The Group aims to be an enterprise with local roots in the areas where we operate, thereby contributing to all local communities.

Lerøy’s culture is based on our values: Honest, Open, Responsible and Creative. The Group strives to create an including and engaging work environment built on collaboration, learning and continuous development.

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Policy:  Human rights
Policy: Diversity and inclusion
Policy:  Whistleblowing

Code of conduct

Lerøy supports and respects the protection of internationally proclaimed human rights and will not be complicit in human rights abuses.

The Group has developed a Human rights policy which is approved at the Board.  The policy is publicly available and communicated internally and externally to all interested parties.

The policy is supplemented by The Groups Business Code of Conduct which stipulates the company’s expectations regarding human rights implementation and compliance both for own personnel and our suppliers' personnel It also refers to The United Nations Global Compact principles on Human rights, Labor , Environment and Anti-Corruption and The International Labor Organization’s declaration of fundamental principles and rights at work.

The company will actively contribute to creation and maintenance of an environment that treats employees and workers with dignity and respect, seek ways to prevent or mitigate adverse human rights impacts and address such impacts if/when they occur.

Lerøy is a member of UN Global Compact, Norway, and are working for human rights continuously through our daily business. 

The Group works continuously to ensure a discrimination-free environment, where every  employee is treated equally, independently of their gender, origin, ethnicity, skin color, language, religion or personal philosophy.

One of the Group’s goals is to provide a workplace without discrimination because of disabilities. The company will arrange for individually adapted workplaces and work tasks (where possible) for employees or work applicants with disabilities.

The Group has always emphasized individual skills, performance and responsibility in its recruitment policy and salary system. Furthermore, the Group at all times ensures equal employment opportunities and rights for all employees, both men and women. The Group has an international working environment and a number of our employees have cross-cultural backgrounds.

In recent years, the Group has seen an increase in the proportion of women in previously traditional "male-dominated" occupations, such as aquaculture and wild fishery. We see the same trend in different study directions for the seafood industry. This will lead the way for a better gender balance in the future.

Lerøy finds that the gender balance is positive for the working environment. In recent years, the Group has seen an increase in the proportion of female employees in the companies, and aims to increase the proportion of women further in the coming years.

Number of women and men in different countries

As an employer, the Group has a responsibility to develop and maintain our human resources, as well as attract and hire employees with the right competencies to solve existing and future challenges.

We are committed to ensure training and development at all levels and offer unique and interesting career opportunities for our employees. We will advertise internal career opportunities and encourage increased internal mobility.

In 2021 the Group launched corporate training and development online platform (Motimate) where compulsory and voluntary training is conducted. Motimate is a tool which our employees can use to develop their competencies and skills. Motimate provides an interactive and simple way for sharing and acquiring knowledge.

Management development

The Group focuses on forward-looking and coherent management based on the Group’s values and business strategy. Our managers shall lead by example, show direction and focus on achieving results jointly. In 2021, the Group continued to develop and implement programs and tools to ensure that our managers are accountable and skilled in their role.

Employee development

The Group operates in a global industry that requires employees who are dynamic and willing to adapt and learn. By facilitating formal and informal learning areas, our employees will have the opportunity to take responsibility for their own learning and development, and are encouraged to work in various areas and positions in the Group.

We have a close cooperation and knowledge sharing with various educational institutions, such as universities and colleges. In addition, we cooperate with students at Bachelor, Master and PhD level.

The Group finds great value in recruiting young people and graduates into the industry. We offer apprenticeships, summer vacancies, internships and trainee positions. It is important for the Group to have people from different backgrounds and with different types of education.

The Group has developed its own nonconformance reporting system where all injuries, near misses and accidents are recorded and followed up with a root cause analysis.

The Group uses these results to improve and to prevent injuries from re-occurring as well as highlight areas that require further attention . One of the most important things for us is to record near misses so we can prevent injuries from occurring.

We aim to have zero workplace injuries and will never compromise on our employees’ safety.

No one wants anyone to get hurt or get sick in the workplace. It is necessary to have an overview of the risks that the business activities entail, and take actions to prevent someone from getting hurt or getting sick.

HSE procedures and risk analyses are essential and allow us to organize our work so we can prevent as many work-related injuries as possible.

We work within a number of HSE-related areas:

• Training and information
• Good ergonomics in the workplace
• Rolling work operations
• Occupational health
• Various forms of organized training
• Preventive work
• Risk analysis

Lerøy has a high focus on reducing sickness absence and works actively to prevent absence due to illness.

Percentage of companies with working environment committee with employee representatives (%) 83.

Risk assessment is completed in relation to risk of employees developing antibiotic resistance.

TOTAL RECORDABLE INJURY RATE AND FATALITIES

Lost time injury rate is calculated using the following formula:

((Number of injuries resulting in absence form work) + (Number of injuries without absence from work)) x 1 000 000/ total number of working hours in the respective period

Fatal accidents

An occupational fatality is a death that occurs while a person is at work or performing work-related tasks.

*The calculation includes injuries both resulting and not resulting in absence from work.

Link

KPI: Occupational health and safety 

Compliance and Business Code of Conduct 

Lerøy Seafood Group (the Group) has a strict policy to promote and ensure compliance with all applicable laws and regulations. 

The Group constantly determines and monitors compliance obligations related to its business activities and evaluates how these should be applied to the organization. Relevant compliance requirements are taken into account when planning, implementing and maintaining the Group’s compliance obligations as well as assessing its compliance performance. 

The Group strongly believes that an ethical business culture is key for creating and maintaining a sustainable company. The Group is committed to working ethically, with integrity and always lawfully everywhere we operate and with everyone we do business with. 

The Group has developed a Business Code of Conduct which outlines the Group’s fundamental standards and principles for business conduct and ethics, human and labor rights, environment, anti-bribery and corruption, whistleblowing and data privacy protection. We require both our employees and our suppliers to respect, support and comply with the Code as applicable. 

The Code is complemented by the Group’s set of values which define our behaviors at work. In order to verify whether and to what extent the Group’s Business Code of Conduct is applied by the Group’s suppliers, they are requested to fill out a questionnaire which requires the suppliers to explain in detail how the Code is applied and complied with. The questionnaire addresses such issues as governance, certifications, digital infrastructure and cybersecurity, supply chain, sustainability practices, human and labor rights and other subject specific requirements. 

All employees shall be able to apply the principles laid out in the Code and have received Business Code of Conduct and Ethics training to raise awareness of and compliance by employees.  All new employees have to familiarize themselves with the Code of Conduct and the Group’s set of values. Existing employees are invited to revisit and review Th Group’s Code of Conduct annually.

The Code of Conduct is reviewed by the Board annually. It is a permanent agenda item of the first Board meeting of each year. The Code is reviewed in order to evaluate its relevance and appropriateness with regards to organizational context changes, social developments, particular cases as well as feedback form relevant stakeholders.

The Group has zero tolerance for corruption. Elimination of corruption has been defined as one of the priorities of the Group. Implementing anti-corruption measures is an integral part of our corporate responsibility protecting our reputation and the interests of our stakeholders. 

The Group is a signatory of UN Global Compact and has committed to both avoiding corruption as well as developing policies and implementing measures to address corruption internally and within our supply chain. 

All our employees and workers have received training on our Business Code of Conduct which, amongst other subjects, includes information on the Group’s anti-corruption policies and procedures. 

All our suppliers are informed of and have to commit to our Business Code of Conduct, and they are expected to conduct their business in an ethical and manner as well as act with integrity complying with international and local anti-corruption and bribery laws and standards.  

All companies within the group complete detailed compliance reporting quarterly. The reporting covers such issues as compliance breaches, data privacy and protection, business code of conduct, whistleblowing, concerns regarding customers, credit policy, potential corruption cases and other issues of concern. In case of discrepancies an appropriate action is taken. The nature of the action taken is defined by the nature and severity of the discrepancy.  

Employees and workers as well as others who are required to respect and comply with the Business Code of Conduct can suggest changes and updates to the Code. If appropriate and necessary, the Business Code of Conduct is amended, updated or explained in greater detail in case there is a necessity for more clarity regarding how an issue should be handled or resolved. 

Concerns regarding compliance and business conduct can also be reported anonymously via an independent whistleblowing channel. 

I 2021 there were zero confirmed incidents of corruption and no employees were dismissed or disciplined for corruption.

There were no confirmed incidents where business partners were terminated or not reviewed due to violations related to corruption. No public legal cases regarding corruption were brought against the organization or the employees/ workers during the reporting period. 

Number of Registered Corruption Cases in 2021: 0

The Group does not support individual political  parties or individual politicians, but does engage in public debate when in the interests of the Group.

Every effort shall be made to safeguard local, regional  and global environmental aspects. Aspects regarding animal ethics shall also be given full consideration.

Supplier agreements shall contain requirements that the principles in ethical guidelines are followed. Particular care must be taken when engaging intermediaries and associated payments.

In procurement, conflicts of interest must be identified, assessed and handled in accordance with guidelines and authorizations.

How different cases are followed up will depend on the type of case, scope and degree of seriousness. Various matters will be followed up with measures by the general manager, executive vice president for the segment or by the group manager. Notification matters are reported to group management and the board.

The Group has established a digital channel for whistleblowing, for all our stakeholders or other external persons who wish to contact the Group, or report a matter of concern. They can contact the Group through the Group's web pages: https://www.leroyseafood.com/no/kontakt/ which directs them to an external whistleblowing channel

External Whistleblowing cases are initially processed by an independent third party and further follow-up is coordinated by the Group's local whistleblowing committee.

How different cases are  handled and followed up will depend on the type of case, scope and degree of its seriousness. Various matters will be followed up with resources such as  the local management, the COO for the particular segment the CEO or in special cases - the Board. Notification matters are reported to Group management and the Board.

The Group has established a digital channel for internal whistleblowing, which is a secure electronic system  that allows the employees to remain anonymous when reporting a matter of concern.

Internal whistleblowing cases are initially processed by an independent third party and further follow-up is coordinated by the Group's whistleblowing committee.

How different cases are followed up will depend on the type of case, scope and degree of seriousness. Various matters will be followed up with current resources such as local management, the COO for the segment the CEO or in special cases by the Board. Notification matters are reported to Group management and the Board.

Whistleblowing cases

2021: 9

2020: 8

2019: 2

The Group is a corporation involved in global business and working relationships with more than 6000 direct suppliers worldwide.We set strict social and environmental requirements for ourselves as well as our suppliers and subcontractors.

The Group’s goal is to contribute towards improving human rights, labor rights and environmental protection within the Group, in relation to our suppliers and subcontractors, and in relation to trading partners.

Environmental and social aspects shall be taken into consideration throughout the production and distribution chain, from production of raw materials to sales, and shall not be limited to the Group’s own activities.

When using external suppliers and subcontractors, it is important that we inform them of our health and safety guidelines and that we ensure that our safety routines are followed by external parties involved in our operations.

In situations involving employees with different languages and cultural backgrounds, it may be difficult to create a shared safety culture with good compliance. It is therefore important to ensure good communication to achieve full understanding of the prevailing safety routines.

Link

POLICY: Procurement

KPI: Supplier evaluation

Supplier Involvement

In the Group, suppliers are an integral part of our operations and we have an obligation to ensure that our suppliers act according to the Group’s governing documents. By implementing a structured and  standardized supplier management, we can verify that our suppliers adhere to our requirements and, if necessary, initiate corrective measures. As a buyer, we have an ethical responsibility to ensure that our suppliers act in accordance with relevant laws and regulations.

Suppliers, including subcontractors, are requested to adhere to the highest industry standards, and it is a prerequisite that laws and regulations are followed. With regards to food suppliers we work towards 100%  obtained food safety GFSI certification. In the Group, supplier audits are a tool for developing cooperation and  ensuring continuous improvement between the companies in the Group and our suppliers, and a requirement to assure compliance.

As one of the largest employers along the coast of Norway, the Group has local suppliers that are valuable contributors to our operations. We highly value the diversity in our supply chain and work continuously to develop a local presence near our operations.

As a responsible buyer, the Group has developed a risk-based approach to supplier management to assure that our supply chains are sustainable and robust. We are influenced by internal and external factors ranging from biodiversity to political risks, and we therefore analyze and focus on understanding those factors.

Supplier Evaluation – Supply chain risk management

The Group is a corporation involved in global business and working relationships with suppliers and subcontractors worldwide.

We have worked closely with several of our suppliers for decades. Lerøy sets requirements for all suppliers. The suppliers are informed of and familiar with our requirements.

As a Group we are aware of our responsibility to control that our suppliers are familiar with legal requirements, our code of conduct, work towards lower emissions, strategy and routines for occupational health and safety management and food safety among other criteria.

To be able to  screen all our suppliers, evaluate high risk suppliers and to take responsibility for working with continuous improvement with our suppliers, the Group has developed a supply chain management system.

In the system new suppliers are categorized and risk-assessed according to turnover, criticality and country of origin in order to identify those who carry the greatest risk regarding potential breaches . New suppliers carrying the greatest risk undergo an electronic assessment during which they have to provide a detailed explanation and description of  their:

• Governance practices
• External certifications
• IT & cybersecurity measures
• Supply chain management
• Sustainability practices
• Occupational health and safety management
• Social and environment criteria
• Relevant supplier specific assessment criteria.

Based the criteria the suppliers can obtain maximum 100 points. Based on the score the suppliers are risk categorized as  Green (Low risk), Orange (medium risk) and red (high risk)

• Red - High risk <50 points
• Orange - Medium risk 50-80 points
• Green - Low risk <80 points

New suppliers identified as high risk, not fulfilling the requirements are considered excluded or  are required to implement corrective actions according to the Lerøy Quality Management system.

In addition, Lerøy will annually make a selection of existing suppliers to be evaluated according to a special relevant topic.

On transport suppliers, Lerøy have signed an cooperate agreement with other seafood suppliers about a common audit scheme. An third party certification body will perform a physical onsite audit on transport companies evaluated high risk.

Lerøy Supply chain risk management system

• Overview  and categorization of suppliers at a corporate level
• Risk assessment and risk categorization of suppliers at a corporate level
• Screening and evaluation of suppliers

Target is to screen all new suppliers in the system using all criteria including environmental and social criteria. In 2021 all new suppliers received a request from the supplier evaluation system. The repsonse rate was 11,5 % screened using environmental and social criteria. We are working on increasing the responsrate, among other things by informing the receipients in advance so they do not believe its a spam mail

Social criteria Screened:

• Governance practices
• Occupational health and safety strategy, targets, risk assessment practices, training programs
• Fair working conditions, equal opportunities, freedom of association
• Whistleblowing practices
• Supply Chain follow-up and management practices

Environmental criteria screened:

• Sustainability strategy and targets
• Carbon footprint and carbon footprint reduction targets
• Sustainability reporting practices