Code of Conduct

6th January 2017

(relating to Anpario plc, “the Company”; and its subsidiaries together “the Group” and “Anpario”)

  1. Corporate social responsibility statement

Anpario seeks to ensure a sustainable business, behaving socially, ethically and environmentally responsibly in relation to all its key stakeholders, including the communities in which the Group operates; its people; and the environment. This is demonstrated through its:

Ethics

At Anpario we are committed to behaving professionally and responsibly to ensure the highest standards of honesty and integrity are maintained. All employees and business partners (including suppliers, customers, consultants, agents and representatives) shall not take any actions to violate any applicable national and international anti-bribery and corruption legislation, including the UK Bribery Act 2010. The Group’s policy is set out in an Anti-bribery and Corruption policy which is set out in this Code of Conduct.

Employees

It is the Group’s policy to involve colleagues in the business and to ensure that matters of concern to them, including the Group’s aims and objectives and its financial performance, are communicated in an open way. We encourage our employees to further develop their skills and provide appropriate training in order to support our people and grow organisational capabilities.

Anpario is an inclusive organisation where no-one receives less favourable treatment on the grounds of gender, nationality, marital status, colour, race, ethnic origin, creed, sexual orientation or disability. The promotion of equal opportunities for all employees is regarded as an important Group priority.

Products and operations

Anpario supplies animal products to many countries and aims to provide products to enhance animal health and nutrition. Internal quality control ensures: the safety of its products; transparency and traceability; the operation of its manufacturing facilities to the highest standards; and the achievement of industry recognised quality standards. We have an established Group health and safety policy and we are committed to achieving a safe and secure working environment in all our own locations.

Suppliers

Responsible procurement policies are in place to source raw materials to high specification and rigorous quality standards. The supplier shall comply with all applicable ethical labour, trade laws and regulations in the geographies where materials are sourced and produced. Anpario does not accept slavery and human trafficking within our supply chain and will endeavour to comply with the requirements of The Modern Slavery Act 2015.

Environment

The Group recognises the importance of good environmental controls. It is the Group’s policy to comply with environmental legislation currently in place, adopt responsible environmental practices and give consideration to minimising the impact of its operations on the environment.

  1. Anti-bribery and corruption policy

Anpario has a commitment that all of our business dealings will be conducted honestly and with integrity. Anpario will not tolerate any form of bribery and corruption. The Executive Directors will support all employees and business partners (including joint venture partners, distributors, consultants, agents and representatives) when they make decisions in accordance with this policy

Scope

This policy applies to all persons who work for or with Anpario and extends to cover all business dealings and transactions in all countries and territories in which subsidiary or associated organisations operate. This policy will also be operated in respect of our dealings with any sub-contractors or suppliers.

Gifts and Entertaining

All Anpario employees are expected to conduct themselves with integrity, impartiality and honesty at all times. In addition all business partners are required to follow these standards. Gifts or entertainment must only be accepted for legitimate business purposes. It is a key requirement of this policy that no gift or entertaining should ever be given or received if there could be an inducement to conduct business which might not otherwise take place.

Facilitation Payments

So called Facilitation Payments are made in the form of a payment or gift to any public official or other person to encourage the proper and prompt enactment of a routine process or procedure. It is common for these to be demanded and paid in some overseas localities and jurisdictions. It is strictly prohibited for any Facilitation Payments to be made by any employee of Anpario or by anyone else on behalf of the Company or Group.

Conflicts of loyalty

Should any employee or business partner discover themselves to be in a situation where any personal interest or relationship might cause any conflict of interest with regard to their duties to the business they are required to immediately declare the same in writing to an appropriate official, Senior Manager or Director who must then immediately declare the matter to the Company Secretary.

Prohibitions

Employees and business partners must never:

  • Offer or make an unauthorised payment or authorise an improper payment (cash or otherwise) to any local or overseas Government Official, or any related person or entity.
  • Attempt to induce any local or overseas Government Official to do something illegal.
  • Shrug off or fail to report any indication of an improper payment or benefit in kind.
  • Offer or receive money or anything of value, gifts or commission in relation to obtaining business or awarding contracts, or designed to improve the chances of that occurring.
  • Do anything to induce or facilitate somebody else to break any part of this policy and the related rules.
  • Fail to report any instance if ever it comes to their attention or it is suspected that any other employee or somebody associated with Anpario is in breach of this policy or any of the related rules. For the avoidance of doubt, an employee must report their own wrongdoing.

Any employee who breaches any of these prohibitions is liable to disciplinary action and outcomes up to and including summary dismissal.

Responsibility

The Executive Directors of Anpario have the overall responsibility for implementing this policy. If any instance of bribery or corruption is identified, the Executive Directors will immediately implement remedial measures.

  1. Raising concerns and contact information

All employees and business partners are encouraged to raise concerns about instances of actual or suspected financial malpractice or infringement of obligations stated in this Code of Conduct at the earliest possible stage by communicating this to The Company Secretary, who is the Group’s Compliance Officer:

Post: The Company Secretary, Manton Wood Enterprise Park, Worksop, Nottinghamshire, S80 2RS, UK

Telephone: +44 (0) 1909 537380