SUSTAINABILITY LIBRARY 2021
Policies
Policies

Policy: Political Involvement

Political involvement policy

Owner/Approver: CEO of Lerøy Seafood Group

Valid from: 2022-04-01

 

Purpose

Lerøy Seafood Group ASA and all it’s underlying subsidaries are politically neutral. We do not affiliate with any political party in any country and we do not make political donations to political parties or to any candidate running for office, nor sell products or provide services that endorse political parties.

 

Public Policy Involvement

The following is stated in Lerøy Seafood Group ASA’s Code of Conduct:

LSG does not support individual political parties or individual politicians. LSG has the right to take part in public debate, when in the interests of the Group.

Lerøy’s business all over the world is impacted both directly and indirectly by political decisions and public policy at all levels, including local, regional, national and internationally.

Lerøy participate in the public policy dialogue and debate when needed to share our knowledge on how decisions may impact our customers, our employees or other parts of our business.

In such occasions we share our insight and ideas as a contribution to relevant policy issues that affects our ability to achieve our goal of creating the world`s most effective and sustainable value chain for seafood.

 

Corruption

We do not attempt to improperly influence any official or policy maker at any level to gain a business advantage for Lerøy. This is lined out in our Code of Conduct Chapter 4 - Corruption.

 

Membership in organizations

Lerøy is a member of numerous industry and trade groups, and partners with various nonprofit organizations and non-governmental organizations, both at a local, national and international level.

This include organizations that represent the seafood industry, food industry and the business community on issues that are important to our stakeholders. 

We provide information directly to stakeholders or through our memberships of trade or policy focused organizations. Such policy engagement and political activities must always comply with Lerøy’s Code of Conduct and all applicable laws.

 

Employees political involvement

A democratic society is dependent on conscious and engaged citizens that takes part in the societies political and democratic processes.

Lerøy’s employes therefore have the right to be engaged in democratic political processes through political parties, NGOs and other kinds of political engagement in their individual private capacity as they see fit.

In such occasions private political activities must not in any way suggest Lerøy’s support or involvement. Our Code of Conduct states:

  • Employees have the right to take part in democratic political activities, but this must take place without reference to or connection with the employees’ relationship to LSG.
  • Without exception, employees shall be entitled to join or establish trade unions according to their free will

 

In addition, the employees personal political activities shall not be an argument or basis for adverse employment action as long as those activities are within the law and in full compliance with Lerøy’s Code of Coduct.

Valid for

All employees and contract labour shall comply with Lerøy’s  policy for political involvement.

Definitions 

None

Framework and principles

  • Lerøy’s Code of Conduct
  • The United Nations Global Compact principles on Human Rights, Labour, Environment and Anti-corruption
  • National and local laws

Roles and responsibilities

  • All those who work at Lerøy are responsible for ensuring that the act in accordance with Lerøy’s policy for political involvement.
  • The top management in each company is responsible for ensuring compliance with this policy.

Policy ownership and implementation

  • The CEO at Lerøy Seafood Group is the owner of this document, and is responsible for updates.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors

 

Policies

Policy for Anti-Corruption

Anti-corruption policy

Owner/approver: Group Director HR

Valid from: 2022-04-01

 

Purpose

This policy provides a brief and principal description of how Lerøy promotes ethical business culture by working transparently, with integrity and always lawfully wherever we operate and with everyone we do business with.

We are committed to conduct our business with integrity and in accordance with the standards and principles for business conduct and ethics outlined in our Business Code of Conduct,  this policy, applicable laws, rules and regulations, as well as internationally accepted guidelines, conventions or similar initiatives relating to anti-corruption, money laundering, fraud, slavery, environment, human rights, or similar activities. 

Lerøy has zero tolerance for corruption. The company opposes corruption in all forms – direct as well as indirect, active as well as passive, and in both private and public sector. Implementing anti-corruption measures is an integral part of our corporate responsibility protecting our reputation and the interests of our stakeholders. Business relations that are unwilling, or unable to comply with our Business Code of Conduct or this policy shall be terminated.

Lerøy shall provide training and guidance to its employees and workers regarding its Business Code of Conduct which communicates the baseline expectations regarding business conduct as well as ensuring that the employees and workers receive advice on how to handle ethical dilemmas which they might encounter in their work.

Concerns regarding corruption can be reported via independent internal or external reporting channel. Reporting can also be performed anonymously.

Principles for anti-corruption:

Never conceal corrupt or potentially corrupt activity;

Avoid activities that may facilitate any form for corruption;

Stay clear of fraudulent or dishonest activity;

Never accept or offer something that can be perceived as bribery or kickback.

In case of uncertainty regarding the content of this policy or the Business Code of Conduct employees and workers shall seek guidance. The first step should always be consulting the Business Code of Conduct or this policy. If the situation still remains unclear, seek advice from the management.

VALID FOR

This policy applies to all employees and workers in the Group. Contracts with business partners operating in relation with Lerøy shall include requirements for compliance with the contents of this policy.

DEFINITIONS

Corruption – abuse of entrusted power for private gain. Corruption erodes trust, weakens democracy and hampers economic development.

Employee - an individual who is in an employment relationship with the organization, according to national law or its application. Employees have a written employment contract directly with the organization.

Worker – an individual who performs work for a certain period of time (for example, seasonal workers etc.) and who is hired via manning agency. Workers have a written employment contract with manning agency.

FRAMEWORK AND PRINCIPLES

Lerøy is committed to complying with prevailing anti-corruption regulations, guidelines and principles, defined in the following documents:

ROLES AND RESPONSIBILITIES

  • All employees and workers at Lerøy are responsible for complying with this policy and for contributing towards transparent and ethical business conduct.
  • The top management in Lerøy Seafood Group and local management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local anti-corruption regulations.

POLICY OWNERSHIP AND IMPLEMENTATION

  • CHRO Lerøy Seafood Group is the owner of this document, and is responsible for updates.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Occupational Health and Safety

Occupational health and safety policy

Owner/approver: Head of ESG & Quality 

Valid from: 2022-04-11

 

Pupose

Lerøy Seafood Group  is committed to providing safe and healthy workplaces, by preventing work-related injuries and ill-health, as well as proactively improving its health and safety performance, fulfilling legal and other relevant requirements and working towards achieving defined health and safety objectives..

This policy provides a brief and principal description of how Lerøy shall establish and further develop sustainable and proactive occupational health and safety management in relation to own and our business partners’ activities. It also outlines the long-term direction for Lerøy to support and continually improve its occupational health and safety performance providing an overall sense of direction, as well as framework for setting occupational health and safety objectives. 

Lerøy aims to have zero injuries in the workplace and prevent all occupational illness. This is achieved through robust health and safety management which is detrimental for succeeding with identifying, preventing and mitigating significant negative occupational health and safety impacts. 

Systematic occupational health and safety measures shall be an integral part of all our activities. Lerøy and its activities shall be organized in a manner which ensures that the employees and workers are protected from harm to life and health. Prevention of injuries and accidents shall always be the company’s top priority.

Lerøy shall work continuously with developing a strong and positive occupational health and safety culture which is supported by the company’s values, managerial practices, patterns of activities and competencies – core elements for ensuring and maintaining sustainable health and safety culture. 

All employees and workers shall be welcomed to participate in dialogue regarding occupational health and safety thus influencing and developing a transparent two-way communication, consultation and participation practice. Lerøy shall ensure that employees and workers receive necessary and regular occupational health and safety training, and shall make active contributions to reinforcing occupational health and safety awareness in the company.

Lerøy is committed to:

  • Defining targets and tasks for the company’s occupational health and safety activities;
  • Continuous identification, assessment, control and mitigation of risk;
  • Measurement and assessment of registered occupational health and safety information;
  • Implementation of necessary measures to improve and boost the company’s occupational health and safety performance;
  • Support transparency and dialogue regarding occupational health and safety to continuously improve our occupational health and safety performance.

 

Valid for

This policy applies to all employees and workers in the Group. Contracts with business partners operating in relation with Lerøy shall include requirements for compliance with the contents of this policy.

Definitions

Employee - an individual who is in an employment relationship with the organization, according to national law or its application. Employees have a written employment contract directly with the organization.

Worker – an individual who performs work for a certain period of time (for example, seasonal workers etc.) and who is hired via manning agency. Workers have a written employment contract with manning agency.

Framework and principles

Lerøy is committed to complying with prevailing occupational health and safety regulations, guidelines and principles, defined in the following documents:

ISO 45001: 2017 Occupational health and safety management systems – Requirements with guidance for use

 

Roles and responsibilities

  • All employees and workers at Lerøy are responsible for complying with the policy and for contributing towards creating and sustaining a proper and safe working environment.
  • The top management in Lerøy Seafood Group and local management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local occupational health and safety regulations.

 

Policy ownership and implementation

  • The Head of ESG & Quality is the owner of this document, and is responsible for updates.
  • The policy has been approved by the corporate management at Lerøy, and is presented to the Group's Board of Directors.
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Cleaner fish

Cleaner fish policy

Owner/approver: COO of Farming 

Valid from: 2022-03-29

 

Purpose

In order to ensure the best possible results from using cleaner fish as a means of biological lice control, we need proper routines and close follow-up. We focus on proper care to safeguard the health and welfare of the cleaner fish in every part of the value chain. We believe that this allows the cleaner fish to act as an efficient lice-eater.

The policy framework has strong support throughout the organisation, and its principles are reflected in both actions and established procedures. We will gradually achieve our goals by means of systematic and continuous improvements.

Valid for

This policy applies to all the Group's farming operations.

Definitions

Cleaner fish: Wild-caught or farmed species in the Labridae family or farmed wrasse (Cyclopterus lumpus) used for biological delousing.

Biological delousing: Combating lice in marine production of salmon and trout using fish species that eat lice.

 

Framework and principles

The framework and principles follow, as a minimum, the provisions of the Norwegian Animal Welfare Act and the Regulations concerning aquaculture operations. We do our utmost to ensure proper welfare by:

  • Having personnel dedicated to cleaner fish who provide daily follow-up
  • Facilitating natural behaviour by creating a good habitat
  • Offering feed with customised nutritional contents
  • Promoting good health via preventive measures
  • Providing the same health care as that for salmon and trout

We also strive to avoid the use of more cleaner fish than deemed necessary to maintain good control of lice.

Roles and responsibilities

  • The management of LSG's Farming companies is responsible for ensuring implementation of this policy in daily operations in the respective companies. The fish health departments in the respective companies are responsible for carrying out inspections of the cleaner fish, in line with the inspections carried out for salmon and trout.

Policy ownership and implementation

  • The technical director for cleaner fish production (LSG) is the owner of and is responsible for updating this policy.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The management of LSG's Farming companies is responsible for implementing the policy in daily operations.
  • The COO of Farming is responsible for approval of this document.
Policies

Policy: Diversity and inclusion

Policy for diversity and inclusion

Owner/approver: Group Director HR

Valid from: 2021-04-29

 

Purpose

Lerøy Seafood Group ASA (Lerøy) has a goal to be the leading and most profitable global supplier of sustainable high-quality seafood. In order to achieve this goal, it is crucial to establish priorities and direction, and to clearly define what factors are strategically important for success.

For Lerøy, diversity and inclusion entail ensuring equal treatment of each employee, irrespective of gender, origin, ethnicity, skin colour, language, religion or personal philosophy.

One of Lerøy’s goals is to offer a workplace without discrimination of persons with disabilities. Lerøy aims to facilitate individually customised workplaces and tasks where possible for employees or applicants with disabilities. The Group has always emphasised the importance of individual competencies, performance and responsibility in their recruitment policy and payroll system.

Moreover, the Group shall at all times ensure equal employment opportunities and rights for all employees, both men and women. Lerøy has an international working environment and a number of employees from different nations. Several of our companies have multinational workforces.

In recent years, the Group has seen an increase in the ratio of females in what have traditionally been “male-dominated” professions, such as fish farming and wild catches. The same trend is evident in the different fields of study for the seafood industry. This will improve the gender balance in the industry Lerøy finds that its gender balance is positive for the psychosocial working environment.

Lerøy has recently seen an increase in the ratio of female employees in the companies both in Norway and abroad, and aims to further increase this ratio at all levels of the Group.

Valid for

This policy applies to all employees at Lerøy.

Interaction

Lerøy participates in various fora to discuss diversity and inclusion.

Roles and responsibilities

  • All those who work at Lerøy are responsible for positively ensuring diversity and inclusion.
  • The top management in each company is responsible for ensuring compliance with this policy, and that the organisation has appointed personnel with competencies who are assigned the task of ensuring compliance.

Policy ownership and implementation

  • The CHRO at Lerøy Seafood Group is the owner of this document, and is responsible for updates.  
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy. 
Policies

Policy: Escapes

Policy for escape prevention

Owner/approver: COO Farming 

Valid from: 2021-04-29

 

Purpose

The purpose of this policy is to provide a principal description of how the Group works to prevent escape. Preventing escape is an extremely important and high-priority area for Lerøy Seafood Group (Lerøy). Substantial investments are made to prevent escape.

Escape of farmed fish is an adverse incident for the environment and causes financial losses. The goal is to prevent escapees from having a negative impact on wild salmon. Lerøy therefore has a zero tolerance policy for escape.

Attitudes, procedures, emergency preparedness plans, the technical status of facilities, correct use of approved equipment and the right training shall ensure fulfilment of the zero-escape policy. Escape prevention is conducted by maintaining a focus on good planning, execution and re-examination of all operations in and at each facility. A lot of time and effort are also spent in optimising equipment and routines.

Valid for

This policy applies to all the Group's farming operations.

Framework and principles

Below is a description of the overall principles/legislation underlying this control strategy. Lerøy is committed to complying with prevailing environmental regulations, provisions, guidelines and principles, as follows:

The administration and the aquaculture industry, including Lerøy, have adopted a zero vision for escaped fish.

This strategy comprises knowledge, exchange of experience, a strong safety culture, efficient safety regulations and professional emergency preparedness.  The strategy is based on two principles:

  1. Escape-proof design and operation of aquaculture facilities and active risk management by the industry and administration to achieve maximum reductions in escapees.
  2. If farmed fish do escape, genetic interaction with wild stocks shall be kept to a minimum.

OURO, the aquaculture industry's association for catching escaped farmed fish

The association shall carry out assignments laid down in the Regulation dated 5 February 2015, no. 89 concerning joint responsibility for catches etc. of escaped farmed fish. These assignments comprise planning and executing initiatives to reduce the numbers of escaped farmed fish of the species salmon, trout and rainbow trout in rivers where the ratio of escaped fish is unacceptable. The association shall also consider planning initiatives to reduce the number of escaped farmed fish in rivers, where monitoring by means of annual percentages or counts of spawning fish indicate that the ratio of escaped farmed fish is equal to or greater than four percent.

Regulation concerning requirements on the technical standard of installations used for aquaculture (NYTEK) and Regulation concerning requirements on the technical standard of land-based aquaculture facilities for fish.

The purpose of these regulations is to limit escape from aquaculture installations by ensuring a proper technical standard for such installations, and proper operations and maintenance of the installations.

Regulation concerning internal control for compliance with the Aquaculture Act (IC-Aquaculture)

The purpose of this regulation is to ensure systematic control and improvement work so that requirements established in or in accordance with the Aquaculture Act are met. The regulation also states that a business shall chart hazards and problems and, on this basis, assess risk then prepare plans and initiatives to reduce these risk factors.

Roles and responsibilities

  • All Lerøy employees in Lerøy’s fish farming companies, within their areas of responsibility and disciplines, are responsible for following the policy.
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.

Policy ownership and implementation

  • The COO Farming is the owner of this document, and is responsible for updates and maintenance.
  • The COO Farming is responsible for implementation of and compliance with the policy.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the
Policies

Policy: Freshwater use

Policy for use of freshwater

Owner/approver: Head of ESG & Quality

Valid from: 2021-04-29

 

Purpose

Lerøy Seafood Group (Lerøy) shall take measures to minimise our impact on local water sources and the surrounding environment that we directly and indirectly use in our operations. Sustainable management of these water sources is important to ensure continued operations and a sound business model.

The world’s dependency on access to clean, high-quality freshwater has never been greater. Freshwater is a renewable resource. In some areas of the world, however, the use of freshwater may exceed the natural processes that refill the water magazines. Water stress or water depletion in individual areas may have a negative impact on our  operations and business and on society in general. Access to freshwater for our operations is essential for the following reasons:

  • We rely on freshwater for our smolt production operations.
  • Our processing operations are dependent on clean freshwater to uphold hygienic standards.
  • Our workers and local communities need access to clean drinking water and sanitation.
  • Raw materials for salmon feed are sourced from agriculture

According to The World Resource Institute’s (WRI) Aqueduct Water Risk Atlas, 2019, no areas in Norway, where all of our water-intensive operations (smolt production) are located, are categorised as being at risk of water stress or water depletion. Some of our processing plants in Europe are located in areas where there are medium water stress or water depletion risks. None of our operations are located in high risk areas according to the WRI.

Our main actions to ensure sustainable management of and minimal impact on water bodies/sources are as follows:

  • Implementation of RAS technology in our smolt operations. RAS technology can reduce our water usage by 99% per location.
  • Investment in, and Implementation of water-saving equipment and technology at our processing plants.
  • Communication and cooperation with the local government to ensure good water management.
    • Our operations must not result in denying any local communities access to clean freshwater.
  • Training of own personnel who manage risk and control our water usage at water-intensive locations.
  • Improving our systems for reporting of freshwater usage and wastewater in the Group.
  • Ensure that wastewater treatments at our locations are in accordance with applicable legislation.
  • Strive to use the best solutions and technology available to ensure that local habitats, wildlife and ecosystems are not affected negatively.
  • Ensure that Lerøy does not pollute any freshwater sources.

Valid for

This policy is applicable to all employees at Lerøy.

Definitions

Water stress: Baseline water stress measures the ratio of total water withdrawals to available renewable surface and groundwater supplies.

Source: WRI Aqueduct 2019

Water depletion: Baseline water depletion measures the ratio of total water consumption to available renewable water supplies.

Source: WRI Aqueduct 2019

WRI, Aqueduct Water Risk Atlas; https://www.wri.org/aqueduct

 

Framework and principles

  • Regulation concerning water supply and water intended for human consumption [Drinking water regulations]
  • Act relating to river systems and groundwater [Water Resources Act]
  • Regulations relating to pollution control [Pollution regulations]

Roles and responsibilities

  • All employees are responsible for complying with this policy.
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.

Policy ownership and implementation

  • The Head of ESG & Quality is the owner of this document and is also responsible for updating the document.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Waste management and sorting

Waste management and sorting policy  

Owner/approver: Head of ESG & Quality 

Valid from: 2021-04-29

 

Purpose

Lerøy Seafood Group, hereby referred to as Lerøy, shall continuously work to reduce the non-organic -and organic waste produced throughout our value chain. This includes both hazardous and non-hazardous wastes. In addition we aim to continue our work to implement a circular waste economy. This is reflected in our target to each year Increase our share of non-organic waste which is recovered, reused or recycled, and our target to reduce our food waste every year.

Lerøy have in recent years been in the forefront in regard to commitment and actions taken to clean our beaches for waste. We will continue our efforts as we see that the local engagement is significant and that our joint efforts are producing good results.

Our program for fishing for litter will also continue in the foreseeable future. We aim to Increase the uptime where our fleet collect wastes from our Ocean, and make sure that this waste is handled and disposed of in a sustainable way.

It`s becoming increasingly important to have dialog with waste handling contractors and local authorities regarding waste handling. To be able to reach our targets we need to collaborate to make sure that as much of our waste as possible are being handled in a sustainable manner. Through several different initiatives on waste handling and management we aim to Increase our knowledge and our Influence on decision-making bodies to make sure that our waste is handled and disposed of in a sustainable manner.

Lerøy encourage all employees to sort their waste also at home in a sustainable manner.

Valid for

This policy is applicable for all employees in Lerøy.

Definitions

Hazardous waste: waste that pose a substantial or potential severe threat to public health or environment.

Non-Hazardous waste: Waste that does not pose a direct threat to public health or environment.

Framework and principles

  • Forskrift om gjenvinning og behandling av avfall (avfallsforskriften)
  • Waste framework Directive (EC 2008/98)
  • Shipment of waste (EC 1013/2016)
  • List of waste (EC 2014/955)

Roles and responsibilities

  • All employees have the responsibility to follow this policy.
  • The local management is responsible for the company having competent personnel who ensure compliance locally to the policy.

Ownership and implementation of policy

  • Head of ESG & Quality is the owner of this document and is responsible also for updating the document.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO in Lerøy Seafood Group has the overall responsibility for the policy.
  • The Group Waste Policy shall be available through the Group's quality management system.
Policies

Policy: Whistleblowing

Whistleblowing policy

Owner/approver: Group Director HR

Valid from: 2021-04-29

 

Purpose

Lerøy Seafood Group (Lerøy) has a goal to be the leading and most profitable global supplier of sustainable high-quality seafood. In order to achieve this goal, it is essential to ensure that Lerøy's business results never take priority over compliance with prevailing acts and regulations and the Group’s Code of Conduct. Lerøy’s Code of Conduct reflects the Group’s fundamental values and guides the employees as to which principles to follow. 

Lerøy’s principal goals represent an organisational culture with a positive and constructive climate for freedom of speech. The whistleblowing regulations shall allow employees or externals to speak out and criticise without the risk of any kind of punishment or negative reaction.

All employees and externals are encouraged to report censurable conditions as this can help rectify such situations. All employees are obliged to report any criminal acts and situations involving a risk to life and health.

Whistleblowing

Whistleblowing is defined as reporting censurable conditions to a person with the authority to do something about it. Employees or externals who are willing to whistleblow represent an important resource for Lerøy. 

The term “censurable conditions” is defined as situations that violate rules of law, the Group's Code of Conduct or ethical standards, for example situations that may represent:

  • a risk to life or health
  • a risk to the climate or environment
  • corruption or other economic crime
  • abuse of authority
  • unsatisfactory working environment (e.g., HSE, bullying, discrimination)
  • breach of personal data privacy (GDPR)

Statements relating to issues that only apply to the employee’s own working conditions, such as professional disagreements and terms, are not defined as whistleblowing.

Whistleblowing channels

People can whistleblow orally or in writing, with their full name or anonymously. Lerøy have both an external whistleblowing channel for persons outside the company and an internal whistle blowing channel for employees  The whistleblowing report should contain relevant information, including persons involved, any witnesses and relevant evidence.

Employees who reports  reports orally, shall as a main rule contact their immediate superior. If this feels difficult, the employee can contact their immediate superior’s manager, the local HR Department or the local employee representative/safety representative. Oral whistleblowing reports are registered in Lerøy's digital whistleblowing channel by the person who receives the report.

Lerøy has established a digital channel for whistleblowing, which allows persons to remain anonymous. Whistleblowers who choose to be anonymous should note that they will not receive feedback regarding follow-up and management of the report.

Employees and externals are encouraged to whistleblow with their full name, as anonymous whistleblowing may complicate management of the case and prevent clarification of and reaction to censurable conditions. Normally, whistleblowing with full name will help improve proceedings and provide a better result for all parties involved.

Follow-up of whistleblowing and protection against retaliation

Initially, whistleblowing reports received via the digital channels will be processed by an independent third party, who will evaluate whether the report represents censurable conditions. The third party then makes a recommendation for further processing by Lerøy’s whistleblowing committee.

The whistleblowing committee covers all Group companies, in order to coordinate processing and implementation of action in the event of nonconformances. The procedure for investigations will depend on the nature and severity of the case, and is flexible to cover the wide diversity of possible whistleblowing cases. If necessary, external resources are contracted.

The whistleblower shall receive feedback within 14 days to confirm that the report has been received and to provide information on proceedings.

All parties involved in a whistleblowing case shall be protected. Retaliation against employees or externals who whistleblow is prohibited. Any person who feels that they have been subject to retaliation after whistleblowing must report this in Lerøy's digital whistleblowing channel.

Confidentiality

The whistleblower’s identity and all information relating to a whistleblowing report are treated as confidential information throughout the process. It is important to note that anonymity cannot be guaranteed for whistleblowers and others if the case results in legal proceedings. 

Case management will be carried out in accordance with the prevailing legislation covering personal data and privacy.

Reports

Lerøy’s whistleblowing committee shall issue quarterly reports on the status of whistleblowing cases to the Group management and Board of Directors.

Valid for

Applies to all employees and contract labour at Lerøy.

Framework and principles

Chapter 2A of the Norwegian Working Environment Act

Lerøy's Code of Conduct and whistleblowing poster

Roles and responsibilities

  • All employees at Lerøy are responsible or complying with the policy and for contributing towards creating and sustaining a proper and safe working environment.
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.
  • Managers shall provide guidance for employees who wish to whistleblow.

Policy ownership and implementation

  • The CHRO at Lerøy Seafood Group is the owner of this document, and is responsible for
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Procurement

Procurement Policy

Owner/approver: Head of Procurement 

Valid from: 2021-04-29

 

Purpose

Lerøy Seafood Group, Lerøy, and its daughter companies must always act in accordance with good business ethics and ensure high ethical standards regarding procurement. The purpose of this policy Is to outline the overarching procurement principles and standards used to set direction within the Group.

Procurement shall, as far as possible, be based on competition and any deviation from this requirement must be justified. This policy shall adhere to the Group's overall Code of Conduct.

This policy shall ensure that procurement processes are managed in a uniform way and this policy applies to all Lerøy`s companies globally.

Scope

The procurement policy applies to all Lerøy Seafood Group personnel and subsidiaries (hereinafter named Companies) Including but not limited to companies or contractors representing the Group which are Involved In procurement activities. Adhering to this policy is mandatory.

Definitions                                                                                                

Best Total Offer: The tender that provides the overall best value for the Group based on predetermined evaluation criteria

Group Procurement Policy: this document as amended from time to time

Head of Procurement: Group's designated Head of Procurement

Procurement: The process of selecting a supplier to provide; service and / or goods based on market competition

Tender: a received offer as part of a tendering process

Tenderers: Meaning the participants in a tendering process

Tender process: Meaning a procurement process

Main Principles and frameworks

Procurement shall as a main principle be based on competition and minimum 3 suppliers shall be Included In procurement processes when possible. Procurement shall be based on the Global Procurement Procedure.

All procurement processes shall be based on fair competition and shall be in accordance with Lerøy Seafood Group's overall vision relating to openness, honesty, responsibility and creativity. Independence and impartiality shall always be practised, meaning that persons with close relations / ties to one of the tenderers cannot take part in the procurement process, final evaluation, or selection for awarding a contract.

Strategic procurement processes shall be based on multidisciplinary tendering teams and the Best Total Offer will be basis for contract award, the evaluation result being a combination of the commercial and technical evaluation results.

Procurement processes shall be based on the Group's Procurement Process that Is available from the Group's quality management system.

The selection of qualified tenderers and evaluation shall be based on objective and non-discriminatory criteria. The following evaluation criteria may be used, but not limited to:

  • Sustainability
  • Quality
  • Competence and experience
  • Technical specifications
  • Functional requirements
  • Commercial elements

The above criteria are not listed in order of priority.

When awarding a contract, a written contract shall always be concluded between the Company and the chosen supplier. As a general principle the contract shall be based on Lerøy Seafood Group's Standard Terms for procurement when possible.

Only personnel Identified in approved authorisation matrixes can sign contracts.

Sustainability

Sustainability Is one of the main pillars of Lerøy Seafood Group and during procurement processes sustainability shall always be Included as part of the evaluation process. Therefore, Lerøy Seafood Group seek suppliers whom can generate the greatest value creation with the least environmental Impact.

Contract administration and Continuous Improvement

Contract administration Is an Integral part of the Global Procurement Process In Lerøy Seafood Group and shall focus on continuous Improvement to add value for both the Companies and the suppliers. To achieve continuous Improvement  efficient and open communication must be established with Identified suppliers and Key Performance Indicators may be Implemented to established common goals.

Monitoring of compliance

The Companies’ management team shall monitor and assure that the Company's respective procurement personnel adhere to the Group's Procurement Policy. If deviations are Identified this shall be reported to the Company`s General Manager and Head of Procurement in LSG.

The Group's quality department may, in cooperation with Group procurement, perform ad-hoc auditing of the Companies compliance with the Global Procurement Policy. If non-conformances are Identified, mitigating actions shall be Implemented and the non-conformances shall be handled as soon as possible.

Demand to our suppliers

All Lerøy Seafood Group's suppliers shall accept to participate In the Group's supplier monitoring system and answer the requested questions honestly and within the requested timeframe. This Is part of the Group's overall responsibility to assure Its supervisory responsibility "påseplikten" related to Its value chain. If such requests are not followed, the local procurement team shall take necessary actions to close any outstanding non-conformances.

The extent of monitoring performed Is based on the assessment of risk related to the category the supplier Is part of.

 

Roles and Responsibilities

  • Employees that participate In procurement processes are responsible for following Policy.
  • Local management shall assure that the Policy Is Implemented locally and that It Is being adhered to. If requested, Head of Procurement shall participate In the Implementation.
  • The Group's procurement organisation shall provide necessary Instructions and training to ensure that the Companies are familiar with the Global Procurement Policy, the Global Procurement process and the Global Procurement Procedure.

 

Ownership and implementation

  • Head of Procurement is owner of the Procurement policy In the Group and is responsible for updating the document.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO in Lerøy Seafood Group has the overall responsibility for the policy.
  • The Group Procurement Policy shall be available through the Group's quality management system.
  • Group Procurement training modules will be available In English through the Group's e-learning platform.
Policies

Policy: Fish feed

Fish feed policy

Owner/approver: COO Farming 

Valid from: 2021-04-29

 

Purpose

The purpose of this policy is to specify guidelines for the requirements and goals stipulated by Lerøy Seafood Group (Lerøy) for finished feed and feed raw materials, in terms of environmental, social and financial sustainability.

Valid for

This policy applies to all employees who carry out work involving fish feed at Lerøy.

Definitions

Lerøy covers all wholly or partly owned subsidiaries and collaborating companies within fish feed purchases.

 

Framework and principles

Marine raw materials shall originate from responsibly regulated fisheries, with individual species governed in accordance with the regulations laid down by national and international authorities and quotas specified on the basis of scientific recommendations (HI, ICES, FAO, IMARPE, CERNAPESCA etc.). We do not accept species that are on the UN’s list of endangered species (the CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora) or classified as critically endangered or endangered on the IUCN Red List of Threatened Species. The supplier shall comply with and follow the prevailing ASC standard for all marine raw material deliveries to Lerøy. Lerøy also aims to increase the share of MSC certified marine raw materials, year by year.

Vegetable raw materials shall originate from land-based production in areas sustainably obtained for such production. The supplier shall not make use of suppliers that are involved in burning/destroying rain forests/mangrove forests. Vegetable raw materials shall be certified in accordance with an internationally approved standard for sustainability, if such exists.

If soy is used in the feed, this must originate from producers who have full traceability throughout the value chain, and suppliers who have specified a cut-off date for deforestation (Brazil).  All soy from Brazil must have ProTerra certification.

When evaluating new raw materials that do not naturally belong to the above-mentioned categories, the raw material's level of sustainability shall be thoroughly and comprehensively assessed, and a written in-house report shall be prepared, supported by documentation from the producers. Lerøy has taken an active choice in relation to establishing new sources for raw materials for feed, and shall continue to lead the way in the development of new, circular raw materials. These do not have to have full certification at the time of use.

All raw materials shall be covered by a tracking system, providing a full overview at all times of the raw material used (down to species and catch/production area) and where the feed containing these raw materials has been used.

Lerøy does not make use of GMO raw materials, palm oil, ethoxyquin, raw materials from salmonids, Land Animal Proteins (PAP/LAP's) or fat sources from land animals.

Feed shall at all times comply with the Group's different fish farming certificates, such as organic production, Lerøy Salmon TM and ASC production.

Lerøy aims to minimise greenhouse gas emissions throughout the value chain. Raw materials for fish feed represent a significant factor in terms of greenhouse gas emissions, and Lerøy therefore aims to focus on raw materials that help us achieve our climate goals.

 

Roles and responsibilities

  • All employees involved in feed developments, feed specification developments, feed purchases and other tasks related to feed are responsible for following the policy.
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.

Policy ownership and implementation

  • The Technical Manager is the owner of this document, and is responsible for updates.
  • The COO Farming is assigned principal responsibility for the policy and is also responsible for ensuring its implementation and compliance.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Human rights

Policy for human rights

Owner/approver: Group Director HR

Valid from: 2021-04-29

 

Purpose

Lerøy Seafood Group (Lerøy) has a goal to be the leading and most profitable global supplier of sustainable high-quality seafood. In their efforts to achieve this goal, Lerøy is mindful of their social responsibility, and aims to combine sound business management with clear responsibility for society and the environment. 

Lerøy shall contribute positively and constructively by influencing work on human rights, prevention of child labour and protection of labour rights, both within the Group, and in relation to suppliers, subcontractors and trading partners.

Human rights are an integral part of Lerøy’s Code of Conduct, which is obligatory for all employees. Contracts with suppliers and subcontractors shall include requirements for compliance with the relevant sections of Lerøy's Code of Conduct. As part of its improvement measures to achieve a responsible supplier chain, Lerøy has established a system to ensure systematic audits and follow-up of suppliers.

Regular employment

Obligations in relation to the employees, in line with international conventions and/or national legislation and regulations regarding regular employment shall not be evaded via utilisation of short-term positions (such as use of contract workers, casual workers and day workers), subcontractors or other employment relationships. 

All employees are entitled to an employment contract in a language they understand. The apprenticeship programme shall be clearly defined in terms of duration and content.

Child and youth labour

Children under the age of 18 shall not perform work that represents a health or safety hazard, including night shifts. 

Children under the age of 15 shall, as a main rule, not be employed. In special circumstances, such as local/traditional factors, exemptions can be made down to the age of 13.

Apprentices complete those assignments and follow the working hours specified for the company at any given time.

Guidelines for work performed by children shall be followed.

Salary 

Salaries paid to employees shall as a minimum comply with the national provisions regarding minimum wage or the industry standard, and shall always be sufficient to cover basic needs.  

Payroll conditions and payment of salary shall be agreed upon in writing before employment starts. This agreement shall be in a format which the employee can understand. Disciplinary deductions from salary are not permitted. 

Working hours

Working hours shall comply with national legislation and shall be in accordance with prevailing international conventions. 

Trade unions and collective bargaining

Without exception, employees shall be entitled to join or establish trade unions according to their free will and to bargain collectively. The employer shall not discriminate against trade union representatives or prevent them from performing their duties for the trade union. Should this entitlement be limited by law, the employer shall facilitate for and not at any time prevent parallel mechanisms for free and independent organisation and bargaining.

Forced labour

All forms of forced labour, slave labour or involuntary labour are strictly prohibited.

Employees shall not be obliged to submit a monetary deposit or identity papers to the employer and shall be free to terminate their employment with a reasonable period of notice. 

Discrimination

All forms of discrimination at work based on ethnicity, religion, age, language, disability, gender, marital status, sexual orientation, trade union membership or political beliefs are strictly prohibited. 

Measures shall be established to safeguard against sexual harassment, threatening, insulting or exploitative behaviour and to prevent discrimination or dismissal on unfair grounds.  

Physical cruelty

Physical cruelty or punishment, or threats of physical cruelty, are strictly forbidden. The same applies to sexual or other abuse and different types of humiliation. 

Interaction

Lerøy participates in various fora to discuss human rights.

Valid for

All employees and contract labour shall comply with this policy.

We expect our suppliers and business partners to conduct themselves in line with the policy's purpose, and to respect all internationally recognised human rights principles.

Definitions 

None

Framework and principles

  • Lerøy’s Code of Conduct
  • The United Nations Global Compact principles on Human Rights, Labour, Environment and Anti-corruption
  • The International Labour Organization’s declaration of fundamental principles and rights at work
  • Local labour laws

 

Roles and responsibilities

  • All those who work at Lerøy are responsible for positively ensuring human rights. Human rights are an integral part of the Group’s Code of Conduct, which is obligatory for all employees.
  • The top management in each company is responsible for ensuring compliance with this policy, and that the organisation has appointed personnel with competencies who are assigned the task of ensuring compliance.

Policy ownership and implementation

  • The CHRO at Lerøy Seafood Group is the owner of this document, and is responsible for updates.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Food waste

Food waste policy

Owner/approver: Head of ESG & Quality 

Valid from: 2021-04-29

 

Purpose

A total 7% of global emissions are caused by food waste. 38% of total energy consumption within global food production can be attributed to food lost from the value chain or thrown away. Lerøy Seafood Group (Lerøy) is committed to reducing food waste in the Group by 50% by 2030. The purpose of this policy is to describe how Lerøy shall take efforts to reduce food loss and food waste throughout the value chain.

Lerøy shall strive to achieve the ambition, throughout the value chain, for 1 kg fish to equal 1 kg of product for consumption.

Farming

Strive to increase survival for salmon and trout in order to reduce food loss and to ensure that the highest possible volume of the fish is processed for human consumption.

Wild Catch 

Strive to preserve as much as possible of residual raw materials and to produce meal, oil and ensilage.

VAP, Sales and Distribution

Strive to utilise the entire fish for products for human consumption and to reduce the number of fish that fall on the floor, non-utilised input factors and unsold products. We shall take efforts to provide the longest possible and appropriate shelf life for our products, and shall make use of new technology to increase shelf life.

Valid for

All Lerøy employees

We also encourage our employees to reduce the amount of food they throw away at home.

Definitions

- Food waste: Edible parts of food produced for human consumption, but which are either thrown away or removed from the food supply chain for other purposes than human consumption after harvesting

- Food loss: Edible parts of food produced for humans, but which are either thrown away or removed from the food supply chain before or during harvesting

Framework and principles

The EU’s Farm to Fork strategy

Roles and responsibilities

  • All Lerøy employees within their areas of responsibility and disciplines are responsible for following the policy. 
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations. 

Policy ownership and implementation

  • The Head of ESG & Quality is the owner of this document, and is responsible for updates. 
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy. 
Policies

Policy: Climate and energy consumption

Climate and energy consumption policy

Owner/approver: Head of ESG & Quality 

Valid from: 2022-04-08

 

Purpose

Lerøy Seafood Group (Lerøy) has an ambition to be the leading and most profitable global supplier of sustainable high-quality seafood. In order to achieve this ambition, it is crucial to establish priorities and direction, and to clearly define what factors are strategically important for our success.

This policy provides a brief and principal description of how Lerøy shall carry out responsible environmental and climate management for the company’s activities and its business partner's activities.

Lerøy is committed to the further development of targeted environmental work, thus contributing to helping solve global challenges regarding climate change. Lerøy shall send clear signals to the market communicating that a climate-neutral low carbon economy by 2050 is an achievable and beneficial target.

Lerøy shall take active measures to identify new and innovative solutions to help cut the company’s greenhouse gas emissions, to further develop existing collaborations and find new partners to help us achieve our climate goals and help developing low carbon society.

The company shall take action to prevent operations from inhibiting an optimally stable climate, by measuring, monitoring, reporting and reducing the company’s carbon footprint. The Company shall report its Scope 1, 2 and 3 emissions in accordance with the Greenhouse Gas Protocol (GHG).

 Lerøy shall take comprehensive measures and commit to establishing climate targets for all operations throughout the value chain.

Lerøy has committed to a Science-based target which is aligned with the climate targets of the Paris Agreement (2015), and willingly accepts the responsibility to do its share towards limiting global warming:

  • The company is committed to 46%  GHG emission reductions (Scope 1+2+3) by 2030, with 2019 as a base-year. (The 1.5 degree target)

Lerøy shall regularly map climate-related risk, carry out assessments and analyses for further decisions and  make necessary adjustments.

Valid for

This policy applies to all employees and workers in the Group. Contracts with business partners operating in relation with Lerøy shall include requirements for compliance with the contents of this policy.

Definitions

Scope 1 – All direct greenhouse gas emissions from use of fossil fuels for own operations.

Scope 2 – Indirect emissions from purchased electricity and district heating/cooling.

Scope 3 – Indirect emissions from input factors (purchased goods or services).

Science-Based Targets – Targets based on what research has shown to be necessary to reach the targets in the Paris Agreement. The targets must therefore help limit global warming to well below 2°C, and strive to limit global warming to 1.5°C.

Employee - an individual who is in an employment relationship with the organization, according to national law or its application. Employees have a written employment contract directly with the organization.

Worker – an individual who performs work for a certain period of time (for example, seasonal workers etc.) and who is hired via manning agency. Workers have a written employment contract with manning agency.

Framework and principles

Lerøy is committed to complying with prevailing environmental regulations, guidelines and principles, defined in the following documents:

Greenhouse Gas Protocol (GHG Protocol) – comprehensive global standardized framework to measure and manage greenhouse gas (GHG) emissions from private and public sector operations, value chains and mitigation actions.

Paris Agreement  2015 – An international agreement to ensure that countries worldwide are able to limit climate change.

 ISO 14001 : 2015 Environmental management systems – Requirements with guidance for use (ISO 14001 : 2015).

 ISO 14064 : 2018 Greenhouse gases – Part 1: Specification with guidance at the organization level for quantification and reporting of greenhouse gas emissions and removals.

Roles and responsibilities

  • Lerøy’s top management is responsible for defining the company’s climate and environmental direction, and is responsible for the contents of this policy.
  • All Lerøy employees and workers, within their areas of responsibility and disciplines, are responsible for contributing towards achievement of the company's climate goals.
  • The local management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with relevant local regulations.

Policy ownership and implementation

  • The Head of ESG & Quality is the owner of this document, and is responsible for updates.
  • The policy has been approved by the Corporate Management at Lerøy, and is presented to the Group's Board of Directors.
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Fish health and fish welfare

Fish health and fish welfare policy

Owner/approver: COO Farming

Valid from: 2022-03-29

 

Purpose

Lerøy works continuously to adapt all parts of production in order to ensure optimal fish welfare. Keeping fish in cages entails responsibility for ensuring that the fish have the best possible conditions. As part of our ongoing improvement measures, we make use of several international standards relating to fish welfare and biosafety.

Valid for

This policy applies to all the Group's farming operations.

Definitions

Animal welfare: Quality of life perceived by the animal itself.

Welfare indicator: An indirect measurement of animal welfare.

Cleaner fish: Wild-caught or farmed species in the Labridae family or farmed wrasse (Cyclopterus lumpus) used for biological delousing.

Biological delousing: Combating lice in marine production of salmon and trout using fish species that eat lice.

Framework and principles

We make use of procedures as governance tools for production. These procedures help us standardise the processes to which the fish are subjected, and they are updated as soon as we obtain new knowledge that has to be taken into account. As such, the entire organisation has rapid and efficient access to new knowledge.  The following elements are key to our work on fish welfare:

  • Water quality and volume shall be adapted to the requirements for fish at different life stages and for different species.
  • Nutrition shall be customised to fish species and life stages.
  • The cleaner fish shall have a good habitat, allowing for natural behaviour.
  • We also strive to avoid the use of more cleaner fish than deemed necessary to maintain good control of lice.
  • Antibiotics shall not be used to promote growth.
  • Breeding shall focus on producing robust fish with increased resistance to different infectious factors.
  • Employees who work with fish shall have sufficient competencies in order to safeguard good fish welfare.
  • Moribund and weak fish shall be removed from the production units as quickly as possible and put down in an appropriate manner.
  • Active measures are required to prevent infection in our facilities or transfer of infection to other facilities.
  • All fish shall be vaccinated as appropriate for the areas where they are to be released.
  • At all facilities, authorised fish health personnel shall regularly monitor the fish to check on health status and to take immediate action when necessary.
  • All devices and equipment shall be designed in a way to ensure good fish welfare.
  • All slaughtering facilities we utilise make use of a blow to the head or shock, followed by cutting, as the method of slaughter. This process is also monitored manually as an extra control.
  • CO2 is not used as a slaughter method in any of our facilities.
  • As support to help us achieve our goals, we make active use of action plans at all levels in the value chain, and submit regular status reports on established KPIs.

 

Careful handling:

Lerøy takes all efforts possible to minimise handling of fish. Stress and impact on the outer barriers for the fish will most likely reduce how resistant the fish are to disease. We therefore focus strongly on measures to reduce risk whenever we have to handle the fish, such as controlling changes in pressure and temperature and the amount of time and the extent to which fish are in crowded conditions. Minimising the amount of handling results in improved fish welfare and fish health, and is a key goal for the company.

 

Welfare indicators:

Systematisation and grading of different welfare criteria are carried out in accordance with the guidelines in the following manual: “Velferdsindikatorer for oppdrettslaks: Hvordan vurdere og dokumentere fiskevelferd” (Welfare indicators for farmed salmon: How to assess and document fish welfare). This publication is the end product of the “FISHWELL” project financed by the Norwegian Seafood Research Fund (FHF) and conducted by Nofima.

The welfare indicators registered daily are temperature, oxygen, growth, density and category for cause of death. The welfare indicators we measure at regular intervals are lice, gases, salinity, visibility, current, vaccine side-effects, outer blemishes, cataracts, gill status, algae, jellyfish, agents and sedimentation under the facility.

The different welfare indicators have provided us with the opportunity to objectively measure and compare the mutual implications of the different parameters and what they indicate about overall fish welfare. This allows us to make interventions in production in order to prevent factors that impair fish welfare.

Systematisation of welfare parameters for all organisations will provide a stronger basis on which to compare different production methods. Machine learning and increased opportunities for analysis of large volumes of data in a short time could possibly represent a positive move towards identifying better solutions for improved fish health and fish welfare.

Roles and responsibilities

  • All employees who work with live fish at Lerøy are responsible for ensuring good fish welfare. Fish health personnel are responsible for ensuring that all employees have the right focus and necessary training so as to provide for good fish welfare. Production employees are responsible for daily execution and for ensuring that the decisions made are based upon correct values.

Policy ownership and implementation

  • The management of the various departments is responsible for policy implementation and updates.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The policy is approved by Bjarne Reinert, COO Farming.
Policies

Policy: Algae monitoring

Algae monitoring policy

Owner/Approver: Head of fish health LSG/COO Farming

Valid from: 2022-03-02

 

Purpose

Algae naturally occur in Norwegian waters and are an important part of the ecosystem. Certain environmental conditions may result in individual incidences of large algal blooms. The algae may either produce toxins that are harmful to the fish or may be so prevalent that they clog the fish gills. Some algae also have a surface structure that harms the gills. If there is a high density of such algae, the fish will not be able to sustain normal gill function. Proper monitoring of algae incidence is important if we are to implement measures at the right time.

Valid for

This policy applies to all the Group's farming operations.

Definitions

Algae: Collective term for very different single-cell and multi-cell organisms that have photosynthesis and humid environments as common factors.

Framework and principles

The Institute of Marine Research carries out national monitoring of algae, and their information is available to the public on their website, algestatus.hi.no. The industry and authorities continue to take efforts to identify the optimal solution for comparison of data collected by the industry with the results of monitoring by the authorities. The aim is to obtain a better and more comprehensive algae monitoring system.

Lerøy's algae monitoring is based on risk periods and observations that indicate suspected algal bloom. If any findings seem suspicious, all involved parties in the area are notified.

If an algal bloom affects one of our localities, we have a clear plan of action describing what has to be done. Depending on the scope, rapidly implemented measures will help reduce the impact on the fish. In some cases, it may be necessary to clarify with the authorities and other parties whether the fish can be moved from the area affected.

Roles and responsibilities

  • Personnel working with fish health and production at Lerøy are jointly responsible for assessing the level of monitoring and possible measures to combat episodes of algal bloom that affect a locality.
  • The management of the various departments is responsible for policy implementation and updates

Policy ownership and implementation

  • The policy is approved by Head of fish health LSG
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by the Board of Directors
  • The COO Farming has the overall responsibility for the policy.
Policies

Policy: Plastic

Plastic policy

Owner/approver: Head of ESG & Quality 

Valid from: 2021-04-29

 

Purpose

Every year, more than eight million tonnes of plastic end up in the sea. Plastic in itself becomes a problem when it is carelessly disposed of and ends up as microplastic in the sea. Plastic should never, under any circumstances, end up in the natural environment.

Lerøy Seafood Group (Lerøy) is dependent upon clean seas to produce safe and sustainable products.


We are very much aware of our responsibilities, and this policy has been prepared to ensure that Lerøy reduces its plastic consumption in areas where there is the greatest risk of plastic pollution. Moreover, Lerøy shall preferably make use of recyclable plastic. If there are alternative materials to plastic that meet technical requirements and are more sustainable, these shall have preferential use. Plastic waste shall be sorted at source to minimise environmental impact.

For every 1 kg reduction in plastic, we save 5 kg CO2e.

We shall:

General:

  • Replace plastic with a different and sustainable material that meets the technical requirements in areas where we currently use plastic and there is a high risk that the plastic will be inappropriately discarded
  • Make use of plastic that is preferably recyclable
  • Preferably use recycled plastic in plastic that is not in direct contact with food
  • Do not use more plastic than required for individual purposes
  • Sort plastic at source
  • Maintain an overview of plastic purchased and of waste management or recycling of these types of plastic
  • Try to make use of biodegradable plastic where there is a risk of inappropriate discarding. Biodegradable plastic is, however, sorted as residual waste and requires specific assessment in other areas.
  • Play an active role in removing plastic from the natural environment, and encourage employees to do the same
  • Encourage our partners to contribute to the fight against plastic pollution

 

On products:

  • Lerøy shall take the initiative together with the customer to reduce plastic consumption
  • Products shall have the optimal percentage of filling in order to reduce plastic consumption
  • Plastic used shall preferably be recyclable
  • Black plastic shall not be used and shall be phased out due to problems at recycling stations with optical sorting
  • Lerøy shall take measures to identify sustainable packaging alternatives to plastic.

 

Valid for

This policy applies to all employees.

 

Definitions

  • Recyclable plastic – plastic material that can be recycled to create new plastic products
  • Bio-based plastic is made of corn, starch etc. that is degraded using micro-organisms
  • Percentage of filling – ratio between product volume and packaging volume
  • Black plastic – packaging coloured carbon black that cannot be detected by sorting machines

 

Framework and principles

Directive 2019/904 of 5 June 2019 on the reduction of the impact of certain plastic products on the environment
2002/72/EF (Plastic Directive).
Directive 2002/72/EF relating to plastic materials and articles intended to come into contact with foodstuffs

Roles and responsibilities

  • All employees, but particularly those working with purchasing, product development and packaging, are responsible for following this policy.
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.

Policy ownership and implementation

  • The Head of ESG & Quality is the owner of this document, and is responsible for updates.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Food safety

Food safety policy

Owner/approver: Head of ESG & Quality 

Valid from: 2021-04-29

 

Purpose

Lerøy Seafood Group (Lerøy) shall deliver safe and sustainable high-quality seafood in every part of the value chain. We are committed to never compromising on food safety for any of our products or services. This requires all our employees to be dedicated and to comply with a strong food safety culture, so that we are able to deliver safe and sustainable high-quality seafood every day, all year round.

As an integrated part of Lerøy's value chain, each company has its own Quality Department made up of personnel with expertise in food safety, who are assigned the task of continuously ensuring and securing that our products and services are safe.

We shall have:

 

  • Up to date hazard analysis with measures to reduce or eliminate the risks
  • In-house audits, external audits, supplier evaluation, control of input factors and packaging
  • Online monitoring, control and trends for chemical and biological analyses
  • Full traceability for all products, with regular testing of recalls/withdrawals
  • Competencies and an understanding of risk within food safety culture
  • Further development and optimisation of hygienic design
  • Compliance with requirements for food safety in accordance with GFSI

Valid for

This policy applies to all employees at Lerøy.

Definitions

Food safety – Ensuring that food produced does not represent a risk for the consumer

Food safety culture – Attitudes, values and beliefs relating to food safety shared by a group of people

Framework and principles

Certifications: ASC, GlobalGAP, BRC, IFS, FSSC22000

Legislation:  The Norwegian Food Act – General Food law regulation

Roles and responsibilities

  • All Lerøy employees within their areas of responsibility and disciplines are responsible for following the policy.
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.

Policy ownership and implementation

  • The Head of ESG & Quality is the owner of this document, and is responsible for updates.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Health, safety and environment

Policy for Health, Safety and the Environment (HSE) management

PURPOSE

Lerøy Seafood Group ASA (Lerøy) has the ambition to be the leading and most profitable global supplier of sustainable high-quality seafood. In order to achieve this ambition, it is crucial to establish priorities and direction, and to clearly define what factors are strategically important for success.

This policy provides a brief and principal description of how Lerøy shall establish and further develop sustainable and proactive HSE management in relation to own activities and suppliers’ activities.

Lerøy shall implement active measures to create a positive and safe physical and psychological working environment. Prevention of injuries and accidents shall always have top priority in the Company. Lerøy and its activities shall organized in a manner which ensures that the employees are protected from harm to life and health. Systematic HSE measures shall be an integral part of all our activities.

The company shall ensure that employees receive necessary and regular HSE training, and shall make active contributions to reinforcing HSE awareness in the company.

Lerøy is committed to:

  • Defining goals and tasks for the company’s HSE activities;
  • Continuous identification, assessment and control of risk;
  • Measurement and assessment of registered HSE information;
  • Implementation of necessary measures to improve and boost the company’s HSE performance;
  • Support transparency and dialogue regarding HSE to achieve continuous improvement to our HSE efforts.

 

VALID FOR

This policy applies to all employees in the Group. This policy also forms the basis for Lerøy’s expectations with regard to suppliers and partners.

DEFINITIONS

HSE – Health, Safety and the Environment

Continuous improvement – Constant improvements, method to improve the quality of processes, development and management

FRAMEWORK AND PRINCIPLES

Lerøy is committed to complying with prevailing HSE regulations, guidelines and principles, defined in the following documents:

ISO 45001: 2017 Occupational health and safety management systems – Requirements with guidance for use

ROLES AND RESPONSIBILITIES

  • All employees at Lerøy are responsible for complying with the policy and for contributing towards creating and sustaining a proper and safe working environment.
  • The top management in each company is responsible for ensuring that the company has personnel with the competencies required to ensure compliance with local regulations.

POLICY OWNERSHIP AND IMPLEMENTATION

  • The Head of ESG & Quality is the owner of this document, and is responsible for updates.
  • The policy has been approved by the corporate management at Lerøy, and is presented to the Group's Board of Directors.
  • The CEO of Lerøy Seafood Group has overall responsibility for the policy.
Policies

Policy: Control of salmon lice

Salmon sea lice control policy

Owner/approver: COO Farming

Valid from: 2022-04-06

 

Purpose

Lerøy’s efforts to control salmon lice follow the principles of an IPM strategy to control salmon lice and keep the numbers at a low level in the long term. The goal is to reduce the negative impact on the environment and the need for active interventions. This policy provides a principal description of how the Group works to control salmon lice.

Valid for

This policy applies to all the Group's farming operations.

Definitions

Salmon lice: Lepeophteirus salmonis. A copepod and parasite living on salmon.

Integrated pest management (IPM): A control strategy with different complementary measures that supplement each other, aiming to control salmon lice and keep them at a low level. The core elements of an IPM strategy are prevention, monitoring and control.

 

Framework and principles

Lerøy’s efforts to control salmon lice follow the principles of an IPM strategy to control salmon lice and keep the numbers at a low level in the long term. The goal is to reduce the negative impact on the environment and the need for active interventions. Below is a description of the overall principles underlying this control strategy.

  1. Acceptable level: Requirements from the authorities provide a definition, at any given time, of the upper maximum limits for fully grown female The following statutory requirements currently apply:
    • Nord-Trøndelag and regions to the south shall, with effect from Monday in calendar week 16 and up to and including Sunday in calendar week 21 have less than 0.2 adult female lice on average per fish in the fish farms. With effect from Monday in calendar week 22 and up to and including Sunday in calendar week 15, there shall be less than 0.5 adult female lice on average per fish in the fish farms.
  • Nordland, Troms and Finnmark shall, with effect from Monday in calendar week 21 and up to and including Sunday in calendar week 26 have less than 0.2 adult female lice on average per fish in the fish farms. With effect from Monday in calendar week 27 and up to and including Sunday in calendar week 20, there shall be less than 0.5 adult female lice on average per fish in the fish farms.

Lerøy has also established their own limit values to provide guidelines for when to implement preventive and active measures to combat salmon lice.

  1. Preventive measures: Prevention is the first line of defence, aiming to control the levels of salmon lice by making use of passive control mechanisms. The methods utilised depend on local prerequisites, and entail use of one or more of the following measures:
    1. Structural measures relating to use of locality
    2. Coordinated operations over larger geographical areas
    3. Zone collaboration
    4. Fallow periods in between production cycles
    5. Smolt quality and smolt weight as measures to reduce period of exposure
    6. Use of various types of physical barriers
  2. Monitoring: All groups of fish are regularly monitored with a view to the incidence and development of salmon The purpose of monitoring is to ensure that the company operates at all times in accordance with regulatory requirements. Monitoring is also required to control salmon lice by providing data for continuous assessments performed by the company in relation to evaluating measures to control salmon lice. Monitoring is carried out per cage.
  3. Biological control: Cleaner fish represent a method for treatment prevention, and the goal is to reduce the need for active The use of cleaner fish depends on local prerequisites, is dynamic and adapted to conditions at individual localities.
  4. Active interventions: Active interventions are divided into the following categories:
  5. Non-medicinal methods: These methods are based on different types of measures that do not include the use of medicines. Lerøy makes use of methods within the categories for fresh water, flushing and temperate water.
  6. Medicinal methods: These methods are based on the use of medicines. In cases where medicines are utilised, these shall be 1) prescribed by authorised fish health personnel and 2) evaluated with a view to the risk for fish welfare, food safety, environment and resistance, and 3) where only medicines approved by Norwegian medicines authorities are used.

 

Roles and responsibilities

The policy is administered by the Group's subsidiaries, which are responsible for ensuring compliance in line with the descriptions provided.

Policy ownership and implementation

The management of the various subsidiaries is responsible for policy implementation and updates.

The policy is approved by Bjarne Reinert, COO Farming

Policies

Policy: Use of medication

Policy for use of antimicrobial agents

Purpose

Lerøy Seafood Group (Lerøy) emphasises the importance of preventive operating practice, aiming to reduce the number of incidences involving disease in fish. In certain situations, however, the disease and needs may require use of antimicrobial agents to treat disease in fish.

The purpose of this policy is to provide a principal description of how the Group approaches use of antimicrobial agents.

Valid for

This policy applies to all the Group's farming operations.

Definitions

Antimicrobial agents: Active substances used to treat bacterial infections and classified as medicines by Norwegian medicines legislation. Antimicrobial agents are only used when medical indications imply that they are needed.

Antibiotic resistance: The ability of bacteria to resist the effect of antibiotics. Antibiotic resistance is caused by use of antibiotics, and the most important measure in preventing the development of antibiotic resistance is to reduce the use of antibiotics.

 

Framework and principles

Use of antibacterial agents:

Lerøy aims to avoid unnecessary use of antimicrobial agents. To achieve this, a number of different preventive measures are implemented and are part of a preventive operating practice including vaccination, risk management, disease control, structural measures, early diagnoses etc.

The use of antimicrobial agents is seen as a last line of defence and only applied in situations where deemed necessary to protect fish welfare, and when factors relating to food safety, the environment, resistance and effect have been clarified.

Moreover, antimicrobial agents are only used when prescribed by authorised fish health personnel, and the only agents used are those approved by Norwegian medicines authorities.

Prevention of antibiotic resistance:

In situations that require the use of antibiotics, the risk of resistance development is managed by means of the following principles:

  1. Choice of agents:Bacterial isolates are tested with a view to sensitivity before treatment starts. Groups of agents classified by the WHO as Critically Important Antimicrobials for Human Medicine (CIA) or Medically Important Antimicrobials for animals that produce food (MIA) shall only be used when a professional assessment shows that this is the only possible method of treatment.
  2. Medication:Medication is only used when prescribed by authorised fish health personnel and according to their instructions.
  3. Retention period:A retention period before slaughter is established for fish treated with antibiotics. The retention period is stipulated by authorised fish health personnel, aiming to ensure that the level of agents in the product for human consumption is below the maximum residue limit (MRL). Residue amounts are documented by means of sampling.
  4. Use of protective equipment:All personnel administering and in close contact with antibiotics to treat fish shall wear protective equipment, such as clothing and respiratory masks, in order to prevent antibiotic resistance among the employees.
  5. Cleaning contaminated equipment and materials:Equipment that has been in contact with antibiotics shall be cleaned before it can be used again in production.

 

Roles and responsibilities

The policy is administered by the Group's subsidiaries, which are responsible for ensuring compliance in line with the descriptions provided.

 

Policy ownership and implementation

The management of the various subsidiaries is responsible for policy implementation and updates.

The policy is approved by Bjarne Reinert, COO Farming.

Policies

Policy: Marketing

Marketing policy

Owner/approver: Head of Brand & Marketing

Valid from: 2022-03-30

 

PURPOSE

The objective behind marketing of Lerøy's products is to maintain dialogue with consumers and other recipients, sending well-balanced and legitimate messages aiming to contribute to a healthier and more sustainable diet. With our planet under pressure and with a steadily increasing lack of balanced diet among the global population, Lerøy wants to inform and inspire, and to generate interest in eating more seafood for two reasons; to conduct sustainable production of protein and to improve public health.

The Group complies with all marketing regulations and requirements in terms of labelling and information on contents, while constantly aiming to provide inspiration for how to make simple and healthy meals. For Lerøy, it is important that the consumers feel safe when purchasing our products. We therefore label our products with relevant and appropriate certificates where suitable.

True and responsible communications, including:

  • Always able to document claims regarding both sustainability and health attributes
  • Zero use of misleading marketing
  • Zero use of speculative marketing
  • Ethical code for communications within prevailing regulations if communicating with younger target groups, < 18 years old
  • Zero use of specific marketing targeting children and adolescents to trigger sales
  • Constant compliance with prevailing legislation governing communications

Honest and open, including:

  • Compliance with the claims we make, including bias, if relevant.
  • Be open about both advantageous and less advantageous aspects of increased seafood consumption
  • Promote own products instead of putting down others
  • Be open about how we produce fish and administer natural resources
  • Disclose all aspects of product contents in terms of both prevailing legislation and regulations, but also when we believe the information is of value and of interest to consumers

Contribute to a healthier and more sustainable lifestyle, including:

  • Products directed at target groups with related content designed specifically for these. Provide information on recommended amount of different types of seafood.
  • We shall contribute towards a balanced diet, and refrain from giving the impression that consuming other foodstuffs may damage health.
  • All communications shall promote our own products as a part of a varied diet.
  • We shall make use of sponsorship to reach the younger segment of the market, introducing them to a well-balanced and healthy diet at an early age. This is an investment in health as well as our contribution to a more sustainable form of consumption.
  • Sponsorships and related marketing shall always be selected with a view to our values, and aiming to create a healthier population and more sustainable planet.

Applies to

The whole Group

Definitions

Sustainability, follows the definition laid down by the Head of ESG

Framework and principles

Brand Master 

Lerøy’s Code of Conduct

Lerøy’s sponsorship guidelines

 

Roles and responsibilities

All sales companies and all other parts of the Group involved in any type of product marketing.

Policy ownership and implementation

  • The ownership of the policy and its content lies with the document owner, Head of Brand & Marketing.
  • Web & Social Media Manager is responsible for ensuring that GDPR and communication via our digital channels are taken care of in accordance with current policy.

The implementation of this is in each individual marketing company that conducts some form of product marketing with the general manager of the individual marketing company as responsible.

Policies

Policy: Use of antimicrobial agents

Policy for use of antimicrobial agents

Owner/approver: COO Farming

Valid from: 2022-03-29

 

Purpose

Lerøy Seafood Group (Lerøy) emphasises the importance of preventive operating practice, aiming to reduce the number of incidences involving disease in fish. In certain situations, however, the disease and needs may require use of antimicrobial agents to treat disease in fish.

The purpose of this policy is to provide a principal description of how the Group approaches use of antimicrobial agents.

Valid for

This policy applies to all the Group's farming operations.

Definitions

Antimicrobial agents: Active substances used to treat bacterial infections and classified as medicines by Norwegian medicines legislation. Antimicrobial agents are only used when medical indications imply that they are needed.

Antibiotic resistance: The ability of bacteria to resist the effect of antibiotics. Antibiotic resistance is caused by use of antibiotics, and the most important measure in preventing the development of antibiotic resistance is to reduce the use of antibiotics.

 

Framework and principles

Use of antimicrobial agents:

Lerøy aims to avoid unnecessary use of antimicrobial agents. To achieve this, a number of different preventive measures are implemented and are part of a preventive operating practice including vaccination, risk management, disease control, structural measures, early diagnoses etc.

The use of antimicrobial agents is seen as a last line of defence and only applied in situations where deemed necessary to protect fish welfare, and when factors relating to food safety, the environment, resistance and effect have been clarified.

Moreover, antimicrobial agents are only used when prescribed by authorised fish health personnel, and the only agents used are those approved by Norwegian medicines authorities.

 

Prevention of antibiotic resistance:

In situations that require the use of antibiotics, the risk of resistance development is managed by means of the following principles:

  1. Choice of agents: Bacterial isolates are tested with a view to sensitivity before treatment starts. Groups of agents classified by the WHO as Critically Important Antimicrobials for Human Medicine (CIA) or Medically Important Antimicrobials for animals that produce food (MIA) shall only be used when a professional assessment shows that this is the only possible method of treatment.
  2. Medication: Medication is only used when prescribed by authorised fish health personnel and according to their instructions.
  3. Retention period: A retention period before slaughter is established for fish treated with antibiotics. The retention period is stipulated by authorised fish health personnel, aiming to ensure that the level of agents in the product for human consumption is below the maximum residue limit (MRL). Residue amounts are documented by means of sampling.
  4. Use of protective equipment: All personnel administering and in close contact with antibiotics to treat fish shall wear protective equipment, such as clothing and respiratory masks, in order to prevent antibiotic resistance among the employees.
  5. Cleaning contaminated equipment and materials: Equipment that has been in contact with antibiotics shall be cleaned before it can be used again in production.

 

Roles and responsibilities

  • The policy is administered by the Group's subsidiaries, which are responsible for ensuring compliance in line with the descriptions provided.

 

Policy ownership and implementation

  • The management of the various subsidiaries is responsible for policy implementation and updates.
  • The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by  the Board of Directors
  • The policy is approved by Bjarne Reinert, COO Farming.
Policies

Policy: Marine ecosystems and biodiversity

Marine ecosystems and biodiversity policy

Owner/approver: Head of  ESG & Quality 

Valid from: 2022-03-31

 

Purpose

The Food and Agriculture Organization (FAO) and the United Nations (UN) High Level Panel for a Sustainable Ocean Economy states that increased sustainable aquaculture production can contribute to both a healthier planet and healthier people. Aquaculture has seen an impressive growth in terms of its share of global seafood production and the supply of fish for human consumption.

Nearly a third of all monitored global fish stocks are overfished, and over 60% are fished to the maximum sustainable yield. Illegal and unregulated fishing is a huge problem too. And millions of non-target sea creatures (such as dolphins) are accidentally killed each year as ‘bycatch’ – caught unintentionally in fishing gear.

It is vital that this growth is coupled with preventive actions to avoid negative impact on the environment and aquatic ecosystems. Targeting challenges such as sea lice, accidental fish release and diseases will ensure efficient and sustainable production.

The growth in seafood production has also caused rapid growth in production of industrial aquaculture feeds. Feed has a large impact on the quality and sustainability of farmed seafood products, accounting for around 80 percent of total CO2 emission from aquaculture operations. There is therefore a considerable need for sustainable feed. If not managed or traced properly, feed production may cause harm to both marine and terrestrial ecosystems.

Principles for marine ecosystems and biodiversity

Our companies are expected to prevent and minimise negative impact on marine ecosystems. This entails that our companies only fish, buy and use in fishfeed, species from science-based managed and regulated fish stocks, and continuously work to employ processes, solutions and equipment that minimise our environmental footprint.

Certifications and regulations:

Our companies are expected to act in accordance with international best practice to protect endangered species and seek to comply with standards aimed at preserving biodiversity, such as GlobalG.A.P., MSC and ASC. Our companies are also expected to continuously evaluate the impact of their operations on marine ecosystems to make sure that they comply with local regulations. All our operations in sea in both farming and fisheries are licensed by regulatory authorities as required by local legislations to ensure that the operations are environmentally viable.

Accidental escaped:

Our companies are expected to have a continuous focus on preventing accidental release within our farming operations. As the ultimate goal is to prevent any fish from escaping, our companies are expected to do mitigating measures such as optimising equipment and routines.  Incidents of accidental release or events that may lead to accidental release are reported to the relevant fishery authorities and mitigating measures are implemented.

Monitoring seabed quality:

Our companies are expected to follow local regulations and constantly work to minimise the footprint on the seabed under our sea facilities. They are required to monitor seabed quality, which include carry out analysis prior to stocking a production site. MOM-B measurements involve taking samples from the seabed under and around the cages in a facility to conduct fauna, chemical and sensory investigations, and are done by a third party. MOM B is performed regularly to monitor how production on the site affects the sea bottom

Usage of raw material:

It is expected high focus on efficient use of scarce marine resources

Our companies are expected to increase the usage of raw materials certified according to sustainability standards and work closely with suppliers of feed ingredients in developing sustainable feed with smaller footprint

Feed ingredients:

The primary ingredients in our salmon feed are fish meal, soy protein, fish oil and canola oil. The Group only use non-GMO soy which is certified by the Round Table on Responsible Soy (RTRS). The soy is manufactured sustainably, and it is deforestation-free.  If the feed producer is buying soy that is not certified by a sustainability standard the supplier must prove that the soy fulfils the same requirements as certified soy.

Risk indicators

Reports from the companies given on a regular basis that include marine ecosystems and biodiversity indicators. For all extraordinary or precarious situations immediate reporting is mandatory

Applies to

All companies within Lerøy Seafood Group (LSG)

Definitions

MOM-B: Modellering – Overvåkning – Matfiskanlegg (Modelling - Surveillance - Fish farm)

 

Roles and responsibilities

All those who work in LSG are responsible for protecting marine ecosystems and for positively ensuring biodiversity. The top management in each company is responsible for ensuring compliance with this policy, and that the organisation has appointed personnel with competencies who are assigned the task of ensuring compliance.

Policy ownership and implementation

  • The Head of ESG & Quality in LSG is the owner of this document, and is responsible for updates.
  • The policy has been approved by the Management Group at LSG, presented to the Audit Committee and approved by the Board of Directors.
  • The CEO of LSG has overall responsibility for the policy.