Anyone who feels or suspects that something isn’t right can raise a concern using the Speak Up Service. This includes employees, contractors, former employees, business partners and customers.

It is o.k. to speak up if you feel something could harm the company, a co-worker, yourself or anyone else. If such a situation occurs, it is vital that you take action. There are various ways and levels to raise your concern. Choose your way, depending on the type of concern you have and how comfortable you feel raising it. Preferably, give feedback to the person involved. Minor issues are almost always best dealt with this way. Do you believe the situation can’t be resolved this way or that you are dealing with a more severe issue? Go to your manager or the next manager higher up. You can also talk to Human Resources or Ethics & Compliance (via compliance@nutreco.com). They are there to listen and take appropriate action. Does it feel uncomfortable taking any of the actions above, or are you not an employee/contractor of Nutreco? If this is the case, then you should use the Speak Up Service. Via the Speak Up phone line or Speak Up website you can submit a report 24/7.

 

Communication

Speak Up is introduced to our employees at the start of employment, it is included in the Code of Conduct and included in the Code of Conduct training. Furthermore, there are display boards at every Nutreco location with information about Speak Up. External stakeholders are informed via the websites Nutreco.com, Trouw Nutrition.com and Skretting.com. On these websites Speak Up has a separate page and Speak Up is also mentioned on the Code of Conduct for Business Partners page. Speak Up metrics are disclosed in the annual Nutreco Sustainability report. This way we build confidence in the mechanism’s performance and its effectiveness.

 

Speak Up Procedure

If you have raised a concern using the Speak Up Service, which is hosted by external service provider NAVEX, you can expect the following next steps:

• Processing and transferring: Your report will be processed independently by a member of the NAVEX team and securely sent to the SHV Speak Up team.
• Initial review: The SHV Speak Up team is completely independent and knows how to assess your report.
• Assigning a case handler: The SHV Speak Up team ensures that your report is investigated by the best person to deal with it. Except for concerns reported against senior management of Nutreco, it will be the Director Ethics & Compliance of Nutreco who will assign the reported concern to the best positioned case handler within Nutreco for investigation. The Ethics & Compliance department will monitor to make sure that it is dealt with in a fair and timely manner.
• Investigation and actions: The case handler investigates your report and does its best to understand all the facts of what happened. The reporter and the person or persons under investigation each have the right to be heard during the investigation and can have a trusted person present at the hearing. If necessary, we will take appropriate actions, such as giving advice, improving a situation, increasing safety measures or giving an official warning.
• Feedback to the reporter: We will give you regular updates during the investigation. Within 7 days after reporting a concern we will confirm receipt. Within 4 weeks we will share information on the progress of the case handling. When the case is closed the outcome will be shared with the reporter, unless giving such feedback would be detrimental to the investigation or otherwise. And, any person under investigation will be notified, if necessary after safeguarding relevant evidence, unless such notification could jeopardise the investigation.

The staff responsible for receiving reports is trained to follow up in accordance with the aforementioned steps.

 

Anonymity

When using the Speak Up service, we appreciate it when you give your name and contact details. This makes the investigation easier. If you’re uncomfortable identifying yourself, you can report your concern anonymously. Anonymous reports are treated just as seriously. However, sometimes anonymous reports are harder to investigate because of this anonymity. For instance, if we don’t have enough information and we need to contact you for further information. We guarantee anonymity as follows:

• NAVEX makes sure your phone call is non traceable.
• NAVEX guarantees that no IP address information directs back to you.
• Speak Up reports from your computer come through a secure Internet port and do not trace or show

• NAVEX will not use information for any purpose other than providing it for Speak Up purposes.

 

Confidentiality and privacy

We will protect the confidentiality of the person who reports, unless we are legally required to disclose it. For instance, if there is a criminal, disciplinary or sanctioning investigation, we may have to reveal the identity of the person who reports to the authorities.

We will respect the privacy of everyone involved in the process. All documents relating to reported concerns must be retained and destroyed in accordance with the Speak Up Privacy Notice and applicable laws and regulations. For information about the way in which the company processes and safeguards any personal data, please consult the Speak Up Privacy Notice.

 

Non-retaliation

If anyone tries to hurt or harm you after sharing a concern, you are dealing with retaliation. This can be very subtle, and even unintentional.

We have a non-retaliation policy. Therefore, anyone raising a concern in good faith must be treated as if no report was filed. It doesn’t matter if a concern later turns out to be unfounded, mistaken or misguided.

If you believe you have faced retaliation of any kind, please report it directly to management, Human Resources, Ethics & Compliance (via compliance@nutreco.com) or through Speak Up.

 

Corrective action

We always try to ensure that outcomes and remedies accord with internationally recognized human rights, as covered in our Code of Conduct.

If we determine that there has been a breach of our values, Code of Conduct, policies, and the law, it will be considered whether there is a need for additional training and/or corrective action against the involved employee(s). This may range from sending the employee(s) a confirmation of our rules or a formal warning letter to terminating their employment and will depend upon:

• Whether the conduct was accidental or deliberate
• Whether the conduct involved a violation of the law
• Whether the conduct involved dishonesty, theft, fraud or personal gain
• Whether the conduct was repetitive or systemic
• Whether the employee cooperated fully or tried to conceal things
• The employee’s level in the organisation

• Whether the employee self-reported or not.

 

Feedback on Speak Up

Concerns about the functioning of the Speak Up service and investigation process can be reported internally via compliance@nutreco.com.

Via a periodic engagement survey we identify the level to which employees feel comfortable to speak up. The results can be found in the sustainability report.