Owner/approver: Group Director HR
Valid from: 2022-05-24
PURPOSE
Lerøy Seafood Group ASA and its subsidiaries (“Lerøy”) are committed to respecting internationally recognized human rights and labor rights in our own operations as well as in our value chain.
It is the policy of Lerøy to always comply with any applicable laws and regulations including internationally recognized conventions regarding the protection of human rights and decent work conditions.
Lerøy respects and supports the International Bill of Human Rights and the core conventions of the International Labor Organization (ILO).
Lerøy further endorse the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. Lerøy is a member of United Nations Global Compact.
Lerøy shall contribute positively and constructively by influencing work on human rights, prevention of child labor and protection of labor rights, both within Lerøy, and in relation to its suppliers, subcontractors and business partners.
The protection of human rights and decent work conditions are an integral part of Lerøy’s Code of Conduct, which applies to all employees, directors, officers, hired personnel, consultants, company representatives and any person conducting work on behalf of or otherwise representing Lerøy. All have the responsibility to understand and follow the standards as well as adhere to the principles outlined in the Code of Conduct.
Lerøy expects its suppliers, sub-contractors and business partners to conduct themselves in line with the policy's purpose, and to respect all internationally recognized human rights principles and fundamental employee rights as described above, as well as local legislations in their geographical area, in their entire value chain.
Contracts with suppliers, subcontractors and other business partners shall include requirements regarding compliance with the contents of this policy and 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 including ensuring protection of human rights and decent work conditions as further set out above.
In addition to adhering to the above principles, Lerøy maintains particular focus on the following topics within human rights and decent work conditions;
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 utilization 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 written employment contract in a language they understand. The apprenticeship program shall be clearly defined in terms of duration and content.
Child and youth labor
Children under the age of 18 shall not perform work that represents a health or safety hazard, including night work.
Children under the age of 15 shall, as a main rule, not be employed. Where national legislation allows it, exceptions can be made in special circumstances down to the age of 13 as further outlined in Lerøy’s Code of Conduct.
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.
Lerøy pays sick pay to all its employees in accordance with national regulations in the countries in which the Group operates, regardless of whether they are full-time, part-time or temporary employees. Lerøy requires that hired employees are to receive sick pay in their employment contracts in accordance with national regulations.
Working hours
Working hours shall comply with national legislation and shall be in accordance with prevailing international conventions.
Trade unions and collective bargaining
Lerøy respects and recognises the right of employees to freedom of association and collective bargaining across the organisation’s operations, suppliers and geographies. Without exception, employees shall be entitled to join or establish trade unions according to their free will and to bargain collectively. No employee shall be discriminated against on the basis of trade union membership. 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 organization and bargaining.
The Group’s suppliers shall operate in accordance with the Group's code of conduct and respect freedom of association for their employees.
Forced labor
All forms of forced labor, slave labor or involuntary labor 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 and harassment
All forms of discrimination or harassment 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 behavior and to prevent discrimination or dismissal on unfair grounds.
Physical mistreatment
Physical mistreatment or punishment, or threats of physical mistreatment, are strictly forbidden. The same applies to sexual or other abuse and different types of humiliation.
Local environment and community engagement
Lerøy shall make a positive contribution towards sustaining a good environment for the local communities where our companies are located. The local environment and production site shall be protected from pollution damage.
Lerøy is committed to an open and transparent approach when engaging with local communities on human and labor right issues related to our business and our value chain.
Use of resources
All forms of environmental crime or ruthless exploitation of natural resources in the local environment are strictly prohibited.
Lerøy shall neither directly nor indirectly contribute to the destruction of the source of income for marginalised communities, for example by seizing large plots of land or other natural resources on which these communities rely.
Chemicals and other hazardous substances shall be properly handled. Production and the utilisation of raw materials for production, shall not represent destruction of natural resources.
Interaction
Lerøy participates in various initiatives regarding human rights protection.
IMPLEMENTATION AND FOLLOW-UP
Lerøy is implementing measures aimed at ensuring compliance with the requirements of this policy. These measures include;
(a) the identification of risks of causing or contributing to adverse impacts on human rights and decent work conditions through Lerøy’s own activities and address such impacts when they occur;
(b) the performance of adequate due diligence processes to prevent such risks of materializing,
(c) seeking to prevent or mitigate adverse impacts on human rights or decent work conditions that are directly linked to Lerøy’s operations or contributed to by our business relationships, and
(d) assess, monitor and report on our progress and performance.
Transparency and openness are encouraged in Lerøy and Lerøy has therefore implemented a whistleblowing scheme which allows Lerøy personnel and any third party to report any concerns. This is further described in Lerøy’s Code of Conduct and allows anonymous reporting. It is also possible to provide direct feedback to the company. This feedback is registered and handled in the company’s incident reporting system.
VALID FOR
Lerøy and its employees, directors, officers, hired personnel, consultants, company representatives and any person conducting work on behalf of or otherwise representing Lerøy.
DEFINITIONS
None
FRAMEWORK AND PRINCIPLES
principles on Human Rights, Labor, Environment and Anti-corruption
ROLES AND RESPONSIBILITIES
All those who work at Lerøy are responsible for respecting human rights. Human rights are an integral part of Lerøy’s Code of Conduct. All employees have the responsibility to understand and follow the standards as well as adhere to principles outlined in the Code.
The top management in each company is responsible for ensuring compliance with this policy, and that the organization 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 at Lerøy and is presented to the Group's Board of Directors.
The CEO of Lerøy Seafood Group has overall responsibility for the policy.