Geanina IORDACHE Project Manager Principles and guidelines We want to strengthen responsible actions within the company and beyond, into our supply chains. We are guided by a set of values that we embody in our sustainable business practices. The most important documents that help us implement sustainability in our governance and management system are: z Human resources policies and guidelines based on the UN Universal Declaration of Human Rights and International Labor Organization (ILO) conventions • forced labor, exploitation of minors, any form of physical abuse or violent threat, sexual, physical or psychological harassment, discrimination in respect of work and profession on the grounds of sex, color, religion, ethnic origin, age, nationality, marital status, sexual orientation, disability, social origin or political opinion are strictly prohibited z Compliance policy z Code of Conduct (adapted at PENNY Romania level according to the REWE Group Code of Conduct) and the related compliance system z Specific policies based on the principles of ethics and integrity z Rules related to internal procedures z Collective labor agreement z Working procedures such as: • Antitrust policy implementation procedure • Procedure for implementing compliance, anti-corruption and anti-fraud policy, including conflict of interest practices • Money laundering and terrorist financing risk management procedure • Risk Assessment Procedure Ethics and Integrity The Code of Conduct represents our internal policy and an external statement of values, principles and expected behaviors. The Code applies to all PENNY employees and is aligned with the REWE Group Code of Conduct, which is regularly reviewed and updated. The Code covers expectations on topics such as ethical decision-making, conflicts of interest, insider trading, sustainability and other fundamental ethics and compliance topics. It also includes examples of how PENNY employees can put integrity into action, outlines our no-retaliation policy, and outlines the consequences of non-compliance with the Code. To complement and supplement the Code of Conduct, we maintain and regularly update the Ethics and Compliance e-learning which is mandatory to be covered annually by all company employees. All relevant group policies applicable to PENNY Romania are accessible to all employees in an interactive IT tool. They are informed of all changes and innovations to the relevant group directives through various communication methods, such as the company intranet. Information on policies is communicated during recruitment through the collective employment contract, internal rules and job descriptions. The PENNY Supplier Standards set out our fundamental expectations of our suppliers on issues such as food and product safety, consumer protection, trade laws compliance, conflicts of interest and fair competition legislation. The scope of the standards applies to all suppliers who sell their products to us for resale or for our own use and provides suppliers with examples of best practices in action. All these standards are part of the tender specifications and subsequently included in contracts. Suppliers are expected to cascade the requirements described in our Standards for suppliers throughout their supply chain – including suppliers of raw materials, components or ingredients, as well as subcontractors and agents. We expect our suppliers and service providers and other business partners to act with integrity and honor our values. SUSTAINABILITY REPORT PENNY ROMANIA 2022 56/250 SUSTAINABILITY STRATEGY ABOUT US AND OUR VALUE CHAIN THE FUTURE IS MADE TODAY SUSTAINABILITY HIGHLIGHTS MESSAGE FROM THE GENERAL DIRECTORS CONTENTS SUSTAINABILITY STEP BY STEP
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