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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:
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
Roles and responsibilities
Policy ownership and implementation
Owner/approver: CEO Lerøy Seafood Group
Valid from: 2023-07-05
Purpose
The purpose of Lerøy’s anti-corruption and anti-money laundering policy is to outline clear expectations and requirements related to compliance with relevant prohibitions against corruption, money laundering and terror financing.
The policy provides a concise and principle description of how Lerøy works to promote an ethical business culture by conducting all business activities with integrity and in an open and transparent manner.
Lerøy is obliged to conducting its business in accordance with the applicable laws and regulations of the countries in which it operates. In addition, we are obliged to act in accordance with the standards and principles of business conduct and ethics as stated in Lerøy’s Code of Conduct, this policy, as well as internationally recognised anti-corruption, anti-money laundering and anti-terror financing conventions and guidelines.
Lerøy has zero tolerance for corruption in any form in both the public or private sector, including bribes, influence peddling and facilitation payments, regardless of whether this takes place directly or through a third party and whether it takes place actively or passively. Lerøy also has zero tolerance for money laundering and terror financing.
Lerøy makes an active effort to prevent activities that facilitate corruption, money laundering and terror financing, and has established secure processes to prevent, identify and manage any risks in the respective areas, including ensuring that the organisation is not misused for money laundering or terror financing purposes. These processes are described in more detail in Lerøy’s underlying procedures.
Lerøy provides training and guidance to its own employees and hired staff with regard to Lerøy’s Code of Conduct, as well as customised anti-corruption and anti-money laundering training for relevant positions. A differentiated and up-to-date training programme ensures that Lerøy’s own employees and hired staff are able to recognise conditions that can represent a risk of corruption, money laundering and terror financing.
A suspected violation of corruption, money laundering and terror financing rules must be reported immediately to the immediate supervisor and LSG Compliance Officer. A suspected violation can also be reported through an internal or external whistleblowing channel, either openly or anonymously.
General guidelines
The following guidelines provide the foundation for how Lerøy addresses anti-corruption and anti-money laundering:
Comply with this policy and other internal anti-corruption and anti-money laundering procedures/guidelines.
Do not participate in or approve corrupt or unethical business activities.
Exercise due care when making decisions and never compromise ethics in connection with business activities.
Undergo relevant training.
If you are uncertain or have any questions about the contents of this policy or Code of Conduct, seek guidance from Lerøy management.
Valid for
The policy applies to Lerøy Seafood Group ASA and its subsidiaries (Lerøy), including all employees and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way. Lerøy’s business partners are required to comply with the Supplier Code of Conduct.
Definitions
Corruption is the abuse of entrusted power for personal gain. The notion of corruption in criminal law encompasses bribing or accepting bribes in the form of money, gifts or services. Corruption is not an unambiguous concept and in the broadest sense, also includes influencing others to carry out their work in a specific way, referred to as influence peddling.
Money laundering pertains to everything related to profiting from criminal activities, including what is referred to in Norwegian criminal law as ‘heleri’, which means receiving the proceeds of crime. This encompasses both providing assistance to secure the proceeds of a criminal act for another person and concealing or disguising the proceeds of a criminal act that has been carried out personally. It also includes receiving or acquiring a share of the proceeds of a criminal act personally or on behalf of others. In other words, money laundering means contributing in some way to securing the proceeds of criminal acts by concealing where these proceeds has been transferred or who has control over them, or concealing income, other assets or the illegal origin of assets.
Terror financing is the financing of acts of terror, terror organisations or individual terrorists
Framework and principles
The provisions of the Norwegian Penal Code (LOV-2005-05-20-28) concerning the handling of the proceeds of crime, money laundering, acts of terror or terror-related activities, as well as corruption and influence peddling, are particularly relevant for Lerøy. Corruption legislation, money laundering legislation and terror financing legislation in other countries in which Lerøy operates also apply.
Roles and responsibilities
All employees of Lerøy and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way, are required to comply with this policy.
The Group management of Lerøy Seafood Group ASA and local management at all subsidiaries are responsible for ensuring that the company has staff with the skills required to ensure compliance with local anti-corruption regulations, anti-money laundering regulations, and anti-terror financing regulations.
Ownership and implementation
The CEO is the owner of the policy and responsible for all updates.
The policy has been approved by Corporate Management Group, presented to the Audit Committee and approved by the Board of Directors.
The CEO of Lerøy Seafood Group ASA has overall responsibility for the policy.
Owner/approver: Head of ESG & Quality
Valid from: 2022-04-11
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.
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 decisive 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 welcomes and encourages proactive incident and hazard reporting as it is crucial for maintaining a safe and healthy work environment. There shall be no reprisals against either employees or workers as a consequence of reporting of hazards and/ or hazardous situations.
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:
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:
Roles and responsibilities
Policy ownership and implementation
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:
We also strive to avoid the use of more cleaner fish than deemed necessary to maintain good control of lice.
Roles and responsibilities
Policy ownership and implementation
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
Policy ownership and implementation
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:
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
Policy ownership and implementation
Owner/approver: Head of ESG & Quality
Valid from: 2022-04-27
PURPOSE
Lerøy Seafood Group (LSG) will work to limit as much as possible the impact on our local water sources and surrounding environment that are directly and indirectly affected by our operations. Sustainable management of these water sources is important to maintain our operations and 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:
Leroy will continue to invest in solutions in accordance with our Policy and Guidelines to ensure a reduction in water withdrawal, and increase water quality of waste water. For more information see the Green Finance Framework on our website (www.leroyseafood.com).
Risk
LSG has carried out a risk assessment relating to water stress and water depletion in our downstream units. Of our 22 factories in 10 countries, 11 are located in areas that have a medium to very high risk of Water Stress or Water depletion (https://www.wri.org/aqueduct). Based on the risk assessment, it has been decided that LSG will focus on these units in the work to reduce water withdrawal, improve the quality of the discharge water (effluents) and reduce our consumption of freshwater. The companies in exposed geographical areas must, in collaboration with the management group in LSG prepare a plan to reduce their impact on the local water sources in 2023.
There are no areas in Norway, which are categorized as being at risk of water stress or water shortage All water-intensive (98% of water withdrawal) activities (smolt production) is located in Norway.
Strategy and KPI
In 2023, the group will adjust its strategy and KPI focusing on areas with medium to high tisk of waterstress. Part of the strategy is, through dialogue with authorities and interest organisations, to develop a progression plan for water-reducing measures and to improve the quality of the discharge water for units located in areas with a medium to high risk of water stress. Our consumed water for the downstream units (see our sustainability library) is mostly related to ice production to cool our products. The measures that appear in the action plan will therefore not significantly affect our consumed water. We have therefore chosen to keep consumed water outside our KPI.
A number of actions have already been carried out which are available in the Sustainability Library
Water withdrawal, Water discharge and Consumed water in LSG:
Smolt production is the largest contributor to the withdrawal and discharge of water in LSG. The facilities that produce smolt are exclusively located in Norway and are the only operation that uses surface water as a water source. These are linked to specific agreements for water withdrawal and waste water discharge per facility. The water that is withdrawn from source into the flow-through system or RAS system returns in its entirety to the surroundings and results in this part of our operations having no consumption of water. We must comply with all the criteria in our discharged permits.
Overview of all focus areas where LSG will reduce fresh water withdrawals and increase the water quality of the waste water:
Suppliers
LSG makes demands through group agreements to suppliers. These satisfy internal and external requirements for water reduction, water purification and consumption of water in the value chain. Together with our suppliers, we establish plans and frameworks for how the suppliers can meet these requirements.
Example of requirements for suppliers
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
ROLES AND RESPONSIBILITIES
POLICY OWNERSHIP AND IMPLEMENTATION
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 targets to increase the volume inorganic waste which is recycled to 65 % by 2030, 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. As a result of this, Lerøy entered into a group agreement in 2022 on waste management for our Norwegian operations. The experience and knowledge we acquire from this collaboration we aim to implement also in our European operations.
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
ROLES AND RESPONSIBILITIES
OWNERSHIP AND IMPLEMENTATION OF 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:
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
Policy ownership and implementation
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:
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
Ownership and implementation
Owner/approver: COO Farming
Valid from: 2023-04-27
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
In an internal ESG risk assessment, Lerøy has identified feed as a key factor in maintaining its position as a leading supplier of sustainable seafood. Lerøy can point to a long history as a pioneering company in fish feed, where we both internally develop new, but also use external new alternative feed raw materials on an industrial scale that we are pioneers. Lerøy will continue to drive the development of sustainable feed towards a "net zero" ambition in 2050, with new fat and protein raw materials that cover all the nutritional needs of Salmon without reducing the next generations' opportunities to do the same.
All raw materials used in feed production for Lerøy must be part of a traceability system. Marine raw materials must be traceable back to fishing zone, species, degree of certification, share of catches and country of landing. For vegetable raw materials, the system must know in which country the crop was harvested, and in which country any processing has taken place. For soy, stricter traceability criteria apply, with area division in Brazil, and an overarching goal of being able to track soy down to individual farms in the long term to ensure a deforestation-free value chain.
Lerøy will require that all feed be produced according to the ASC Feed Standard when this is ready for implementation, at the latest at the end of 2025. ASC has a good approach to the acquisition of sustainable marine raw material, but Lerøy's sustainability targets are higher. Lerøy will therefore aim for all marine raw material from whole fish, excluding by-catch, to at least meet the requirements in category 1 of the ASC-Feed standard.
Marine raw materials must come from responsibly regulated fisheries where the individual species is regulated in accordance with the regulations of national and international authorities and where quotas are given in accordance with scientific recommendations. None of the species can be on the UN's list of threatened species, classified as critically endangered or threatened on the IUCN's red list. The supplier must comply with and comply with the current ASC standard for all deliveries of marine raw materials to Lerøy. Lerøy has an ambition to increase the proportion of MSC certified raw materials, and the proportion of trimmings year by year.
Vegetable raw materials must come from production that takes place on land that has been acquired for this production in a sustainable manner. The supplier must not use subcontractors who make use of the burning down/razing of rainforests/mangrove forests. Vegetable raw materials must be certified according to an internationally approved standard for sustainability where this is available.
The production of the raw materials must take place in line with the group's ethical guidelines, where no illegal use of child labor is accepted. Together with our feed suppliers, we must focus on the use of water resources and displacement of indigenous people in connection with the production of raw materials is not accepted.
If soy is to be used in the feed, this must come from producers with tracking through the value chain, as well as suppliers who have already implemented a cut of date in relation to deforestation (Brazil). All soy from Brazil must be ProTerra certified.
When evaluating new raw materials that do not naturally fall under the above-mentioned categories, a thorough and holistic sustainability evaluation must be carried out and there must be a written internal report, supported by documentation from the producers. Lerøy has made an active choice with regard to the establishment of new sources of feed raw materials, and will continue to be a driving force for the development of new circular feed raw materials. These raw materials do not need to be fully certified at the time of use.
Lerøy does not use GMO raw materials, palm oil, ethoxyquine, raw materials from salmon fish, Land Animal Proteins (PAP/LAP's) or fat sources from land animals.
The feed must at all times satisfy the group's various aquaculture certifications, such as Organic production, Lerøy Salmon TM and ASC production.
Lerøy has a goal to reduce greenhouse gas emissions throughout the value chain. Raw materials for fish feed are a strong driver in relation to greenhouse gas emissions, and Lerøy therefore wants to prioritize raw materials that contribute to reaching our climate target without compromising biodiversity and other important ESG targets.
Roles and responsibilities
Policy ownership and implementation
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.
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 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.
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.
To achieve further improvements in this area, we have created a 100% Fish team, whose purpose is to investigate future commercial opportunities and assisting in R&D efforts in the utilization of consequence products in our value chain.
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
Policy ownership and implementation
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 have an ambition to be climate neutral by 2050.
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:
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
Policy ownership and implementation
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:
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
Policy ownership and implementation
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
Policy ownership and implementation
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:
On products:
Valid for
This policy applies to all employees.
Definitions
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
Policy ownership and implementation
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:
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
Policy ownership and implementation
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.
Lerøy has also established their own limit values to provide guidelines for when to implement preventive and active measures to combat salmon lice.
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
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:
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.
Owner/approver: Head of Brand & Innovation
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:
Honest and open, including:
Contribute to a healthier and more sustainable lifestyle, including:
Applies to
The whole Group
Definitions
Sustainability, follows the definition laid down by the Head of ESG
Framework and principles
Brand Master
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 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.
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.
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:
Roles and responsibilities
Policy ownership and implementation
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
Owner/approver: CEO Lerøy Seafood Group
Valid from: 2022-04-24
The purpose of Lerøy’s sanctions policy is to outline clear expectations and requirements related to compliance with sanctions, including export control, which is also considered to be encompassed by the concept of sanctions.
The policy provides a concise and principle description of how Lerøy works to comply with the applicable sanctions regulations.
Lerøy is obliged to conducting its business with integrity and in accordance with the applicable laws and regulations of the countries in which it operates.
It is Lerøy’s policy to forbid and actively work to prevent any activity that conflicts with the applicable sanctions regulations.
Lerøy implements the necessary measures in line with a risk-based approach in order to ensure compliance with the relevant sanctions regulations, including ensuring that goods/services that are sold/bought are not subject to sanctions, whether directly or indirectly, and that Lerøy does not transfer or make available funds or assets to sanctioned parties. Lerøy also actively works to prevent sanctions evasion.
Lerøy structures and organises its operations in a manner that reduces the risk of sanctions violation to a minimum. Lerøy has established secure processes to prevent, identify and manage any risks associated with this work. These processes are described in more detail in Lerøy’s underlying procedures.
Lerøy provides training and guidance to its own employees and hired staff with regard to Lerøy’s Code of Conduct, as well as customised sanctions training for relevant positions. A differentiated and up-to-date training programme ensures that Lerøy’s own employees and hired staff are able to recognise conditions that can represent a risk of sanctions violation.
The policy applies to Lerøy Seafood Group ASA and its subsidiaries (Lerøy), including all of Lerøy’s own employees and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way. Lerøy’s business partners are required to comply with the Supplier Code of Conduct.
Definitions:
Sanctions – refers to non-military national security and foreign policy instruments aimed at government authorities, companies, groups, organisations or individuals in the form, for example, a weapons embargo, travel restrictions, financial freeze measures or other financial measures, such as import and export restrictions or trade restrictions for specific goods or services.
Export control – refers to rules that can be implemented on the national or international level in order to regulate, ban or require licensing for the export of goods.
Sanctions evasion – refers to activities with the purpose or effect of evading sanctions regulations, such as acting as a proxy for physical or legal persons included in sanctions lists. Intentional sanctions evasion is a criminal offence under Norwegian law. Counties associated with frequent sanctions evasion represent an increased evasion risk.
Sanctions are implemented by way of various sanctions regimes, including in the EU, Norway, UN, U.S. and Great Britain. These regimes include different sanctions programmes. A sanctions programme may be aimed at a specific country or regime and define restrictions on trade with or in such countries or with persons/companies in such countries. There are also sanctions programmes that are not country-specific, such as programmes aimed at gross human rights violations or corruption. Sanctions can define restrictions associated with trade with countries and areas, as well as certain types of products/services or certain types of companies, individuals or organisations/groups.
Lerøy is exposed to different sanctions regimes through its geographical presence, employees, third parties, products or other factors, such as currency use. Different sanctions regimes may be relevant for a specific activity or transaction, and the types of regimes and underlying sanctions rules that apply must be examined specifically for each activity or transaction. Lerøy Seafood Group ASA has its headquarters in Norway and consequently, will always make every effort to comply with sanctions regulations issued by Norway, the EU and UN, as well as other sanctions regulations that apply to individual transactions or trade.
All employees of Lerøy and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way, are required to comply with this policy.
The Group management of Lerøy Seafood Group ASA and local management at all subsidiaries are responsible for ensuring that the company has staff with the skills required to ensure compliance with sanctions.
The CEO of Lerøy Seafood Group is the owner of the policy and responsible for all updates.
The policy has been approved by the corporate management of Lerøy, submitted to the Audit Committee and approved by the Board of Directors.
The CEO of Lerøy Seafood Group ASA has overall responsibility for the policy.
Owner/Approver: Group Chief Accountant
Valid from: 24.06.2024
This document sets out the global framework for tax management and governance in the Lerøy Seafood Group (“LSG”). Tax management is an integrated part of the group's corporate strategy. The Global Tax Policy shall be in line with the corporate governance of LSG, including LSG's Code of Conduct and The Lerøy Way. LSG intends with this statement to disclose what approach the management has to ensure that LSG are compliant with all reporting and payment obligations related to statutory taxes.
This policy applies to all LSG’s legal entities, and its employees are obliged to adopt and follow the Global Tax Policy in all business activity and in all decision making.
None
Overview of applicable tax framework
1. Tax Residence: LSG and its subsidiaries are subject to taxation based on their tax residence. The tax residence is typically determined by the location of a corporation's main operations, management, or the place of incorporation.
2. Corporate Tax Rates: LSG is required to pay corporate taxes at the rates set by the host country where they operate. Corporate tax rates vary across the different jurisdiction. These rates are generally applicable on the company's net profits. Some jurisdictions have special taxes in addition, as the Norwegian resource rent tax on salmon farming.
3. Double Taxation Avoidance: To avoid double taxation in case of cross-border activities, LSG benefit from tax treaties between countries. These treaties generally avoid income from being taxed twice on same source of income, either based on a tax credit method or an exemption method.
4. Transfer Pricing: Transfer pricing regulations and guidelines aim to prevent profit shifting and tax evasion through pricing of related-party transactions. This is particularly relevant for cross border transactions, but will also be relevant in national transactions, including when there are different tax schemes (such as the resource rent tax in Norway). Related party transactions shall be performed in accordance with OECD’s Transfer Pricing Guidelines for Multinational Enterprises.
5. Tax Deductions and Incentives: LSG may be eligible for tax deductions and incentives provided by the host country to encourage investment, research and development, job creation, sustainable practices, or other specific objectives. These incentives can help reduce the overall tax burden.
6. Withholding Taxes: Subsidiaries in LSG may be subject to withholding taxes on certain types of income, such as dividends, interest, royalties, or service fees. These taxes are often levied on the payment made to foreign entities and are deducted at the source.
7. Tax Credit: Taxable income in Norway may have been subject to foreign tax, including withholding taxes. Tax credit can be obtained by invoking the relevant tax treaty or Norwegian internal regulations.
8. Anti-Abuse Measures: Most jurisdictions where LSG operate have enacted anti-abuse measures to prevent tax avoidance or evasion schemes used by international corporations. These measures may include controlled foreign corporation (CFC) rules, limitations on interest deductions, and anti-hybrid rules.
Tax governance
LSG’s Board of Directors is responsible for approving this policy and further develop it in collaboration with the administration in LSG. The Audit Committee has an active role in the collaboration with the administration.
The administration in LSG is responsible to periodically review the policy in order to make sure that it is relevant and updated in terms of changes in organization and the legal environment. Changes in tax legislation, with an assumed material effect on the financial statements of LSG, are discussed with the Audit Committee.
The administration in LSG works closely with other Group Functions and Business Areas to identify, monitor and mitigate tax risks.
All LSG legal entities and its employees are obliged to adopt and follow the Global Tax Policy in all business activity and in all decision making.
Legal and Regulatory Requirement
The management of taxes in LSG shall be performed in accordance with all local laws and regulations both with regards to taxes and accounting and bookkeeping. Related party transactions shall be in accordance with OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations including, but not limited to the arm’s length principle. LSG shall ensure compliance with EU Mandatory Disclosure Rules (MDR).
Tax compliance and reporting
LSG is committed to transparency and accuracy in its tax compliance and reporting. LSG shall ensure full, fair, accurate and understandable tax calculations, reporting, filings and payment of taxes. Payable tax in LSG is paid when it is due. LSG shall ensure that financial reporting is in accordance with IFRS and LSG’s accounting principles.
Tax planning and advisory
LSG is committed to sustainable value- creation for its shareholders, other stakeholders, and the communities where it operates. LSG shall seek to adopt tax efficiency and cost optimization within the principles listed below:
· Equitable taxes shall be paid where the economic value is generated.
· LSG does not actively seek to reduce taxes through exploitation of asymmetry in rules and legislations.
· All tax management will be performed based on LSG’s commercial needs and all transactions must have a business purpose or commercial rationale.
· LSG does not operate in grey areas.
· Consideration shall be given to LSG’s social responsibility, reputation, brand as well as the expectations from its key stakeholders.
Relationship with tax authorities
LSG is committed to a constructive, professional, and transparent relationship with tax authorities, based on the concept of integrity, collaboration, and mutual trust. LSG shall respond to tax enquiries and audits in an open, honest, and responsive manner. LSG is positive to dialogue meetings with tax authorities where impact of changes in legislation and other changes to tax related matters can be discussed at an early stage rather than during retrospective audit.
Tax transparency
LSG shall maintain a principle of openness and be honest and responsive when dealing with interested parties outside LSG and society at large. LSG shall fully comply with the relevant tax transparency legislation and reporting requirements in all jurisdictions.
· 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 the policy.
· The Group Chief Accountant of Lerøy Seafood Group ASA is the owner of this document, and is responsible for updates.
· The policy has been approved by the Board of Directors
· The CFO of Lerøy Seafood Group ASA has overall responsibility for the policy.