Ethics and Compliance

Midooc Group Limited (“Midooc”) aims to create and maintain a corporate culture in which it is best possible to comply with the applicable laws and standards as well as with the Company’s own ethical principles. For this reason, Midooc has established an Ethics and Compliance as a voluntary commitment, which sets out the benchmarks and guidelines of corporate activities. Ethics and Compliance has two main objectives: On the one hand, the Company provides the employees with general standards of conduct which are intended as guidelines to deal with colleagues, business associates and customers. Based on the BSCI´s valid rulings the Ethics and Compliance should on the other hand act as a building block to fully understand the corporate culture with regard to integrity and ethical conduct. The Ethics and Compliance, details of which are set out in the relevant long version, specify the following principles.

Competition and antitrust law

Midooc has a commitment to undistorted competition, i.e. competition that is not impaired by inadmissible anti-competitive and/or unfair business practices. The employees must refrain from using improper business practices.

Cooperation and dealing with authorities

Midooc works with public authorities in accordance with current legislation on the basis of mutual trust.

Conflicts of interest

It is imperative to avoid conflicts of interest that could arise or could seem to arise for example from the close relationship of employees with business associates and customers or from secondary employment of the employees. Where there might be a potential conflict of interest, the employees are obliged to consult their superior on the course of action to be taken.

Gifts and gratuities

Offering or accepting gifts and gratuities, which might even only have a potential impact on business decisions, is generally prohibited. If there is no risk that business decisions will be influenced, then the offering and accepting of gifts and gratuities is only permitted if they comply with ethical business practices and no applicable laws are violated.

Environmental protection

As a company in the food industry, the protection of the environment and its resources for today’s generation and for future generations is a fundamental concern to Midooc. Midooc and its employees thus work constantly to reduce the environmental impact in the development, production and marketing of their products without wasting resources.

Data protection

Midooc respects the rights of employees and persons not employed by the Company (e.g. customers or business associates) with regard to their personal data. Personal data is therefore processed solely in compliance with legal provisions and Midooc’s contractual obligations. The employees are obliged to comply with legal and contractual data protection standards regarding the personal data for which they are responsible.

Handling of confidential information

Employees are obliged to treat information about the Company, customers, business associates and colleagues in strict confidence. For this reason, employees must keep confidential documents in such a way as to protect them from the unauthorized access of a third party.

Prohibition of undue discrimination and sexual harassment

The behavior of Midooc’s employees is marked by a great sense of responsibility and complies with statutory provisions. A respectful and fair behavior towards each other is important, as it is the only way to ensure a working environment built on trust which ultimately is a prerequisite for proper decision-making.

The diversity expressed in the origin, culture, language and ideas of the employees provides Midooc with business and personal opportunities. Midooc values this diversity and is aware that great care is required when dealing with one another in order to avoid misunderstandings and conflicts.

Midooc therefore rejects any type of undue discrimination as well as any form of bullying and sexual harassment. A discriminatory treatment of employees, e.g. on grounds of race, ethnic origin, gender, religion or belief, disability, age or sexual orientation is not allowed. Midooc opposes any form of xenophobia and extremism, and has joined the “Working together for Tolerance” initiative with total conviction.

Political activities

Midooc recognizes the rights to freedom of assembly and the setting up of interest groups.

Party political activity in the Company, in particular the organization of political events on the Company premises, is explicitly forbidden. The employees are not permitted to attach posters, write on walls or distribute leaflets or other printed matter without the explicit agreement of Midooc. § 74 paras. 2 sentences (Works Council Constitution Act) points out that the employer and works council must refrain from any party political activity within the company; dealing with collective bargaining, socio-political, environmental and economical issues, which are directly related to the company or its employees, is not affected by this.

Employees are of course free to engage in political activity privately if they do not act as employees or representatives of Midooc.

Alcohol and drugs

Alcohol and drug abuse are a serious risk for the safety, health and productivity of the company and the employees. The health and well-being of the employees as well as high safety standards have the utmost priority. This includes assuming responsibility where there is a risk of alcohol and drug consumption and the associated hazards at the place of work.

The possession, consumption and procurement of drugs on the company premises is therefore strictly forbidden. It is also prohibited for employees to carry out their job for Midooc under the influence of drugs or alcohol. Any employees who are under the influence of alcohol or any other intoxicants must leave the company premises.

Prohibition of child labor

Child labor and also any exploitation of children and youths is not tolerated by Midooc. Statutory provisions specified in the law on youth employment protection are applied when hiring and employing personnel.

Prohibition of forced labor and disciplinary action

In accordance with statutory provisions, there is neither forced labor nor are there disciplinary actions at Midooc. Employees are only to be recruited if they have made themselves available for work on a voluntary basis. You have the right to leave your place of work at the end of the working day and you are free to end your employment subject to the period of notice (Collective Wage Agreement). The use of corporal punishment or psychological or physical coercion and verbal abuse is prohibited.

Remuneration

Remuneration at Midooc is in accordance with the basic collective agreement and the collective wage agreement of the location country government in accordance with the statutory regulations such as e.g. the law on working hours, the law regulating workers’ leave and the law on continued remuneration. No illegal or unjustified wage deductions or disciplinary measures in the form of wage deductions shall be carried out. Midooc ensures that the employees are informed clearly, in detail and on a regular basis about their pay structure. It is also guaranteed that remuneration is paid in compliance with the applicable laws and that remuneration is paid in a manner that is appropriate for the employees.

Working hours

Midooc pays attention that the regulations on the working hours are in accordance with statutory provisions. There are regulations regarding extra hours and overtime, which are also specified in the collective wage agreement of overtime and/or in other collective agreements.

Implementation of and compliance with the Ethics and Compliance

Each individual employee shall contribute to the correct implementation of the Ethics and Compliance in the Company at all times. Should there be uncertainties regarding the contents of the Ethics and Compliance or if there are questions on whether a specific behavior complies with the requirements of the Ethics and Compliance, each employee should feel free to contact his/her superior and other employees who are responsible for these matters.