3.8 Ethics and compliance

Following the introduction of the new Code of Conduct in the second-half of 2019, covering all new Ethics & Compliance (E&C) policies adopted over the last three years, the focus in 2020 was on fully embedding the new standards into business operations. Although COVID-19 has hampered physical contact with OpCos to a large extent, the E&C function managed to launch several initiatives to bring it closer to the business.

E&C launched a conflicts of interest campaign with OpCo management, followed by a conflicts of interest disclosureprocess covering all employees with system access (approximately 5,500 people). This helps raise awareness on this particular issue and remind people of their duty to disclose any (potential) conflicts to next level management so proper measures can be considered.

Together with Group Internal Audit and KPMG, E&C also performed a compliance culture assessment in 13 OpCos across Trouw Nutrition and Skretting. This soft controls survey, in which approximately 350 employees participated, provided insight into strong and weaker aspects of local compliance culture and provided tools for management teams to enhance soft controls into their organisations.

Additionally, E&C rolled-out the Nutreco Compliance Risk Management Framework to all OpCos. It reconciles E&C policies and control activities to be performed in the OpCos and reports on this to E&C. This helps the business to put E&C policy requirements into daily practice and enables E&C to see where support is required. The framework produces semi-annual reports and generates action plans for OpCos where needed.

A new Code of Conduct for Business Partners was developed, with separate supplements for suppliers of agricultural products and marine products. Translated into seven languages, it helps Nutreco engage with our business partners on sustainability, compliance and integrity issues, and we will only conduct business with companies or individuals that comply with the standards set out in this Code of Conduct. If a business partner fails to comply with the code, Nutreco may take corrective measures, including termination of the business relationship.

Our E&C e-learning programme comprises four modules: Code of Conduct, Fair Competition, Anti-Bribery & Corruption and Data Protection. In mid-2020, we moved to Workday as platform for these e-learnings. This has made completion tracking and reminding easier. At the end of the year, the overall completion rate was more than 90%.

In 2020, we dealt with a relatively high number of E&C incidents reported through our internal whistle-blower line “Speak Up”. Reasons behind this rise could include the new Code of Conduct, the new e-learnings, increased awareness of E&C, and new management starting in several parts of the organisation. The increased number of incidents were reflected in a higher number of disciplinary measures including dismissals and official warnings.

In 2020, we abolished the separate Ethics & Compliance Committees for Trouw Nutrition and Skretting and moved to one Ethics & Compliance Committee for Nutreco, of which the COOs of the divisions are now are members. This has fostered a company overview of compliance activities and has driven collaboration.

Last but not least, we strengthened the E&C function with additional resources, particularly in Amersfoort and Asia.

Code of Conduct for Business Partners

We recognise that our purpose can only be achieved with the cooperation of our business partners. Therefore, we have developed a Code of Conduct for Business Partners, which enables us to engage with our Business Partners on sustainability, compliance and integrity issues.