Principles and guidelines We structure the governance of our business according to a series of guidelines that allow us to develop our activity both in terms of business expansion, but also in a responsible way towards the environment, society, and the economy in general. Below the most important documentation that underpins our governance system are: z Policies and guidelines on human resources, based on the Universal Declaration of Human Rights proclaimed by the UN and the conventions of the International Labor Organization (ILO) • Forced labor, exploitation of minors, any form of physical abuse or violent threat, sexual and moral, physical or psychological harassment, as defined by the normative acts in force, discrimination in terms of activity and profession on grounds such as gender, skin color, religion, ethnic origin, age, nationality, marital status, sexual orientation, disability, social origin or political opinions are strictly prohibited z Compliance Policy z Code of Conduct for employees (adapted at the level of PENNY Romania according to the REWE Group Code of Conduct) and the related compliance system z Code of Conduct for suppliers (adapted at the level of PENNY Romania according to the REWE Group Code of Conduct) for creating the preconditions for the implementation of the highest standards of business ethics in the supply chain z Specific policies, which are based on the principles of ethics and integrity z Rules of Procedure z Collective Bargaining Agreement z Work procedures such as: • Procedure for implementing the antitrust policy • Procedure for implementing the compliance, anti-corruption, and anti-fraud policy, including practices related to conflict of interest • Procedure for the management of money laundering and terrorist financing risks • Risk Assessment procedure • Guide on preventing and combating gender-based harassment and psychological harassment at work Ethics and Integrity The Code of Conduct is our main document that summarizes the values, principles and behaviors expected from stakeholders. 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 ethical and compliance topics. It also includes examples of how PENNY employees can put integrity into action, outlines our non-refoulement policy, and outlines the consequences of non-compliance with the Code. We have a series of measures to ensure compliance with the Code of Conduct, which include both proactive measures such as a specific training program on different topics related to ethics and integrity, customized for different structures. More information is available in the 'Risk management' section of this report. At the same time, all our employees have access to our company's policies, regulations, and procedures, either through the intranet or through an interactive IT tool made available at Group level. Information on the policies is communicated at the time of employment through the collective bargaining agreement, the internal regulations, and the job description. At the same time, we follow the implementation of our values in our supply chain, through the implementation of PENNY standards for suppliers. These standards set out the fundamental expectations of our suppliers on topics such as food and product safety, consumer protection, compliance with trade laws, conflicts of interest and fair competition. The scope of the standards applies to all suppliers who sell their products to us for resale or for their own use and they provide suppliers with examples of best practice SUSTAINABILITY STEP BY STEP CORPORATE GOVERNANCE AND BUSINESS SUSTAINABLE ASSORTMENT ENERGY, CLIMATE AND RESOURCES EMPLOYEES AND SOCIETY GRI & SASB INDEX ASSURANCE OF SELECTED NON-FINANCIAL INDICATORS
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