Code of conduct

The core values of TOP The Onion Group are:

• Taking good care of our employees, acting loyally towards our competitors, promoting ethically responsible business relationships, and treating the environment with respect;
• As an international company with suppliers and representatives all over the world, we recognize our obligation to act in a responsible and ethical manner;
• For this reason, we want to ensure that the parties with whom we do business, and in particular our suppliers and representatives, also respect our values and rules;
• Our suppliers and representatives must therefore endorse the principles set out below, act in accordance with these principles, adapt to these principles, and endeavor to develop their relationships within their own logistics chain in such a way that they are in line with these principles. They must comply with national laws and regulations and the principles set out below as a minimum.

Free choice of work

There is no forced, compulsory, or involuntary work. Employees are not required to pay an advance to the employer or to hand over their identity documents for safekeeping. Employees have the right to terminate their employment, subject to a statutory notice period.

Safety and hygiene are decisive factors in working conditions

Employees must be able to work in a safe and healthy environment, taking into account the knowledge available within the industry and the specific risks. Appropriate measures must be taken to prevent accidents and work-related health problems, minimizing as much as possible the causes of risks inherent in the working environment.

Employees must receive regular training in health and safety. All new employees must receive immediate training in this area, as must employees who are assigned to a different position. Access to clean sanitary facilities, drinking water, and, where applicable, food storage facilities must be guaranteed. If accommodation is provided, it must be clean and safe and meet the basic needs of employees.

Within the company, responsibility for all health and safety issues is delegated to a representative of senior management.

The use of child labor is prohibited

The Universal Declaration of Human Rights and the children’s rights established by the United Nations Assembly are observed, as are the conventions of the International Labor Organization, of which the Netherlands is a member and whose subjects are incorporated into the SA*8000 standard (Social Accountability).

The use of child labor (children under the age of 15) is not tolerated under any circumstances. Children and young people between the ages of 15 and 18 who are officially allowed to work are not permitted to work at night or in hazardous conditions.

The rules and procedures must be in line with the current recommendations of the International Labor Organization (ILO).

Payment of appropriate salaries

The salaries and emoluments paid for a normal working week or month must be at least within the range between national minimum wage legislation and customary salary standards within the industry.

All employees must be provided with clear written information about the applicable collective labor and salary conditions; a pay slip for the relevant period must also be provided with each salary payment. Deductions from salary in connection with disciplinary measures, or deductions that are not required by law, may not be made without the express consent of the employee concerned. Disciplinary measures must always be recorded in writing.

Working hours must comply with applicable regulations

Working hours must fall within the range specified by national legislation and customary reference standards within the industry.

Discrimination in any form is not permitted

With regard to employment, remuneration, access to training, promotion, dismissal, or retirement, there must never be any discrimination on the basis of race, caste, nationality, religion, age, disability, gender, marital status, sexual orientation, union membership, or political preference.

Unrestricted competition

The legislation on unrestricted competition that applies to every activity must be complied with. This legislation ensures that companies compete with each other in a predominantly fair manner and adhere to the principles according to which agreements are entered into freely and fairly.

All employment must be regular

All work must be performed on the basis of employment relationships that comply with national legislation and customary practice.

The employer’s obligations towards employees under labor or social security legislation and regulations, including, but not limited to, the Foreign Nationals Employment Act, may not be set aside, circumvented, or avoided by hiring workers, outsourcing, home-based work, or apprenticeship programs that are not specifically intended to transfer skills or that do not offer prospects for permanent employment. Nor may those obligations be circumvented by excessive use of temporary employment contracts.

It is prohibited to work without complying with the applicable tax and social security contribution obligations.

Humiliating or inhumane treatment is prohibited

Any form of (threat of) physical, psychological, or verbal violence, unwanted (sexual or non-sexual) intimacy, and/or any other form of intimidation or abuse is prohibited and will not be tolerated.

Confidentiality

All information exchanged in the context of business relationships must be treated as confidential. This information may not be shared with third parties/outsiders or otherwise made public. This information may not be used for illegal purposes or personal gain.

Violation of TOP The Onion Group’s trade secrets is prohibited. Incorrect information must never be provided during business negotiations.

Influence peddling or corruption will not be tolerated

Offering, paying, requesting, or accepting bribes, including flexible payment terms, is considered corruption and is strictly prohibited.

Bribes are defined as any form of gift or present, favor, reward, service, or benefit offered or requested directly or indirectly to a person with the aim of:

• Obtaining or retaining a business or personal advantage; and/or
• Inducing that person to engage in certain conduct or to reward them for doing so;

Provided that it would be improper or contrary to any duty for the beneficiary to accept such an advantage.

Corruption also includes offering bribes through an intermediary (e.g., an agent, representative, intermediary, etc.).

Some non-exhaustive examples of bribes:

• Excessive meals, gifts, entertainment, or travel, particularly if these are disproportionate, frequent, or granted during business negotiations;
• The use—without compensation—of the company’s services, facilities, or assets;
• Payments in kind;
• Loans, loan guarantees, or other forms of credit.
• The provision of benefits, such as a scholarship or medical care, to a family member, friend, or acquaintance of a (potential) customer or a government or public official.
• Awarding a supply contract to a person who has ties to the party responsible for awarding the main contract;
• Involving a local company owned by the family of a (potential) customer or by a government or public official.

Facilitation payments are small payments or expenses that are directly or indirectly requested by government officials to expedite or improve existing administrative procedures (e.g., to obtain a visa or customs approval). Such payments are strictly prohibited. In the event that the safety or freedom of an employee or external service provider of Top Taste Holding B.V. is at risk, the payment should not be refused. In all cases, a request for payment of a facilitation payment must be reported immediately to the responsible person/department.

Suppliers, representatives, and their employees must comply with all laws and regulations regarding bribery and corruption. If the aforementioned legislation does not apply, or if it is less strict than the UK Bribery Act – US Foreign Corrupt Practices Act, suppliers, representatives, and their employees must comply with the latter legislation and ensure that they keep proper records demonstrating this compliance. Suppliers and representatives must establish internal procedures to combat influence peddling and corruption in order to prevent their employees and other parties involved in their business from committing such violations. Suppliers and their representatives shall establish such procedures in the context of their business relationships. They shall also review these procedures regularly to ensure their effectiveness.

Audits and termination of agreements

TOP The Onion Group reserves the right to check whether the supplier or its representative complies with the provisions of this Code. To the extent reasonably necessary, the supplier or its representative shall give Top Taste Holding B.V. access to the documents, data, information, and records of the supplier or its representative.

If the reports and audits of the supplier or its representative mention shortcomings in any of the areas concerned, the supplier or its representative must ensure that a program is implemented within a short period of time to bring the product or service in question into line with the requirements.

If TOP The Onion Group is aware of actions or circumstances that are not in accordance with this Code, TOP The Onion Group reserves the right to demand that these matters be corrected. TOP The Onion Group also reserves the right to terminate an agreement if the supplier or representative in question does not comply with the provisions of this Code.

Termination of the agreement does not affect any obligations to provide documents, data, or information.

Proper administration

Every employee, manager, and director of TOP The Onion Group, and any third party engaged by TOP The Onion Group, for example as an agent or representative, is obliged to comply with the applicable laws and regulations that require TOP The Onion Group to maintain proper administration, to use an adequate internal control system, and to report material information that is required to be disclosed under applicable law adequately internally.

No one is permitted to enter incorrect, misleading, or otherwise irregular transactions or data in the books of TOP The Onion Group. Nor will any relationships be entered into that could lead (directly or indirectly) to incorrect, misleading, or otherwise irregular entries in the books. Examples of this include arrangements involving (cash or non-cash) bribery payments, hidden bank accounts (whether or not belonging to third parties) and/or bank accounts with incorrect or concealed names.

Every employee, manager, and director of TOP The Onion Group, as well as any third party engaged by TOP The Onion Group, for example as an agent or representative, shall report any complaints or concerns regarding accounting, administration, reporting, or other doubts in this area to the responsible person/department as soon as possible.

Prevention of money laundering and terrorist financing

Every employee, manager, and director of TOP The Onion Group, as well as every third party engaged by TOP The Onion Group, for example as an agent or representative, shall refrain from any activity that could in any way be related to money laundering and/or terrorist financing.

No employee, manager, or director of TOP The Onion Group, nor any third party engaged by TOP The Onion Group, for example as an agent or representative, is permitted to conceal or disguise the true nature, origin, location, disposal, or movement of an object, including, explicitly, money (whether cash or not), which they know or reasonably suspect to be the proceeds of crime.

Nor may the identity of the rightful owner of the object in question or the person in possession of it be concealed. Such objects may also not be acquired, held, transferred, converted, or used. Every employee, manager, and director of Top Taste Holding B.V., and every third party engaged by TOP The Onion Group, for example as an agent or representative, who knows or reasonably suspects that an object, explicitly including money (whether cash or not), is derived from a crime, must report this as soon as possible to the responsible person/department.

Reporting system

TOP The Onion Group takes its responsibility seriously to enable stakeholders in its value chain, both within and outside its organization, to voice their opinions on matters they consider important. That is why TOP The Onion Group has set up a whistleblower portal where information, complaints, and questions can be submitted in a confidential and anonymous environment so that these issues can be dealt with.

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