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Our Code of Conduct Made of us.
Our Code of Conduct
Made of us.
with our people.
CARED E L I C I O U S I SD E L I C I O U S I S
RESPECT
PASSIOND E L I C I O U S I S
Contents
Contents
We love food — Our Vision, and Values
A focus on quality and consumers — Our Plate to Pasture strategy
Our Responsibilities
Chief Executive Message
What are our policies
In Summary
How we ‘do what’s right’
Administration of the code
What matters to us• Our People – with a focus on
diversity and inclusion• Safety and Wellbeing – ORA – a real
commitment to caring for our people• Our Customers – critical to our future• Our Farmers, Sustainability and the
Environment – working together tocreate a sustainable chain of care
• Animal Welfare – our customers andconsumers expect it
• Food Quality and Safety – a core partof delivering world-class products
• Plant and Equipment – taking careof our tools of work
Other Expectations• Using social media wisely• Being sensible when you
are travelling• Being prepared for a crisis,
an emergency or any business disruption
• Using sponsorship, grantsand donations that alignwith our purpose and values
• Only accepting gifts when itmakes sense to do so
• Avoiding any conflicts of interest• Working with our competitors• Respecting confidentiality –
covers not only us as a businessbut also our farmers and suppliers
• Always being on the lookout forinstances of bribery and corruption
• Knowing how to manage insidertrading risks
• Being careful with our money andany threat of anti-money laundering
What is this all about?
Raising a concern — Speaking up
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Section 03Silver Fern FarmsCode Of Conduct02 Contents
Hello
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Kia Ora
Silver Fern Farms 05Code Of Conduct04 Chief Executive Message
Much thought has gone into this document and I would encourage you all to consider it carefully, discuss it with your colleagues and managers, and thoroughly understand the expectations we have for each other.
I am proud to be part of Silver Fern Farms and am committed to the values which underpin who we are - expertise, performance, innovation, collaboration and integrity. Doing business with integrity goes beyond policies, procedures and regulations; it’s about a culture that, at its core, ensures we do the right thing. We should all choose to live by our Code of Conduct - not because we feel obliged to but because we believe that it’s the right thing to do.
For me, the Silver Fern Farms brand not only represents the quality of our products but, most importantly, also the quality of our people and how we conduct ourselves.
Ngā mihi,
Simon Limmer Chief Executive
Silver Fern Farms strives to be the most successful and sustainable grass-fed red meat company in the world. Our business is a cornerstone of the New Zealand economy, directly contributing to the lives of up to 7,000 employees and 16,000 local farmers, delivering our products to consumers in over 60 countries around the globe.
This is quite a responsibility. The way in which we conduct ourselves impacts the interests of our customers, shareholders, suppliers, colleagues, communities and the environment.
Every day, we are all faced with challenging decisions as we go about our work at Silver Fern Farms. For the most part these are straightforward choices and we are able to act confidently and quickly; however, every so often we are confronted by situations where we have to make tougher judgements to ensure that we ‘do the right thing’.
We are all interacting with a diverse range of people, from varied backgrounds, cultures and experiences, and with different expectations. We should seek to understand and act with empathy, apply strong principles of respect and fairness, and keep to our word.
By adopting this Code of Conduct, we are publishing a set of expectations for both ourselves and others to measure our actions against.
Silver Fern Farms 07Code Of Conduct06 Chief Executive Message
What’s this all about?
We need all Silver Fern Farms’ people to read, understand and use this Code of Conduct as they make decisions every day.
It applies to all Silver Fern Farms’ employees across New Zealand and the world – including our executives, full-time employees, seasonal employees, contract workers, and directors.
We acknowledge that in the pursuit of our business objectives, our people will have choices to make. Our Code of Conduct (the Code) is a cornerstone of the expected behaviour and company culture at Silver Fern Farms.
Like most things in life, working for Silver Fern Farms is a choice. If you choose to be a part of our company, we expect you to take personal responsibility for ensuring that you conduct yourselves with integrity and respect and act in our best interests and in following the law. This Code provides reference information that you need to know when making choices. It sets out what we expect from every person working for and with us, regardless of location, and confirms our commitments to our people, customers, business partners and everyone we interact with in our work.
However, the Code cannot address every situation and neither can it provide a substitute for you and your managers taking responsibility, or for exercising good judgement and seeking help when unsure.
This is not a ‘nice to have’ document – it is essential. We need all Passionate Food People to read, understand and live by this Code.
Code Of Conduct Silver Fern Farms08 09What’s this all about?
Our Vision:
To become the world’s most successful and sustainable grass-fed red meat company.
Our Values:
Collaboration
IntegrityExpertise Performance
We are individually accountable and
collectively responsible
We do the right thing by our people, shareholders,
suppliers, customers, communities and the
environment.
At our heart we are food people, making it well, taking care of it from
plate to pasture.
We must sustainably grow our profitability in order to
invest in our business.
Innovation
We have big ideas, take action and get it done.
Code Of Conduct Silver Fern Farms10 11We love food — Our Vision, and Values
A focus on quality and consumers — Our Plate to Pasture strategyWe have big ideas, take action and get it done.
Our vision, purpose and values define who we are. Our strategies tell us what we need to do to get there. We have set a clear market-led strategy based on the concept of ‘plate to pasture’ – where consumer needs drive how we do things. All our actions will, therefore, be focused on the five elements, which start with our Consumers who are supplied through Supermarkets and Foodservice, who rely on our Processing to produce products which in turn need the right Livestock raised on New Zealand’s outstanding Pasture.
To achieve our vision and purpose, we need to become a ‘plate-to-pasture market-led organisation’, with an integrated supply base and best-in-class operations which are well supported by functional experts in people, systems and processes.
Our strategy depends on Quality and Food Safety, where we focus on ‘production done safely to a high standard’, and on our Consumers, where our number one priority is meeting our customers’ expectations.
Code Of Conduct Silver Fern Farms12 13A focus on quality and consumers
We love food.
Silver Fern Farms 15Code Of Conduct14
Our diverse multicultural workforce is one of our strengths as we welcome people into our whanau from all backgrounds. Silver Fern Farms recognises Te Tiriti o Waitangi (The Treaty of Waitangi), and the foundation principles of partnership, participation and protection. Silver Fern Farms complies with all New Zealand employment and human rights related legislation.
Silver Fern Farms 17Code Of Conduct16
How we do what’s right
A guide to making business decisions at Silver Fern Farms.
We want everybody at Silver Fern Farms to take actions and make decisions that will make us successful. We want people to aim high and achieve exceptional results, and we encourage everyone to find ways to keep us positively in the front of mind for our consumers. However, we also want to accomplish these things in a way that is honest, ethical and straightforward.
To help you do this, you should ask yourself:
• Am I acting within the law, no matter where I work?
• Am I acting by our values and policies?• After using common sense and
good judgement, does it feel right?• Am I comfortable with my name
being associated with this decision?• Could I explain my actions to family,
friends or colleagues?• How would I like it if someone
treated me this way?• What would happen if everybody
took this course of action?• Would my manager and the
company be comfortable should it appear in the media?
The most important question of all is “is this the right thing to do?”
If it doesn’t feel right, stop and seek guidance from someone you trust before you do it, or don’t do it.
We are a highly capable business that cares for our people and supports them
to be successful and adaptable to change.
This requires a highly collaborative and engaged team.
Code Of Conduct Silver Fern Farms18 19How we do what’s right
What are our policies?
We have adopted policies that govern business conduct and how we all must conduct ourselves in pursuit of our objectives. Our policies exist to guide and protect us.
Food Quality and Safety, and the Environment
• Quality Policy• Laboratory Quality Policy• Sustainability Policy• Environment Policy• Farm Assurance Policy• Animal Welfare Policy
People, Health and Safety
• Ora Health and Safety Policy• Fitness for Work (Alcohol and
Drug) Policy• Rehabilitation Policy• Harassment and Bullying Prevention Policy• Long Term Illness Policy• Ethics Policy • Leave Policy• Travel Policy• Safe Driving and Motor
Vehicle Policies
These include, but are not limited to, the following:
Commercial Conduct
• Competition Policy• Credit Risk Policy• Security Trading Policy• Sales Policy• Procurement and Purchasing Policy• Livestock Procurement Policy• Hospitality and Gifts Policy• Delegated Authority Policy• Fraud and Whistleblower
Protection Policy• Asset Management Policy• Repairs and Maintenance Policy
Information Technology (IT) and Equipment
• IT Acceptable Use Policy• Systems Owner Policy• System Security Policy• Mobile Phone Policy• Information Security Policy• Information Retention Policy• Information Classification Policy
Communications
• Electronic Media Policy• Media Policy
Please take the time to review the full list of our policies which
are available on the staff intranet. It is the responsibility of every employee, director, consultant and contractor to ensure they are familiar with the policies relevant to their role. It is a
condition of working for us in any capacity that Silver Fern
Farms’ policies govern acceptable behaviour.
Code Of Conduct Silver Fern Farms20 21What are our policies?
Code Of Conduct Silver Fern Farms22 23
Our Responsibilities
We are individually accountable and collectively responsible.
Our values and policies should guide every decision that you might make.
As Passionate Food People, we are all expected to ‘do what’s right’ in our daily work and actions, so we expect you to:
• Look after yourself and others by living our ORA philosophy: Mates Keep Mates Safe
• Always act in a way that you and Silver Fern Farms would be happy to explain
• Comply with the principles and requirements set out in this Code and all the policies
• Seek to act with the highest level of honesty and care as you carry out the responsibilities of your role
• If you relate to external stakeholders, always comply with our Competition Policy
• Always consider: “The standard we walk past is the standard we set” and hold our customers’ needs close
• Speak up if you see any unsafe or unethical behaviour if it breaches our Code
• Act at all times in a way that promotes and protects our business, reputation and relationships
• As required by your employment agreement, comply with reasonable requests and directions
Our leaders have additional responsibilities under the Code:
• Uphold the Code consistently for all your employees and lead the necessary standards from the front
• Where there is a conflict between our values and business objectives, our values must always come first
• Champion business conduct, risk management and ethics compliance activities
• Make sure appropriate controls are in place within your team
• Never overlook a business conduct or ethical problem; address the matter immediately and seek guidance if necessary
• Encourage your team members to ask questions and speak up
• Deal with concerns when they are raised and, most importantly, make sure that no one who speaks up is treated unfairly as a result.
Code Of Conduct Silver Fern Farms24 25Our Responsibilities
What matters to us
We believe taking care of our People and the environment we’re in will ensure the long term value of our business.
The issues detailed in this section form the critical part of the Code, which we all need to understand.
The most important issues for us are simple; they are:
— Our People— Safety and Wellbeing— Our Customers— Our Farmer Partners — Sustainability and the
Environment — Animal Welfare— Food Quality and Safety — Plant and Equipment
Silver Fern Farms 27Code Of Conduct26 What matters to us
Our People — with a focus on diversity and inclusion
Outline:The vision of our People strategy is to be a highly capable business that cares for our people and supports them to be successful and adaptable to change. This requires a highly collaborative and engaged team where our success depends on you. This means it’s essential that we can attract and retain skilled and highly capable employees. We will always hire the best person for the role. We recognise that building a diverse and inclusive workplace culture will result in enhanced relationships with stakeholders, better customer relationships, improved financial performance and a stronger corporate reputation.
We believe that every individual has the right to be treated with human dignity and respect. We encourage diversity and appreciate the part that each person has to play. Together we aim to create a culture that is high-performing, yet fun, and where each person feels valued. We are dedicated to creating and maintaining an inclusive environment where all of our employees are encouraged to reach their full potential, and individual differences are valued and respected. We are all individuals working together as a team towards achieving the same goals, so mutual trust, confidence and a willingness to help each other are crucial.
Some of the policies to consider• Harassment and Bullying Policy• Long-term Illness Policy• Ethics Policy • Leave Policy• Travel Policy
Ask yourself• Is my behaviour making someone
uncomfortable?• Are my actions for the good of the
company or only for myself?• Do I let discrimination, harassment or
bullying happen in my workplace?• Do I collaborate and work together to
achieve superior outcomes?• Do I make sure that everyone is
treated fairly, with respect and dignity, and without discrimination?
• Do I actively and openly celebrate diversity so people can be their whole self at work?
• Do I ensure employment, development opportunities and promotion are offered and provided on merit?
Spotlight on: Bullying and harassment
We do not tolerate any form of harassment (verbal, sexual or physical), bullying or victimisation, either directly (face to face) or indirectly. Indirect activity may include email,
text messaging/SMS, social media, or exposing colleagues to offensive and/or unauthorised images or content
intentionally or unintentionally.
If you are concerned about any sort of harassment, bullying or victimisation, or you think a colleague
is subject to this behaviour, please refer to the ‘Raising a Concern - Speak Up’ section.
Silver Fern Farms 29Code Of Conduct28 What matters to us
Safety and Wellbeing – ORA Mates Keep Mates Safe – a real commitment to caring for our people
Outline:Safety is as much of a priority as production or quality. We are committed to the safety and wellbeing of our people. Our ORA health and safety (H&S) management systems are used to evaluate and improve our workplace safety performance. We expect everyone at Silver Fern Farms to behave in a safe and responsible manner at all times.
The wellbeing of our people is important to us also. We are committed to supporting workers to perform to the best of their abilities without lasting impact to mind or body. We understand that wellbeing is often a personal situation but want to encourage workers to “Be Well” and take up opportunities through health and wellbeing initiatives in the workplace to better support our connectedness, family, body and mind.
If you feel you need support to be and feel your best an independent employee assistance programme is available to all employees. We use an independent workplace support provider to enable our people to address work and personal matters in a confidential manner. You can contact Workplace Support confidentially on 0800 333 200.
Some of the policies to consider:• Ora Health and Safety Policy• Fitness for Work Policy• Safe Driving Policy• Rehabilitation Policy
Ask yourself:• Can I make a process even safer than
it currently is?• If my CEO or H&S Manager saw me
doing this, would they disapprove?• Am I demonstrating visible H&S
leadership by speaking up when something might be unsafe?
• Am I fully responsible for my safety and wellbeing, and the safety of my colleagues, visitors and our customers? (Mates keep mates safe.)
• Would I walk past something substandard and not fix it/raise my concern? (The standard we walk past is the standard we set.)
• Am I fit for work and free from impairment?
• Do I proactively identify and report any hazards/risks?
• Do I lead by example, especially when driving a company car?
• Do I report in confidence any concerns I have about the use of alcohol or other drugs?
• Do I follow reasonable instructions which are for my own or others’ safety?
• If I see a workmate’s wellbeing has changed, would I ask, “Are you OK?”
Spotlight on: Drugs, Alcohol and other impairment
Given the nature of the work we do, we must be strict about the use of drugs and alcohol. We will not tolerate anyone being
affected by alcohol or other drugs in the workplace.
You must be fit for the work you are doing. This includes coming to work free from impairment, both from legal and illegal substances. Any possession, use, sale or distribution of illicit substances at work
will be treated very seriously.
Remember: never, under any circumstances, carry out any work while affected by alcohol or any other drugs or medications
that impair judgement, performance or behaviour. Never drive a vehicle used for business purposes if you are impaired by alcohol,
drugs or medications. Finally, you may be required to undergo alcohol and other drug testing at safety-sensitive sites and where there is cause. Please read our policy on fitness for
work if you are unclear about this.
Silver Fern Farms 31What matters to us30 Code Of Conduct
Our Customers — critical to our future
Outline:We believe that Silver Fern Farms can be a trusted partner to our customers globally and earn the status of industry leader by consistently delivering a great product.
We are committed to knowing our customers and understanding their requirements across the globe. We treat our customers with respect and dignity, we deliver value and friendly, positive customer service, and we meet all international business standards.
Some of the policies to consider• Sales Policy• Competition Policy
Ask yourself• What impact might this have on
Silver Fern Farms reputation locally and globally?
• How would I feel if I were in the customer’s shoes?
• Are my actions likely to result in a loss of repeat business?
• Can my actions be viewed as ‘playing dirty’?
• Could my actions be construed as collusion?
Silver Fern Farms 33Code Of Conduct32 What matters to us
Our Farmers, Sustainability and the Environment – working together to create a sustainable chain of care.
Outline:We believe that Silver Fern Farms, in partnership with our Farmer suppliers, can create positive change for our environment, our people and the economic success of New Zealand. We will protect and safeguard the natural environment, minimising our use of finite resources and the release of harmful emissions to the environment.
We comply with all environmental laws and our own strict requirements, and continuously improve our performance through waste minimisation and efficient resource use across our supply chain and with our farmers.
We believe that natural resources are precious, and to be successful, our economic pursuits need to be in harmony with the environment and with society.
Our vision is to become the world’s most successful and sustainable grass-fed red meat company and by focusing on sustainability and the wider environment alongside our farmers, we think this vision is achievable.
Some of the policies to consider:• Farm Assurance Policy• Sustainability Policy• Environment Policy
Ask yourself:• Will my actions have an irreversible
negative impact on the environment?• Do I understand the legal
requirements of what we are doing, and have I obtained all the required permits and sign-offs?
• Do the suppliers I am working with understand our position and policies on sustainability and the environment?
• What would the reaction be if my conduct were reported in the newspapers?
• What impact might this have on Silver Fern Farms’ reputation?
• Would I be OK with this activity taking place next to where I live?
Working together with our farmer shareholders and suppliers
The success of Silver Fern Farms relies on strong partnerships with
our loyal and dedicated farmer shareholders and suppliers.
Together with our 16,000 farming partners across New Zealand we
work to grow animals and apply our expertise to meet consumer needs.
We are a company of proud, passionate farmers and food people, dedicated to doing the right thing, collaborating and innovating, and always creating inspirational food
for our customers.
Silver Fern Farms 35What matters to us34 Code Of Conduct
Animal Welfare – our customers and consumers expect it
Outline:We believe healthy, well-cared-for animals are vital to producing safe, high-quality meat. We are committed to responsible animal welfare practices. We also know that diseases and pests pose an ongoing threat to animal health and welfare and general farm resilience. We are committed to supporting robust standards, innovative solutions, and being prepared to respond to any incidents.
Some of the policies to consider:• Animal Welfare Policy• Livestock Procurement Policy• Farm Assurance Policy
Ask yourself:• Does this show respect to the animal?• What would the reaction be if my
conduct were reported in the newspapers?
• What impact might this have on Silver Fern Farms reputation?
• Would I be okay with this activity next to where I live?
• What impact might this have on our product’s reputation?
• Will this meet our customers’ expectations of quality?
• Will my actions risk a breach of our food safety regulations?
Silver Fern Farms 37Code Of Conduct36 What matters to us
Food Quality and Safety – a core part of delivering world-class products
Outline:To become the world’s most successful and sustainable grass-fed red meat company, we must focus on the highest standards, with food safety and quality at the core.
We want to provide safe and high-quality food every time, everywhere, that meets the expectations of our customers and consumers.
We use internal systems and external suppliers that ensure our products meet our own strict food safety and quality requirements, as well as all applicable laws.
To continually improve our food safety and quality standards, we share information both internally and externally and encourage our employees to bring forward ideas which can improve our efforts.
Some of the policies to consider:• Farm Assurance Policy• Laboratory Quality Policy• Quality Policy
Ask yourself:• Would I eat this food, or want my own
family to eat this food?• Will this have a negative impact on
the quality of our products?• Is there a problem in our operations
that could compromise food safety or quality that I need to tell management about?
• What impact might this have on our product’s reputation?
• Will this meet our customers’ expectations of quality?
• Will my actions risk a breach of our food safety regulations?
Silver Fern Farms 39Code Of Conduct38 What matters to us
Plant and Equipment – taking care of our tools of work
Outline:Our plant and equipment are there to produce quality products and support us in working effectively. We treat all our tools and equipment with respect, taking care to ensure they remain fit for purpose and reliable. We seek to minimise energy wastage, undertake preventative maintenance and always operate within tolerance levels.
Some of the policies to consider:• Equipment and machinery guidelines• Repairs and Maintenance Policy• Asset Management Policy• IT Acceptable Use Guidelines/Policy• Information/Systems Security Policy
Ask yourself:• Am I properly trained to use this plant
or equipment?• Is my use of company equipment
appropriate?• Do I make sure I use the company’s
machinery to deliver top-quality products?
• Am I unnecessarily costing the company money?
• Do I have the appropriate delegated authority to commit to this expenditure?
• Have I considered the social, ethical and environmental considerations before I buy assets for the company?
• Have I safeguarded our confidential and sensitive information from improper disclosure?
Silver Fern Farms 41Code Of Conduct40 What matters to us
Code Of Conduct Silver Fern Farms42 43
Other Expectations
We operate in a complex business with a global supply chain and many factors to consider.
As a consequence of this, we also need to think about several other matters. Some would say these are ‘common sense’, but we feel we still need to be clear on these matters.
Using social media wiselySocial media is a great way for us to engage with our customers and stakeholders and to connect and collaborate with colleagues around the globe. Silver Fern Farms uses several social media platforms to encourage and enable two-way communication and increase engagement with our brands and our consumers. We encourage you to participate in this dialogue; however, please remain mindful of your responsibilities online and ensure that you participate in a respectful, relevant way. Please refer to our Social Media and Electronic Media policies for further details.
Being sensible when you are travellingWe have a large number of people on the road who need to travel for business. This can create some issues for us so any time you are travelling for work, use good judgement. For example, please ensure that any consumption of alcohol before, during or after travelling will enable you to comply with the policy when you are next expected to work. Also, when you are travelling and staying at various locations, you are still representing Silver Fern Farms. Please refer to our Travel Policy for further details.
Being prepared for a crisis, an emergency or any business disruptionCrisis, emergency and business disruption management is vital to protect our people and reduce any damage or loss. We must retain a high level of preparedness to respond to any business interruption in any location where we might have people, property or assets. Effective crisis, emergency and business disruption planning ensures we are committed to protecting our health and safety, minimising damage and impact to the company and continuing our operations after any disaster. Make sure you know what’s expected of you in these situations and help protect you and your mates as well as all our equipment and assets.
These include:
Using sponsorship, grants and donations that align with our purpose and valuesWe support legitimate and worthy causes aligned with our vision, purpose and values. Please work within established processes regarding sponsorship, grant or donation requests or decisions. Never request sponsorships or use company money for personal gain, and raise questions about any potential conflict of interest or appearance issues that may arise from charitable donations or sponsorships.
Only accepting gifts when it makes sense to do soThe line between token gifts of appreciation and those that might compromise the recipient is often not easily defined. Under the Hospitality and Gifts Policy, a gift should not be accepted where it could be seen by others as an open incentive or a reward that might place us under any obligation. This does not include customary gifts received as part of a typical marketing exercise by other businesses or persons - for example, calendars or Christmas gifts. As a general rule, you should obtain approval of your manager before accepting any gifts valued over NZ$50. The Legal team maintains a central gift register and all gifts received by employees over a value of NZ$50 must be reported via this gift register. This register details the recipient, donor, value, description and purpose of the gift. Please refer to our Hospitality and Gifts Policy for further details.
Representing yourself and your team wellAll staff attending internal and external work events are always expected to comply with the expected standards of behaviour. This includes taking care and responsibility around alcohol consumption.
Code Of Conduct Silver Fern Farms44 45Other Expectations
Avoiding any conflicts of interestWe value the integrity of our employees and your commitment to the interests of the company. Therefore, we rely on you to act in an open and honest manner at all times and in a way that does not interfere or conflict with your employment obligations. Conflicts of interest may arise when you or someone close to you (such as a spouse or family member) has an association with another business that is substantially similar to or likely to be in conflict with our business, or has any association with any business which is, or is seeking to become, a contractor, supplier or business partner to us. Conflicts of interest are assessed in terms of the likelihood that an employee who has a particular interest could be, or could appear to be, improperly influenced in the performance of their duties. If you use or intend to apply knowledge, information, experience or position gained through your association with us to further yourself materially in some external capacity, you must disclose this to your manager. If you consider that a conflict of interest does, or may, exist, you must advise your manager immediately.
Working with our competitorsWe are fully committed to complying with all local and global competition laws and regulations. We need to ensure that all our practices provide for fair and effective commercial competition between businesses. It is important to us that you understand and are fully aware of what you may and may not do when interacting or dealing with competitors and other parties (for example, with pricing and sharing market information). Please refer to our Competition Policy to find out more about this.
Respecting confidentiality – covers not only us as a business but also our farmers and suppliersExcept in the proper performance of your duties, you must not disclose (directly or indirectly) any information or knowledge regarding the affairs of our company, employees, farmers, suppliers and our customers, which is of a confidential nature. You must not share, or use for other than company purposes, any confidential information which is the property of Silver Fern Farms or may have been disclosed to us by a third party under an obligation of confidentiality, and you must take all reasonable precautions to maintain the security of such information. This requirement continues even after you cease working for us until the information ceases to be confidential. For more information, please refer to our Competition Policy.
Always being on the lookout for instances of bribery and corruptionYou must never accept or offer bribes. The direct or indirect offer, payment, soliciting or acceptance of bribes in any form (including favours) by our employees is unacceptable. We make no distinction between bribes and so-called ‘facilitation payments’, which are also prohibited. Facilitation payments are small payments to a low-level public official which are not legally required in order to speed up or enable a process which it is the official’s job to arrange. We also seek to ensure that contractors, agents and suppliers do not make facilitation payments on our behalf. You must never accept or give a bribe, facilitation payment, ‘kickback’ or other improper payment for any reason, whether or not it is received directly or indirectly.
A kickback is the giving or accepting of money, gifts or anything of value that is provided in return for favourable treatment. For more information, please refer to our Hospitality and Gifts Policy.
Knowing how to manage insider trading risksSilver Fern Farms undertakes many and varied commercial transactions. Many are legislatively driven which are designed to protect us and the people who invest in us. This legislation ensures that everyone has the same access to the same information at the same time, so nobody can take advantage of inside knowledge to profit unfairly. To make sure we comply with this legislation, we prohibit the disclosure of material information gained through employment before it is made public. We require all employees to comply with our Disclosure Policy. We prohibit all employees from trading in financial instruments of companies or encouraging others to trade based on material information gained through employment with us before it is made public. Please refer to our Securities Trading Policy.
Being careful with our money and any threat of anti-money launderingMoney laundering is the use of transactions by criminals, terrorists or others to conceal the illegal source of their funds. We are committed to the highest standards of anti-money laundering compliance to prevent the use of our products and services for money laundering purposes or for the financing of terrorism. We comply with all applicable local and international laws and regulations, appropriate standards and principles, including all competition, anti-trust and anti-money laundering laws.
Silver Fern Farms 47Code Of Conduct46 Other Expectations
Raising a concern —Speaking up
We encourage everyone to raise concerns about potentially unethical or illegal conduct. If something doesn’t seem right to you don’t ignore it, speak up.
Speaking up is crucial to our culture and our long-term results - it is a living example of our values. Speaking up when something doesn’t seem right demonstrates our integrity and that we always want to do the right thing. Speaking up helps to prevent mistakes and misconduct, and fosters trust and respect. Speaking up shows that we care about each other and our business. And speaking up to get things right or keep them on track helps us live up to our commitment to delivering high-quality safe food to our customers. Please refer to this Code often. It isn’t something you read once and forget about; it’s your guidebook for doing what’s right.
If you see behaviour at work that you feel may be in breach of this Code or seems illegal or unethical – like theft, drug use, or a threat to data privacy – you must report it, even if you only suspect it. You should also report the abuse of our systems, processes or policies. This could be bullying or harassment, potential conflicts of interest, or danger to the health and safety of employees or customers.
There are four ways to speak up:
01Report it to your Supervisor or Manager. We know it’s not always easy to raise your concerns. However, we value open and honest communications, so you’re encouraged to discuss any issues or potential issues with your manager.
02Report it to your People/Human Resources team. If it’s not appropriate to discuss the issue with your manager or supervisor, you should talk with someone from our People/Human Resources team – ask your manager if you don’t know who these team members are.
03Report it to your Health and Safety Manager/Co-ordinator. Particularly for safety-related incidents or issues, continue to use our safety reporting processes such as hazard and near-miss reporting as a priority.
04Report it through the ‘Report It Now’ Hotline. If you are more comfortable speaking to someone externally, or the concern is of a nature that could seriously affect our company and its reputation, you may report your concerns to an appointed third party or higher authority (refer to the Protected Disclosures Act). The Report It Now Hotline is staffed by a third party external to Silver Fern Farms. Employees who report any such concerns in good faith are assured that their reports are treated as confidential and the source of the report will be kept secret in accordance with our Fraud and Whistleblower Policy and the law.
You can make a report in a number of ways:
Visit https://sff.reportitnow.co.nz/make-a-report/
Telephone 0800 2 ALERT (0800 225 378)
Text your phone number to 022 077 3740 and the service will call you back.
Code Of Conduct Silver Fern Farms48 49Raising a concern — Speaking up
What happens when a concern is raised?
This will depend on the nature of the concern. Once you have spoken to someone, you may be able to resolve the matter yourself. If not, you will be advised on the next steps to be taken. At all times, the confidentiality of any information you provide will be respected.
Breaches of the Code
We encourage you to come forward with any concerns. We take breaches of the Code seriously and your concern will be followed up.
We need all Silver Fern Farms’ employees to read, understand and live by this Code.
FAQs:
I am concerned that my colleagues will find out if I raise a concern. Will it be kept confidential?Yes, Silver Fern Farms will not tolerate retaliation against anyone who raises, in good faith, a genuine concern. We will keep what you tell us private throughout the investigation process, subject to our legal obligations. Your issue will be kept confidential regardless of which method you use to report it.
What if I report something suspicious that turns out not to be a breach of compliance? As long as your report was made in good faith because of a genuine concern, no action will be taken against you.
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Administration of the code
All employees must acknowledge that they have read, understood and agree to comply with the Code.
You are required to do this when you are hired and to renew this commitment annually.
Please note that the Code is not a contract of employment, and we may interpret, modify or delete some or all of the Code’s provisions, as well as related policies and standards at any time. Our philosophy of addressing risk focuses on open reporting, process improvement and prevention measures, rather than on blame or punitive action.
However, reckless behaviour is a failure to follow this Code and will be treated as misconduct, which could result in disciplinary action and even dismissal. Breaches of the law may also result in civil or criminal penalties.
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In summary
Because our Code covers so much detail and different situations, keeping everything in mind may seem unnerving.
However, in any situation you’re not sure about, remember the following key points, and you’ll be well on your way to living our Code of Conduct.
Decide what’s right.
Ask yourself:
• Am I acting with integrity and respect?
• Would I be proud to tell a colleague I admire?
• Is it legal?• Who is this good for?• Who could be harmed?• What is the truth?• Is this the right thing to do?
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