Code of Conduct
Updated: 1st January 2019
CODE OF CONDUCT
(relating to Anpario plc, “the Company”; and its subsidiaries together “the Group” and “Anpario”) and applicable to all employees and business partners, including joint venture partners, suppliers, customers, consultants, agents and representatives.
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:
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 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.
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 products for animal health 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.
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.
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.
2. 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 when they make decisions in accordance with this policy.
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.
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.
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.
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.
3. 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 and or the Group Risk and Compliance Director: Manton Wood Enterprise Park, Worksop, Nottinghamshire, S80 2RS, UK. Telephone: 00 44 1909 537380
Environmental, Responsibility & Sustainability Statements
Updated: 28th January 2022
Sustainability means avoiding depletion of natural resources in order to maintain an ecological balance. It focuses on meeting the needs of the present without compromising the ability of future generations to meet their needs.
- Through our products, innovations and collaborations, Anpario:
- - contributes to feeding a growing global population in a world with finite resources;
- - helps to create good health and nutrition from feed to farm;
- - helps to combat animal diseases that can destroy animals, livelihoods and world food supply.
2. Our innovative products work in harmony with the animals’ biology to promote healthy growth and demonstrate value:
- - to the animals fed directly through all life stages;
- - indirectly to their progeny; and
- - ultimately within the human food chain.
(8th September 2022)
Anpario plc has established this Environmental Policy to be consistent with the purpose and context of our Organisation. It provides a framework for the setting and review of environmental objectives in addition to our commitment towards the following:
- protection of the environment, including the prevention of pollution;
- sustainable resource use, climate change mitigation and protection of biodiversity and ecosystems;
- conformity to applicable legislative, regulatory and compliance obligations; and
- to continually improve our Environmental Management System and to enhance environmental performance.
Anpario plc has produced environmental objectives which relate to this policy and encompassed in the 3 Pillars Framework PLANET PEOPLE, PROMISE and in ISO14001 documents retained on the server.
This policy is communicated to all interested parties as well as being made available to the wider community through publication on our Website.
- Our work and products have a potential impact on the environment. We have a duty to ensure we proactively manage the impact we have in a responsible, positive and ethical manner. This contributes to the more efficient use of feed ingredients to reduce environmental footprints and ensures responsibly produced food.
- Anpario has a corporate obligation led by the Board of Directors to recognise our worldwide responsibilities; working with nature to champion the production of safe and healthy food globally.
- Anpario can have a positive impact on several of the UN Sustainable Development Goals. https://sustainabledevelopment.un.org/?menu=1300
GOAL 3: Good Health and Well-being
GOAL 12: Responsible Consumption and Production
GOAL 17: Partnerships for the goals
- Anpario management and employees are our front line in delivering our corporate goals. Our values of integrity, teamwork, innovation and leadership have been established internally by our people. The Anpario ‘Green Team’, with volunteers representing all functions, initiate improved ways of working which are more sustainable for our environment.
- Each of us has our own personal goals to contribute to a cleaner sustainable planet.
Quality Policy Statement
Reviewed: 14th September 2021
Quality Policy Statement
It is our policy to source and obtain raw materials that conform to UK & EU regulations with respect to Feed Safety for the manufacture and supply of feed additives that satisfy our customer’s requirements and technical specifications.
In order to achieve this we have established a documented Quality Management system that complies with FEMAS & UFAS requirements and is overseen by the Company Quality Manager.
The Quality Management system is reviewed annually with the HACCP plan review.
ANPARIO Employee’s Responsibilities
All employees are made aware of the Company’s Quality policy objectives summarised in the Quality Policy statement during Company induction and are trained to meet Company quality standards. It is the responsibility of the Quality Manager to oversee the Quality policy and to agree changes with Directors and appropriate Managers.
Employees are expected to inform their Line Manager or the Quality Manager of any activities, operations or conditions likely to put product quality at risk. It is the responsibility of the Quality Manager to organise and maintain the Quality Management system. It is the responsibility of the Quality Manager to work with the Production department Managers to ensure that all employees follow Company procedures and Work instructions.
The Quality Manager has the authority to give direction with respect to all aspects of quality assurance.
Quality Management System Documentation
The ANPARIO Quality Manual sets out our business divisions’ control and assurance strategies.
The revision and maintenance of the manual is the responsibility of the Quality Manager. It is the responsibility of the Quality Manager to make sure that the work instructions and Company procedures in use are the current ones found in the Quality manual.
To be the global leader in developing and delivering products that naturally support and maintain animal health.
Anpario’s aim is to add value throughout the lives of animals. We combine knowledge, science and nature to provide products that enhance the natural development of livestock animals to maximise producers’ profitability.
Anpario operates a Quality system that meets the requirements of the FEMAS & UFAS code of practices.
Quality is at the heart of Anpario and all employees follow company procedures.
Feed safety requirements are part of our business goals and our commitment to feed safety is demonstrated by our use of HACCP and adherence to the FEMAS & UFAS code of practices. We comply with all legislation relating to the Animal Feed Industry and Health and Safety at work 1974.
The Anpario group monitors the quality performance of all its divisions and improvements are implemented whenever possible.
Anpario core quality objectives
- To offer high quality Animal Feed Additives that are safe to use and fulfil the appropriate technological requirement.
- To offer technical advice to our customers.
- To do business honestly and ethically.
- To be resourceful and helpful in meeting our customer’s needs.
- To be flexible with a helpful and responsive attitude.
- Above all we remember that our customers are the very purpose of our business.
This statement represents our commitment on behalf of the Company to our Quality policy.
Modern Slavery Policy
Updated: 3rd December 2020
A. WHAT IS SLAVERY?
The Modern Slavery Act 2015 covers four activities:
Forced or compulsory labour Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily. Human trafficking Arranging or facilitating the travel of another person with a view to their exploitation. Servitude The obligation to provide services is imposed by the use of coercion. Slavery Exercising powers of ownership over a person.
B. HOW IS IT RELEVANT TO ANPARIO PLC?
- Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part.
- At first glance it may seem that this is not an issue relevant to our business. We are however a global business operating in many countries around the world, sourcing materials from numerous countries. The economic and social conditions in the countries in which we trade are diverse leaving our business and supply chains at risk to the influence of modern slavery.
- In our business the principal areas of risk we face related to modern slavery are:
- our supply chains,
- the agencies we use for recruitment, and
- the business from whom we source materials.
- With this in mind, we need to pay close attention to these risk areas and aim to ensure everyone we employ, our agents, sub-contractors, suppliers, distributors and everyone involved in our supply chain are safeguarded, treated fairly and with dignity.
- Everyone we employ, our agents, sub-contractors, suppliers, distributors and everyone involved in our supply chain must observe this Policy and be aware that turning a blind eye is unacceptable and not an option.
C. OUR COMMITMENT
Within Anpario the commitment to this Policy starts at a corporate level and runs through to all our managers and employees.
- At a corporate level we will:
- maintain clear and proportionate policies and procedures to prevent modern slavery in our supply chain;
- be clear about our recruitment policy (see ‘Recruitment’ below);
- monitor our supply chains (see ‘Supply Chains’ below);
- lead by example by making appropriate checks on all employees, recruitment agencies and suppliers to ensure we know who is working for us and who we are working with;
- ensure we have in place an open and transparent grievance process for all staff;
- seek to raise awareness so that our colleagues know what we are doing to promote their welfare; and
- make a clear annual statement setting out the steps we have taken to ensure modern slavery is not taking place in our supply chains and to demonstrate that we take our responsibilities seriously.
- Our managers will:
- listen, and be approachable, to colleagues;
- respond appropriately if they are told something that might indicate a colleague, or any other person, is in situation where they may be exploited;
- remain alert to indicators of slavery (see ‘Identifying Slavery’ below);
- raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do; and
- use their experience and professional judgment to gauge situations.
- Our employees whatever their role or level of seniority will:
- keep their eyes and ears open and if they suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery);
- follow our reporting procedure if a colleague tells relays something that might indicate they or someone else is being exploited or ill-treated; and
- tell us if they think there is more we can do to prevent people from being exploited.
D. OUR PROCEDURES
- Anti-slavery statement:
We make a clear statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees, people working within our supply chain and our clients seriously.
We make this statement on our website and as part of our company reporting.
- Supply chains
- We perform thorough due diligence checks and risk assessments on supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
- Through our Code of Conduct we make it clear to the companies with whom we do business that we are not prepared to accept any form of exploitation.
- We ensure we can account for each step of our supply processes to ensure we know who is providing goods and services to us.
- Human Resources
- All our employees are treated equally and paid fairly and restrict working hours to those permitted and that are reasonable.
- Anpario has an established Equal Opportunities and Dignity at Work Policy which is communicated to all employees and training provided on its implementation.
- Our HR department follows a firm policy and only uses agreed specified reputable recruitment agencies who have acceptable anti-slavery policies and commitments.
- To ensure the potential for slavery and human trafficking is reduced as far as possible, we thoroughly check recruitment agencies before adding them to our list of approved agencies and we keep agents on the list under regular review.
- We always ensure all staff have a written contract of employment and have a full understanding of how they were recruited, and knowledge of any legitimate third party fees paid.
- We always ensure staff are legally able to work in the UK.
- We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
- If, through our recruitment process, we suspect someone is being exploited, the HR department will follow our reporting procedures (See ‘Reporting Slavery’ below).
E. TRAINING AND MONITORING
- We provide specialist training to those staff members who are involved in managing recruitment and our supply chains with more general awareness training is provided to all staff.
- We will review our Anti-slavery policy regularly, at least annually and will provide information and/or training on any changes we make.
F. IDENTIFYING SLAVERY
There is no typical victim and some victims do not understand they have been exploited. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.
The following key signs could indicate that someone may be a slavery or trafficking victim (this list is not exhaustive):
- they are not in possession of their own passport, identification or travel documents;
- they act as though they are being instructed or coached by someone else;
- they allow others to speak for them when spoken to directly;
- they are dropped off and collected from work;
- the person is withdrawn, or they appear frightened;
- the person does not seem to be able to contact friends or family freely; and
- the person has limited social interaction or contact with people outside their immediate environment.
A person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking.
If you have a suspicion, report it.
G. REPORTING SLAVERY
Talking to someone about your concerns may stop someone else from being exploited or abused.
Otherwise, you should discuss your concerns with our HR Manager, Risk and Compliance Officer or a Director who will decide a course of action and provide any further advice.
Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first before taking any further action.
If you think that someone is in immediate danger, dial 999.
H. Board Approval
This Policy is endorsed by our Board of Directors and will be reviewed regularly.