7. Ethics and compliance

The Russian invasion of Ukraine in February 2022 caused a great deal of disruption across Europe and marked the start of an eventful year for Nutreco's Ethics & Compliance (E&C) function in 2022. In addition to caring for our Ukrainian colleagues and their families, we were required to manage our response to the sanctions increasingly imposed on Russia by the EU, the U.S., and several other countries, which had a direct impact on our Russian operations. As trade sanctions compliance is part of the E&C activities, it required intensive efforts by our team to comply with these measures. During the second quarter of 2022, we decided to divest our Russian business through a management buyout.

In 2022, we also continued to embed our compliance standards more fully into our business operations. Under Nutreco's new strategy, launched in late 2021, the company's business units (BUs), which are organised geography or by products, have become its main organisational units, fully mandated to and accountable for taking care of all aspects of their businesses, including E&C. We adapted Nutreco's overall E&C activities to the new strategy by reinforcing business unit management’s accountability for E&C. This led to a renewed reporting and monitoring process stretching from OpCo level to BU level to the Trouw Nutrition and Skretting Business Line COOs and finally the Ethics and Compliance Committee. Building on the new strategy and the BU’s enhanced responsibility for E&C, we streamlined Nutreco's control environment, removing three E&C controls at OpCo level and introducing one new control at BU level.

During the year, we conducted a soft controls survey within Nutreco Asia, covering six OpCos and the overall business unit. This survey gave us insight into the strengths and weaknesses of the local compliance culture and provided tools for management teams to enhance soft controls within their organisations. We discussed these reports with the management teams and identified follow- up actions.

We revamped our Code of Conduct and the related e-learning programme in Nutreco's new branding (introduced in 2021), adding a new introduction by our CEO and an additional section on Health, Safety and Environment. We relaunched the Code of Conduct and the e-learning course to all employees who had participated in the previous e-learning more than 24 months prior.

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

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 took a deeper dive into awareness and knowledge of Conflicts of Interest (COI) during the year by interviewing approximately 100 randomly selected employees across the globe. No major deficiencies were found. Going forward, managers will be given insight into the COI disclosures made within their teams and COI disclosure will become part of the onboarding process.

We also performed a risk assessment on trade association memberships worldwide. While no major risks were found, we will create a central register of trade associations to better structure training and monitoring.

Our teams developed 2023 E&C annual plans at OpCo, BU and Nutreco level. In addition to reinforcing the BU management’s accountability for E&C, these plans focus on improving the effectiveness of our E&C activities.

In 2022, 43 reports were made through our whistle-blower line, Speak Up. As in previous years, the vast majority concerned HR, diversity and workplace respect. The average number of handling days was 73. About 50% of the reports made were found to be (partly) substantiated.

Chapters:

1. About Nutreco
2. Our Roadmap
3. Pillar one: Health & welfare
4. Pillar two: Climate and circularity
5. Pillar three: Good citizenship
6. Sharing dilemmas
7. Ethics and compliance
8. Innovation: A sustainability keydriver
9. About this report