Introduction
 

At Egmont, our values drive the way we do business and reflect our commitment to sustainable development. Egmont's Code of Conduct for Third Parties (“Code” or “Code of Conduct”) outlines what Egmont believes to be responsible business and what is required by laws and regulations. Egmont does business by these standards and believes that acting responsibly means going beyond what is required by law. Egmont continuously monitors and improves efforts to maintain a responsible supply chain and engage with responsible business partners. "Third Parties" means any individual or legal entity with whom Egmont collaborates (e.g. business partners, suppliers, manufacturers, and consultants) or who acts on behalf of Egmont (e.g. agents).

International standards and applicable law

This Code is based on international regulations, like e.g. OECD Guidelines, the UN Guiding Principles onBusiness and Human Rights, UN Global Compact andUN Convention against Corruption, EU regulations andindustry standards. Third Parties are always required toabide by local laws and regulations.

Implementation

We require our Third Parties to live up to principles and standards of this Code in their own businesses and supply chain. We assess our Third Parties’ compliance with the Code through a combination of signature confirmations, contractual commitments, audits, due diligence, self-assessments or documentation reviews. Consequences of non-compliance may be termination of the business relationship.

Report concerns

We expect Third Parties to have a whistleblower system in place to enable anonymous reporting on concerns if required by local law. Severe concerns of breach of this Code may also be reported via the Egmont global whistleblower hotline. Examples of severe concerns are corruption, fraud & humanrights violations such as child labour or forced labour.

Labour and human rights
 

Third Parties must uphold human rights, which include labour rights, follow e.g. the United Nations Guiding Principles on Business and Human Rights(UNGP), and ensure a working environment where workers are treated with dignity and respect, especially those who are vulnerable. Some of the most important human rights are highlighted below.

Child labour and young workers

Third Parties must not use child labour and must not employ children who are below the local minimum working age, the age of compulsory education or the ages set out in the International Labour Organization Core Conventions (whichever is higher). Young workers below the age of 18, and above the legal age for employment, must not work overtime, night shifts or carry out hazardous work or work that can hinder their physical or mental development, education or health.

Freely chosen employment

Third Parties must refrain from any practices that give rise to risk of forced labour, modern slavery or human trafficking. When a written employment document is legally required, workers must receive a copy. Workers must not be required to hand over personal identity papers to secure employment unless it is required by law. If that is the case, workers must have full access to their papers. Workers must be free to leave their jobs after reasonable notice.

Harassment

Third Parties must treat workers with dignity and respect. The workplace must be free from bullying, intimidation and harassment in any form, including physical, psychological, sexual or verbal.

Discrimination

Third Parties must provide a working environment where individuals are respected, valued and empowered. In hiring and employment practices discrimination for reasons such as gender identity or expression, age, national origin, ethnicity, religion, marital status, pregnancy, mental or physical disability, sexual orientation, political views or union membership must be avoided. Workers must be able to rely on open communication and engagement when addressing workplace issues without threat of reprisal or intimidation.

Freedom of association

Third Parties must respect workers’ right to associate freely, join or not join labour unions, seek consultation and join workers’ councils in accordance with national laws and international conventions.

Wages, benefits and working hours

Third Parties must pay workers on time and in full according to national laws on minimum wages, overtime and benefits, including paid sick leave, annual leave or parental leave, also during the notice period. If no statutory minimum wages exist, the Third Party must ensure that remuneration is fair and sufficient to meet workers’ basic needs locally. Third Parties must ensure that employment terms and conditions are understood by workers, including a written pay slip.

Third Parties must provide reasonable working hours, breaks and rest periods according to national law, collective agreements and international standards. Working hours must not regularly exceed 48 hours or overtime 12 hours per week. Accurate records of working hours must be kept for all workers and overtime must be voluntary.

Health and safety

Third Parties must provide a safe, healthy and secure working environment. Health and safety measures must extend to contractors and subcontractors.

Worker protection and emergency preparedness

Third Parties must protect workers to ensure that they are not exposed to chemical, biological and physical hazards at the workplace and any living quarters and accidents are prevented. Workers must have adequate and acceptable electricity, lighting, ventilation, privacy, food, water and sanitary standards. If housing is offered as part of the compensation package, it is a benefit and using the housing must never be compulsory.

Emergency and response plans as well as safety information must exist, for instance fire exits, escape routes and firefighting equipment in case of a fire and information on processes to identify risks from hazardous materials and how to protect workers. Basic protective equipment appropriate to the nature of work and relevant training of workers must be in place, including proper use, storage, cleaning and maintenance.

Third Parties must ensure that safety information regarding hazardous materials is available and that workers are educated and protected.

Environment

Egmont requires Third Parties to demonstrate commitment towards environmental protection, to establish and enforce policies and procedures to comply with all applicable environmental laws and regulations, and to follow best practices to minimise negative impacts on the environment from their operations and activities.

Environmental authorisations

Third Parties must ensure that any work that requires a specific environmental licence is only performed by individuals who are appropriately registered and licensed. Appropriate records must be maintained to demonstrate compliance with requirements and permits, including data relating to environmental impacts.

Product quality and assurance

Third Parties must ensure that products and services are of high quality, comply with all applicable laws and standards, and are safe to use.

Resource use and climate

Egmont expects Third Parties to adopt sustainable practices aiming at recycling and reusing resources and reducing consumption of resources. Third Parties must strive to continuously improve resource efficiency.

Ethics and integrity

Third Parties must conduct their business with integrity and ensure transparency, honesty and ethical conduct.

Corruption and bribery

Third Parties must refrain from engaging in any form of corrupt practices or illegal bribes. This includes any offer, payment or benefit in kind which is offered –directly or indirectly –as an illegal inducement. An example may be a reward to a contractor to secure a contract, e.g.in a tender. Facilitation payments are illegal and must be avoided.

Offering or receiving gifts, hospitality and entertainment that are not in accordance with reasonable marketplace customs and practices may constitute inappropriate financial ormaterial benefits to influence business decisions. Third Parties must ensure that such exchanges are legal, transparent and for a sound business reason.

Third Parties are encouraged to work against any conflict of interest in their business dealings and must inform Egmont of any conflict of interest that may affect the business with Egmont.

Third Parties must avoid any political contributions, charitable donations or sponsorships that would aim at gaining an unfair competitive advantage or improper influence.

Anti-money laundering

Third Parties must prevent money laundering and not participate in any such activities.

Data Privacy

Third Parties must safeguard confidential information and ensure data privacy.

Intellectual property

Third Parties must respect Egmont’s intellectual property rights (as well as Third Party rights licensed through Egmont companies) and protect Egmont’s trade secrets and confidential information. Third Parties must manage technology and knowhow in a manner that protects intellectual property rights.

Competition law

Third Parties must uphold standards of fair business practices and competition and adhere to anti-trust and other competition laws. Third Parties must not share sensitive information with competitors.

Sanctions and export controls

Trade sanctions are preventive measures put in place by governments and international bodies (such as the European Union, United Nations and United States, etc.). Third Parties must refrain from trade with sanctioned persons, entities, sectors and countries. Third Parties must abide by export controls relating to transfer of goods and services, software or technology between countries.