Sedalcol UK Ltd places a high level of importance upon its environmental responsibility and is committed to the careful management of all aspects of its operation, in order to maximise efficiency and minimise any impact to the natural environment. At Sedalcol we employ a range of modern production and monitoring methods, alongside effective environmental procedures, in order that our operations ensure the efficient use of natural and renewable resources and the promotion of sustainable development. Fulfilment of all applicable compliance obligations, as well as continual efforts to protect the environment including preventing pollution and improving environment and energy performance, throughout all our activities, is an integral part of the Sedalcol business model. Sedalcol UK Ltd is moreover committed to maintain the confidence of its stakeholders (neighbourhood, community, customers) by meeting or exceeding environmental and energy performance expectations. This commitment is implemented on a daily basis through the company s environmental management system (EMS), which is certified to ISO 14001 and which is continually improved to enhance environmental performance and to ensure ongoing: Reduction of the environmental impacts associated with site activities, products and services. Compliance with legal requirements and permits. Reduction in the use of energy and water per tonne of finished product. Control of nuisances to within acceptable limits (odour, noise, air emissions). Minimisation of liquid and solid wastes for disposal. Maintenance of existing ISO 14001 certification. Focus on energy usage and efficiency facilitated by internal monitoring and audits, both internal and external. This continual environmental improvement is achieved by: 1. Controlling current operations through appropriate operating procedures and according to the BAT principle (Best Available Techniques). 2. Evaluation of environmental impacts of new projects, redevelopments and/or important process modifications. 3. Maintenance of a proactive, constructive relationship with regulators, relevant local bodies and neighbours. 4. Well-developed contingency plans and procedures for incidents, emergencies and disaster relief. 5. Careful consideration of the environmental probity of major suppliers and contractors to ensure, through safety data sheets and supplier questionnaires, understanding of any implication that their products or services might have on operations. 6. Setting and reviewing environmental objectives on an annual basis. ------------------------------------------------ 14/06/2018 SED EMS-005 rev.4
Quality Sedalcol UK strives to provide its business partners of the food industry, chemical and industrial applications and animal nutrition industry wheat derived products and services complying with the highest standards for quality and reliability. Our plant operates according to recognized standards for product safety (food and animal feed), occupational health, safety and environmental aspects. Our Company has established and applies an Ethical Charter. Being successful in our mission and continuously improving our performances will enhance the satisfaction of our customers, create value for our partners, motivate our employees and stakeholders; hence ensuring future growth for our company and its business partners in a sustainable way. Compliance with our core values is translated in our everyday business by applying total quality principles and targeting continuous improvements as follows: 1. Safety Ensure our end products and production processes meet requested regulatory and quality standards as applicable for personal health and safety, food and feed safety. Promote continual improvement at our suppliers and subcontractors for products and services, in accordance with our internal standards. 2. Customer focus Set up close relationships with our customers to understand their requirements and expectations, show high responsiveness and flexibility to enhance the customer satisfaction level. Be recognized as a key player in the global success of our customers, by creating and supporting a partnership approach. Provide timely and effective responses and implementation of corrective and preventive measures in relation to customer concerns. 3. Initiative Provide work conditions where employees can achieve high professionalism and quality, through use and development of their skills and talents and where their role in the value creation for the company is truly recognized to their personal satisfaction. Apply creative solutions throughout the whole business process for meeting the agreed requirements in terms of performance, costs, deadlines and quality. 4. Team Spirit Promote cooperation between our teams and our partners in order to provide our customers with the best global solutions meeting their expectations in each domain of our business. Ensure that there is a clear understanding of responsibility of every employee toward the quality of our products and services to obtain Production Excellence. --------------------------------- 18/01/2018 SED SM-002 Rev.4
Food & Feed Safety and Hygiene Fundamental to our belief that being successful in our mission depends on the supply of safe products and services, it is Sedalcol UK responsibility to ensure the product safety of all products we manufacture. In addition to its Quality Policy, Sedalcol UK is committed to maintain the confidence of its customers in the food and feed industry by meeting or exceeding their expectation on the food and feed safety, in broad sense referred to as product safety in this policy. In compliance with our core values this is translated in our everyday business as follows: 1. Safety Meet and exceed statutory and regulatory requirements on product safety for all end products and production processes intended to the food and feed industry. Ensure that suppliers and subcontractors for products and services embrace the same commitment to product safety, in accordance with our internal standards. Have a Food Defence program in place protecting us from deliberate acts against our premises, staff and products produced. 2. Customer focus With regards to product safety, set up close relationships with our customers to understand their requirements and expectations provide timely and accurate responses to customer complaints and monitor customer satisfaction. Set up programs for critical product safety elements ensuring compliance with HACCP (Hazard Analysis Critical Control Points), allergen management, foreign bodies control, personal hygiene, good manufacturing and cleaning practises, pest control and emergency response preparedness. 3. Initiative Set up suitable channels for internal and external communication in order to ensure that our employees, customers and any other business partners are fully informed and aware of our commitment and expectations on product safety. Maintain records and documentation to demonstrate compliance with manufacturing specifications and policies. Regularly review, verify and validate the effectiveness and efficacy of the product safety management system and compliance with the company targets via Management Review, HACCP review and Product Review. 4. Team Spirit Ensure sustainable product safety through implementation and certification of effective product safety management system: FSSC 22000 for food safety, EFISC for feed safety and our Internal Standard for FES Food Safety. Support Production Excellence by ensuring well-understood responsibility and accountability of every employee regarding the product safety of our product and services. ---------------------------------- 17/01/2018 SED SM-003 Rev.4
General Health & Safety Policy Statement of Intent 2018 In accordance with the requirements of Section 2(3) of the Health and Safety at Work, etc. Act 1974, Sedalcol UK Ltd states that its general health & safety policy is: To fully comply with all relevant statutory requirements To provide adequate control of the health and safety risks arising from our work activities; To consult with our employees, and main contractors on matters affecting their health and safety; To provide and maintain safe plant and equipment; To ensure safe handling and use of substances; To provide information, instruction and supervision for employees; To ensure all employees are competent to do their tasks, and to give them adequate training; To prevent accidents and cases of work-related ill health; To maintain safe and healthy working conditions; To review and revise this policy as necessary at regular intervals. An effective health and safety management system depends on co-operative efforts by all. Sedalcol UK Ltd expects management, employees, visitors and contractors to recognise that they have a clear duty to: Take care of the health and safety of themselves and others; Co-operate fully with health and safety arrangements made by Sedalcol UK Ltd. --------------------------------- 04/01/2018 Note: This one-pager represents only the general intention of the company health & safety policy and should be posted on all health & safety notice boards and brought to the attention of all employees on an annual basis. The overall system is explained in SAF 200 Sedalcol UK Ltd Health & Safety Policy and other associated documentation, which is freely available for all interested parties to review.
Ethical Trading Sedalcol UK Ltd supports in its actions the principles of the Ethical Trading Initiative (ETI) Base Code in the areas of human and labour rights, environment and anti-corruption, and perceives the principles as a powerful platform for our activities within sustainability. Sedalcol UK Ltd will integrate social and environmental concerns into its business operations and in its interaction with its stakeholders. Employment is freely chosen Freedom of association and the right to collective bargaining are respected Working condition are safe and hygienic Child labour shall not be used Living wages are paid Working hours are not excessive No discrimination is practised Regular employment is provided No harsh or inhumane treatment is allowed --------------------------------- 19/01/2018 SED SM-004 Rev.0
No Child Labour Sedalcol UK Ltd endeavours to provide a conducive working environment that is characterized by equality and mutual respect. Sedalcol UK Ltd Child Labour Policy has been established in order to make Sedalcol UK Ltd position clear to suppliers and their co-workers, as well as any other parties. The requirements in this code of conduct are mandatory to all suppliers and their sub-contractors. General Principle Sedalcol UK Ltd child labour policy is based on the International Labour Organisation (ILO) Minimum Age Convention no. 138 (1973). According to this convention, Child labour means work by children under the age of 12; work by children under the age of 15 that prevents school attendance; and work by children under of age of 18 that is hazardous to the physical or mental health of the child. Sedalcol UK Ltd does not employ any person below the age of eighteen years at the workplace. Sedalcol UK Ltd prohibits the use of child labour and forced or compulsory labour at all its productions departments. No employee is made to work against his/her will or work as bonded/forced labour, or subject to corporal punishment or coercion of any type related to work. Young Workers Sedalcol UK Ltd supports the legal employment of young workers. Young workers of legal working age have, until the age of 18, the right to be protected from any type of employment or work which, by its nature or the circumstances in which it is carried out, is likely to jeopardise their health, safety or morals. Sedalcol UK Ltd therefore requires all its suppliers to ensure that young workers are treated according to the law; this includes measures to avoid hazardous jobs, night shifts and ensure minimum wages. Limits for working hours and overtime should be set with special consideration to the workers young age. In the conduct of its business, Sedalcol UK Ltd: Will not employ children that falls into the definition as stipulated by ILO Convention, notwithstanding any national law or local regulation; Will comply with all other applicable child labour laws, including those related to wages, hours worked, overtime and working conditions; Is against all forms of exploitation of children; Expects its business partners and associates to have and uphold similar standards and abide by countrygoverning laws in countries wherein they operate. Should violation of these principles become known to Sedalcol UK Ltd and not be remediated, we will take serious action, including discontinuation of the business relationship; It is the responsibility of local management and Human Resource Department to implement and ensure compliance with this policy at all Sedalcol UK Ltd. ---------------------------- 10/04/2018 SED SM-009 Rev.0
Slavery and Human Trafficking Introduction from the Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them. Organisation s structure Sedalcol UK Ltd has its head office in Denison Road, Selby, North Yorkshire, YO8 8AN. Through the use of innovative technology, we manufacture products by the transformation of wheat to satisfy the needs of the food industry (grain neutral alcohol, native wheat gluten), of the paper industry (native and modified starches) and animal feed industry (bran and stillage). In compliance with the Modern Slavery Act 2015, Sedalcol UK Ltd offers the following statement regarding its efforts to prevent slavery and human trafficking in its supply chain. Our policies on Slavery and Human Trafficking We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business, working closely with our suppliers to ensure that slavery and human trafficking risks are identified and managed proactively. Sedalcol UK is accordingly committed to eliminate forced labour and compulsory labour and to effectively abolish child labour. This includes International Labour Organisation conventions 138 & 182 on the prohibition of child labour and 29 & 105 on the elimination of forced or mandatory labour. We expect the same standards from all those we work with, including business partners and suppliers. Due diligence processes for Slavery and Human Trafficking As part of our initiative to identify and mitigate risk: Where possible we build long standing relationships with local suppliers and tenancy customers and make clear our expectations of business behaviour; With regards to national or international supply chains, our point contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the food chain to, at least, adopt oneup due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the food chain, ultimately to the field or utility generator. We encourage the reporting of concerns. The Company will support anyone who raises genuine concerns in good faith under this Statement, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in human Trafficking, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future. We will continue to conduct our business in accordance with our ethical sourcing standards across our supply chains through our Ethical Trading Policy. Sedalcol UK Ltd will not support or work with supplying sites that are involved in human slavery and human trafficking issues. Page 1 SED SM-008 Rev.0
Slavery and Human Trafficking This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company's slavery and human trafficking statement for the current financial year. The Company Director has lead responsibility for ensuring compliance with this Policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and ensuring that this Policy complies with the Company s legal and ethical obligations. ---------------------------- 10/04/2018 Page 2 SED SM-008 Rev.0
Anti Bribery Introduction Sedalcol is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. Its reputation for maintaining lawful business practices is of paramount importance and this policy is designed to safeguard this. Sedalcol therefore has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings. Purpose and scope of Policy This Policy sets out the Sedalcol s position on any form of bribery and corruption: We will ensure compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which the Company may carry out its business. We will enable employees and persons associated with the Company to understand the risks associated with bribery and to encourage them to report any wrongdoing. We will provide suitable and secure reporting and ensuring that any information that is reported is effectively dealt with. This Policy applies to all permanent and temporary employees of the Company. It also applies to any individual or corporate entity associated with the Company, including, but not limited to, directors, contractors, consultants, seconded staff, agents and suppliers. Legal obligations The UK legislation on which this Policy is based is the Bribery Act 2010 and it applies to the Company s conduct both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is an offence in the UK to: offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct bribe a foreign public official. You can be held personally liable for any such offence. SED SM-007 Rev.0
Anti Bribery It is also an offence in the UK for an employee or an associated person to bribe another person in the course of doing business intending either to obtain or retain business, or to obtain or retain an advantage in the conduct of business, for the Company. The Company can be liable for this offence where it has failed to prevent such bribery by associated persons. Policy statement All employees and associated persons are required to comply with anti-bribery and anti-corruption legislation that applies act honestly, responsibly and with integrity Operate in an ethical, professional and lawful manner at all times. Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe. The Company recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this Policy is expected of all employees and associated persons at all times. Business Gifts/Hospitality The giving of business gifts to clients, customers, contractors and suppliers is not prohibited provided the following requirements are met: The gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage it complies with local laws it is given in the Company s name, not in the giver s personal name it does not include cash or a cash equivalent (such as gift vouchers) it is of an appropriate and reasonable type and value and given at an appropriate time it is given openly, not secretly it is approved in advance by a director of the Company. SED SM-007 Rev.0
Anti Bribery In summary, it is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them. Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government process, otherwise known as a facilitation payment, is also strictly prohibited. Facilitation payments are not commonly paid in the UK. Responsibilities It is the contractual duty and responsibility of all employees and associated persons to take whatever reasonable steps are necessary to ensure compliance with this Policy. You must immediately disclose to the Company any knowledge or suspicion you may have that you, or any other employee or associated person, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the Company. Whistle Blowing The Company is committed to taking appropriate action against bribery and corruption. If you have a concern or suspicion report this directly to your manager or next most senior manager if the incident relates to them. During an investigation period we will keep your information confidential as long as reasonably practical. The Company will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future. Sanctions for breach A breach of this Policy will constitute a disciplinary offence and will be dealt with in accordance with the Company s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could result in summary dismissal. As far as associated persons are concerned, a breach of this Policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement. SED SM-007 Rev.0
Anti Bribery Monitoring compliance The Company Director has lead responsibility for ensuring compliance with this Policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and ensuring that this Policy complies with the Company s legal and ethical obligations. ---------------------------- 19/01/2018 SED SM-007 Rev.0