8.4 Ethics and compliance

In 2021, the focus was on bringing our Ethics and Compliance (E&C) function closer to the business by fully embedding our compliance standards into business operations. Although COVID-19 continued to hamper physical contact with our businesses, the E&C function managed to organise a significant number of training and awareness sessions. 

The team finalised our conflicts of interest disclosure process, covering all employees with system access (approximately 5,500 people). This helped raise awareness about the issue and reminded people of their duty to disclose any (potential) conflicts to the next level management in order that proper measures can be considered and taken. 

Following their introduction in 2020, Compliance Culture Assessments were completed across Nutreco. This soft controls survey provided insights into the strong and weaker aspects of the local compliance culture and provided tools for management teams to enhance soft controls within their organisations. In the first quarter of 2022, Nutreco Asia will hold their survey, after which the entire organisation will be covered. 

Surveys were discussed with management, after which management responses and action plans were drafted. 

We have performed or validated compliance risk assessments on anti-bribery and corruption and on competition law compliance. These serve to map developments in the company’s risk profile on these topics and put in specific activities to mitigate risk.

The Nutreco Compliance Risk Management Framework, implemented in all our businesses, reconciles E&C policies and provides control activities to be performed. It helps the business put E&C policy requirements into daily practice and enables E&C to see where support is required. Our teams use the framework to produce semi- annual reports and generate action plans for our businesses where needed.

Our E&C e-learning programme comprises four modules: Code of Conduct, Fair Competition, Anti-Bribery & Corruption and Data Protection. Our overall completion rate by employees across Nutreco was over 95%.

We also launched the Speak Up culture campaign, designed by our parent company SHV. Key messages included:

  • Speak Up is part of our culture.
  • Speak Up is about speaking and listening.
  • Speak Up is a set of tools that supports a healthy Speak Up culture.
  • Integrity is a key value and Speak Up is a way to turn this value into action.

The campaign featured training materials, presentations and posters, provided in 33 languages.

In 2021, 66 reports were made through our internal whistle-blower line. The majority of cases related to workplace respect, unprofessional behaviour and intimidation. Cases were handled with due speed; at the end of the year, seven cases were open.

Local Compliance Champions (LCCs) are the first point of contact for compliance matters at all of our businesses. In 2021, we bolstered the LLC network with training, a webinar and regular newsletters.

The success of our efforts to raise awareness of our E&C programme among employees was reflected in the results of our employee engagement survey, held in September. It included three E&C-related statements, which were rated by respondents on a scale of one to 10:

• I understand Nutreco's standards of business conduct and ethics > score 8.7.

• I never feel pressured to compromise Nutreco's Code of Conduct or policies to achieve business goals > score 8.4.

• If I observed misconduct, I would feel comfortable to report it or raise a question > score 8.2.

The total number of participants was 8,000. With an overall score of 8.0 (out of a maximum 10), the results for E&C were favourable and slightly higher than two years ago.

In 2021, the Nutreco Ethics and Compliance Committee met five times.

The E&C function was strengthened with additional resources in Latin America.

Chapters:

8.1 Nutreco Exploration
8.2 Occupational health and safe work
8.3 Quality assurance
8.4 Ethics and compliance
8.5 Government Relations
8.6 Taxes