners openly, fairly and with that is intended to result in, or is a to events or electronic items, cause behind the gift does
reward for, an unfair or improper but also job or internship offers, not necessarily mean it is
integrity. This accountability applies throughout business advantage. special discounts or credits not allowed. Stick to business and
the entire food supply chain. available to others, donations always ask yourself who is
or sponsorships. Whatever the benefitting from a gift.
form, bribes are unacceptable
Business partner and illegal in most countries.
s refers
to suppliers, co
-packers,
distributors, de
alers,
wholesalers, re
tailers,
cont ractors, ag
ents,
consultants or an
y other
external party
we do business
with at Nomad
Foods.
14 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Business Partners
OUR INGREDIENTS
No bribes or facilitation payments continued Political Donations and Charitable Contributions
Bribery and corruption take many forms, which are not always easy to Facilitation payments Facilitation Nomad Foods does not make We encourage our local
recognise. Some general guidelines in doing business are helpful: payments are payments made donations to any political parties businesses and employees to
to government officials or others or candidates, or for any political engage in their local communities
o Clearly document and record all payments and transactions, and
as a personal benefit to secure purpose. However, we respect and support charitable causes.
make sure they are based on a solid, legal contract. If you don’t
or speed up the performance of the rights of our employees to For all work related charitable
understand the basis or reason for payment, ask and check further,
a normal business transaction. participate in political activities donations, you should obtain the
with Legal and Finance.
For example, a customs officer and to determine their individual approval of your function lead,
o Do not accept any off-the-books transactions, secret accounts, asks for an extra fee to allow a political views and preferences. make sure the donation is made
‘work-arounds’ or quick solutions, or anything that looks like a food shipment to cross borders. Employees should only conduct only to a registered charity and
circumvention of this policy In most countries, facilitation such activities outside of working that it complies with our Anti-
o Be extra mindful when dealing with government officials or payments are illegal, but in some hours and not use Nomad Foods Bribery and Corruption Policy.
authorities. Gifts and hospitality to government officials are clearly countries, such payments are resources or claim to represent
forbidden in most countries. Public hospitals and retirement homes, considered part of business. Even Nomad Foods in any way.
import and export functionaries are all government officials and if legal, facilitation payments
Nomad Foods may do business with them in some countries, either are controversial, and may
directly or through agents. We and our business partners should not lead to bribery and corruption.
give gifts or hospitality to government officials, as they can easily be That’s why Nomad Foods as a
seen as bribes. general rule does not tolerate
facilitation payments.
15 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Business Partners
OUR INGREDIENTS
Use Common Sense One of Nomad Foods agents
sells Food Service on behalf
Nomad Foods recognises that gifts o Gifts and hospitality should o Nomad Foods’ merchandise o Be mindful of the recipient’s o Limit gifts and hospitality to of Nomad Foods to a public
and hospitality can play a positive always be modest, appropriate is a good alternative to gifts own policy and practice on gifts business relationships only... hospital. The holidays are
role in building relationships with to the circumstances and not and hospitality... and hospitality... Family, children, partners or near and the agent decides
our business partners. At the more than once a year... Make sure it is branded Even if it’s allowed by Nomad friends should not receive to give a nice bottle of wine
same time, gifts and hospitality For example, a nice book with the Nomad Foods or Foods, a gift might create gifts and generally should not with a note, thanking the
can easily create the impression of EUR/GBP 20 to a retailer is local brands’ logos an awkward situation if the participate in events hospital director for business
of bribery. We must always use fine; twenty books to all team recipient cannot accept it, like a done and looking forward to
o Follow the zero-based o When in doubt, don’t accept or doing business again next
caution and common sense members of the retailer is government official
budgeting policy... offer gifts or hospitality... year. Is that OK?
when accepting or offering gifts excessive and inappropriate
We are cost conscious in all our Trust your judgment; if it
and hospitality, especially when o Nomad Foods does not Probably not. Even though the
o Be mindful of cultural business decisions, so also in our feels wrong, it probably is
doing business with government accept nor offer travel and value of the bottle of wine is
differences and act with grace gifts and hospitality budget wrong. Kindly decline, or ask
officials who generally cannot accommodation costs to an not much compa red to the
and respect... and check internally before
accept anything of value. The event, whether this is work- total value of the business
In some countries, gifts of o Do not accept gifts or accepting an offering
main rule is that we can accept related or not... done with the retirement
EUR/ GPB 50 or even more are hospitality when they may be
or offer gifts and hospitality of When a supplier invites us to visit home, this gift can and will
considered quite normal, and seen as a bribe... o Log all gifts and hospitality
EUR/GBP 50 or less, and that we their factory in another country, likely be seen as a bribe.
refusal to accept or even open For example, stay away accepted or offered in our Gifts
need authorisation for anything Nomad Foods pays for the Worse, the hospital director
the gift may be seen as impolite from gifts or hospitality just and Hospitality Log...
more. However, it really depends travel and hotel. When we invite is a government official, and
before or during any contract We always promote
on the circumstances whether a a customer, they pay for the cannot accept any gift if the
o Cash or cash equivalents, like negotiation or tendering, or to transparency and visibility of
gift or hospitality is appropriate. travel and hotel intention is to gain an unfair
tokens or vouchers, should not secure new business gifts and hospitality
Please apply these guidelines, and business advantage.
be accepted or offered as gifts...
always use common sense:
An exception is vouchers The agent is a Nomad Foods
given to consumers of retailers, business partner, and we are
although use common sense responsible for their actions as
and modesty too if we ourselves had given the
bottle of wine.
16 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Gifts & Hospitality
OUR INGREDIENTS
What to do with gifts and What to do when a gift
hospitality over EUR/ GBP 50 or hospitality cannot be Two important customers to
or exceptional situations? accepted? Nomad Foods are interested
£€ o Gifts: o Return the gift or hospitality and
in visiting the new Nomad
Foods factory as part of
kindly explain that we cannot a business trip. As the
– Direct manager must approve accept it because it is not in line customers are based in
NOMINAL VALUE VALUE OF £/€50 MEALS WHERE BOTH PERISHABLE and log reason for exception with Nomad Foods policy another country than the
BEARING THE OR LESS PARTIES ARE PRESENT in the Gifts and Hospitality Log factory, you offer to pay for
COMPANY LOGO
o Raffle the gift within their travel and lodging costs,
o Hospitality: your department also since Nomad Foods has
– Event within country: Direct
a cheap corporate rate at a
manager must approve and
?
o Donate the gift to charity, hotel near the factory. Are
log reason for exception in the
£€
explaining to the charity you allowed to do this?
Gifts and Hospitality Log that we could not accept it
because it is not in line with No. This offer could be
– Event outside country: seen as a bribe to keep our
Nomad Foods policy
Manager’s manager must customers’ business. Just as
REQUESTS FOR CHAR- MORE THAN MULTIPLE GIFTS MAY BE approve and log reason for
ITABLE NOMINAL VALUE CONSIDERED BRIBES we pay for our own travel and
CONTRIBUTIONS exception in the Gifts and lodging when we visit business
Hospitality Log partners, so must customers
of ours, even if we invite them
to visit. A local lunch or dinner
can be offered, but only if
£€ the amount remains within
reasonable limits.
INTENDED TO LAVISH / HIGH CASH OR CASH TO GOVERNMENT
INFLUENCE A BUSINESS VALUE GIFTS EQUIVALENT OFFICIALS
DECISION (GIFT CARDS)
17 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Competition & Pricing
OUR INGREDIENTS
Free enterprise and fair market competition Pricing
Nomad Foods has a leading Competition laws can be difficult to understand. There are two main As market leader, we must
At a corporate event open
position in many markets. That rules worth knowing, but please always check with Group Legal when always be mindful when we
to many companies and
brings responsibilities that we you have any questions: discuss pricing with customers
thei r custome rs, one of
take seriously. We support the or competitors. Sometimes,
our business contacts who
principle of free enterprise and our biggest business partners
2. Abuse of a works at a retailer star ts
fair market competition as a basis are also our competitors – e.g.,
dominant position talk ing about the pricing of
for conducting our business. We 1. Anti-competitive supermarkets or other retailers
thei r private label products.
follow all applicable competition agreements or practices Companies that are that carry private labels as well
market leaders may have What should you do?
laws and regulations, as they are This rule prohibits any as Nomad Foods products. In
essential to protect consumers. agreement or practice a so- called dominant our conversations with them, Do not continue with this
between two or more position It is not illegal to we are wearing ‘two hats’ – the discussion. Pricing is sensitive
Also, competition laws and companies, which has have a dominant position, hat of supplier and the hat of commercial info rmation.
regulations drive us to compete on the object or effect of but it is illegal to abuse competitor. In our discussions The retailer must set its prices
the basis of innovation, quality and preventing or restricting or that position, for example, with retailers, we will always only independently, and even an
the loyalty of consumers, rather distorting competition. If, for by setting the price of discuss the Recommended Retail info rmal discussion of prices
than just on price. All Nomad example, you agree with your products excessively Price and leave the retailer to can be illegal.
Foods employees, especially a competitor to fix prices, high or low (to get rid of decide the price at which it
those involved in Sales, Marketing, or to allocate customers or competitors). It is also wells to consumers.
Procurement or other commercial markets, the agreement will illegal to discriminate
functions, should be familiar with be prohibited and illegal. between customers
applicable competition laws, without a good reason – for
and Nomad Foods will ensure example, refusing to do
that these employees receive business with one customer
appropriate training. without good reason.
18 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Accountability in Taxes
& Supply Chain OUR INGREDIENTS
No facilitation of tax evasion Accountability in the supply chain
Some businesses seek to evade Potential signs of tax evasion could As we deal with all of our business We will enforce the Supplier Code
their responsibility to pay tax by be deviation from contractual We have bought fish from a partners openly and fairly, and of Conduct with all suppliers and,
breaking the law. As a result, it arrangements or asking for supplie r in Chile for many without discrimination, so we hold where necessary, help suppliers
is possible that our suppliers or payment to be channelled to years and our contract is our business partners accountable to implement the Code, and
customers may be engaged in a different jurisdiction. This may with a company in Chile. Our to apply the same standards, engage with them to collectively
tax evasion. Nomad Foods will not also be a sign of fraud at the contact at the supplie r asks laws and regulations throughout help improve quality, health and
facilitate this or participate in this supplier or customer. If in doubt, us to pay future invoices to the supply chain. When we safety, as well as labour conditions,
in any way, even at the cost of our before agreeing to any change, a company in Switzerland believe that business is not in our global food supply chain. In
ongoing commercial relationship speak to Group Tax. instead. What should you do? being done fairly, we discuss this case of non- compliance with the
with that supplier or retailer. This may be tax evasion. openly with them. Supplier Code of Conduct, Nomad
Do not agree to any Foods will apply the key principle
With respect to our suppliers, of “Protect, Respect and Remedy”
changes without speaking
we maintain international food in line with the United Nations
to Group Tax, who may be
health and safety standards, and Guiding Principles on Business
able to advise on how the
applicable laws and regulations and Human Rights.
commercial objectives of any
through the Nomad Foods Supplier
proposed change can be
Code of Conduct.
implemented legally.
19 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Consumers
OUR INGREDIENTS
Even in the Business-to-Business environment Quality, health and safety Open and honest
that Nomad Foods operates, we are in regular marketing and advertising
Our consumers love our brands
contact with our consumers. They love our because they represent quality. Just as our consumers should rely
brands, buy our products in stores and online, We apply high standards of on the quality of our products, they
quality, health and safety in our must also trust that what we say
and contact us with questions, complaints,
factories and sites. Similarly, we about our products is correct and
comments and suggestions about our products. make sure that these standards transparent. We will be honest and
Just as we apply high standards to ourselves apply to our products and services open in all of our marketing and
and our business partners, so we must apply wherever we market and sell them. advertising, and not make any
We are committed to providing claims – whether on quality, health
high standards whenever and wherever we our consumers with high quality or safety – that we cannot back
are in contact with our consumers – whether products, manufactured with high up. We will make sure that we
directly or indirectly. The guiding principle levels of safety and cleanliness. do this whether we deal directly
We welcome any questions or with our consumers, or through
here is the Golden Rule: Treat others as you feedback from our consumers our business partners. When our
would yourself. Because, in the end, we are on the subject of quality, consumers have any questions or
consumers ourselves. health and safety. complaints about our marketing
and advertising, we encourage
them to contact us.
20 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Privacy
OUR INGREDIENTS
Protecting personal data and privacy From one of our marketing
agencies, you receive a
When we are in contact with We will make sure that we use
database with names and
our consumers, we learn about personal data only for the purpose
contact details of consumers Under th
them – which helps us improve our that we get it for, and not any e E U Ge n
who tried our famous Fish Protectio e ral Data
products and services. But we also other. We will make sure we have a n Regula
Fingers in the past and liked it. k ind of m tion, this
get to know personal information legal basis for using personal data, a rketing
You send these consumers a will not b initiative
– starting with their names and like our consumers’ permission. e allowe
mass marketing email, asking prio r exp d withou
addresses. They also share with When we ask our consumers for licit perm t
them for feedback on a new “consen ission – o
us their buying behaviour. Or permission, they must clearly and t” – of the r
version of Fish Fingers and Being an consume
when they ask a question online, explicitly give it to us. When we use existing c r.
offering them a vouche r for a o r receiv onsumer,
or download a recipe, their IP their data, we will be transparent ing ou r re
free product of their choice. newslette gula r
or email address. We may get about why, when, where, how r, does n
sensitive information, like health- and for how long we will use an autom ot mean
Is this allowed? atic opt-
related or religious information. it. And we will not keep their ma rketin in fo r new
g o r sale
Sometimes, we even get personal personal data any longer than we s initiative
s.
information without us knowing it. need to, and delete it when our
consumers ask this.
Most of the information we get
from our consumers is personal
data, meaning it’s their data, not
ours. We just use it to help them
with the question or comment
they have, or to make sure that our
products end up in the right place.
Just as we take privacy for our
employees seriously, so we treat
our consumers’ personal data with
due care and respect.
21 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Code of
Business Principles
And Speaking Up
All of us at Nomad Foods will act in line with our Still, we live in an imperfect world. At Nomad Foods, we see incidents As an open and transparent
Code of Business Principles. In summary, that People make mistakes and and mistakes as an opportunity organisation, willing to learn and
incidents happen. With all the to learn and improve – but we improve, we care deeply about
means we will do our business with honesty,
laws and regulations governing can only do so if we know about speaking up. We will make sure
integrity and openness, with respect for human our behaviour and business, it isn’t it. That’s why speaking up is so that we follow up on all reported
rights, the environment and society, and in the always easy to know what “the important. If you see something incidents and, if necessary,
interest of our employees, our business partners right thing” is. In a global food wrong, say something. We speak discipline misconduct when it has
and our consumers. We do this because it’s the supply chain, we are dependent up when we see or hear about occurred. We will not tolerate any
on many others, who can an issue or incident, whether retaliation against an employee
right thing to do. It’s good for our people, our
also make mistakes. that’s a violation of a law or reporting an incident or giving
planet and our profit. regulation or our Code of Business feedback in good faith, and make
Principles. But we also speak sure there’s a safe environment for
up when we disagree or wish all employees to speak up.
to challenge something, at all
employee levels, within or outside
of our organisation. We learn
from feedback, and get better.
So – speak up! It doesn’t matter to
whom – a colleague, a manager,
HR, Legal, Finance. If you like,
you can speak anonymously
through our Safecall reporting
line (see page 22).
22 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
Our Helpline
Safecall is a completely independent company How does it work? How to contact SafeCall?
that operates a confidential reporting service
Nomad Foods employees can
in multiple languages. The service is available What matters is that you
report any incident or suspicion [The contact telephone numbers and website details have speak up; to whom is less
seven days a week and 24 hours a day,and of a Code of Business Principles been communicated to Nomad Foods employees] important. If you feel better
is staffed by highly skilled call handlers. Any violation to the Safecall reporting
about discussing the matter
Nomad Foods employee can contact Safecall line. Once you report, the Safecall
with a colleague or manager,
call handler will take notes and
by telephone or its website. You can do so please do so. If anonymity is
ask you questions for details.
anonymously if you like, and even if you make Safecall will send a written report
important, contact SafeCall.
a mistake and share your name, Safecall will If you already know there’s an
of the incident to the Nomad
HR, financial or legal aspect
not pass it on. Foods Compliance Committee,
involved, you may want to
consisting of the Head of Legal,
contact the app ropr iate
the Group Compliance Officer,
function. Just make sure
the Chief People Officer and
that Nomad Foods as an
the Head of Internal Audit. This
organization follows up on
Committee will follow-up on the
the repo rted matter. As long
incident and keep the reporter of
as we speak up, we lear n
the incident informed of progress
and get better.
and the result of the case, also
anonymously when required.
23 | NOVEMBER 2020 one vision, shared valuesour society our employees our business our consumers
partners
In Conclusion
The Nomad Foods Code of Business Principles contains
high-level principles, guidelines and standards for how we
conduct our business in general. It is a living document that
may be updated from time to time as needed. For that,
we welcome your input and feedback. If you have any
questions or suggestions for our Code of Business Principles,
please let us know. That is our way of working.
Be inspired by our Code and work each day in a way that
inspires others. When something does not feel right or puts
our business, colleagues or those we serve or work with at
risk, report your concerns.
For more specific, rule-based guidance, please see
our policies in the Nomad Foods Policy House. When in
doubt which policy applies or if you have any questions
regarding the policies, please contact Group Legal at:
legal@nomadfoods.com
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