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Code of Conduct and Policies

Calbee Group Code of Conduct

The Calbee Group Code of Conduct serves as the foundation for each person working for the Calbee Group to act according to high ethical standards and in keeping with our corporate philosophy.
As a member of the international community, the Calbee Group assures all stakeholders that we adhere fully to the Code of Conduct.

Compliance with Laws and Social Norms

We will comply with laws, social norms, internal and external rules, etc., and carry out business activities in good faith with fairness and justness.

  1. We will strictly manage information owned by the company, including personal information, and will not use or disclose them in violation of laws, social norms, internal, or external rules.
  2. We will endeavor to protect the company’s brand and the intellectual property rights of the company and will respect and not infringe the legitimate intellectual property rights of third parties.
  3. We will not improperly damage the profits of the company, such as by inducing profits for one’s self or third parties.
  4. We will have no relationship with antisocial forces or groups that threaten the order and safety of civilian life.
  5. We will not act unfairly or unjustly with any other party in our relationships with business partners.
  6. We will comply with local laws and regulations in our relationships with public officials, civil servants, and business partners, and will not give or receive inappropriate gifts, entertainment, money, or other benefits that cannot be explained to others.

Respect for Human Rights

We will treat all people involved in our business activities with respect at all times and value each other’s human rights.

  1. We will not participate in any human rights violations.
  2. We will also encourage our business partners not to be involved in human rights violations.
  3. We will not discriminate or harass people on the grounds of race, ethnicity, nationality, religion, beliefs, birthplace, gender, age, disability, sexual orientation, gender identity, etc.
  4. We will not tolerate any form of forced labor, child labor, or discrimination over employment or occupation.
  5. We will protect the freedom of association and the right to collective bargaining so that anyone can form a group.

Conservation and Protection of the Global Environment

We will co-create with stakeholders to work on the conservation and protection of the global environment in order to pass on the blessings of nature to the next generation.

  1. To prevent global warming, we will work to reduce greenhouse gas emissions throughout the value chain and aim for a carbon-free society.
  2. We will use water carefully, reduce waste, and make effective use of it to work on the realization of a resource recycling society.
  3. We will endeavor to conserve the natural environment with diversity in ecosystems and biology in order to pass on a global environment that supports affluent lifestyles.

Contribution to Customers’ “Healthy Living”

We will develop and provide products and services that are useful to society, and contribute to the sustainable “healthy living” of our customers.

  1. We will provide safe, secure, and high-quality products and services to earn the satisfaction and high trust of our customers.
  2. We will endeavor to build a relationship of trust with our customers by providing them with accurate information in a timely manner without the risk of misinterpretation or misunderstanding.
  3. We will create new value by sharing correct information with our customers and providing them with opportunities for communication such as factory tours and food education so we can learn about appropriate consumption behavior together.
  4. We will sincerely listen to each customer’s voice and strive to embody them in our products and services at all times.

Active Participation of Diverse Employees

We will work to create a workplace where diverse employees have an awareness of being part of the group and can respect each other and grow together.

  1. We will endeavor to create a work environment where people can work in good physical and mental health, in safety and with peace of mind, and take actions that pay attention to ensuring work safety and hygiene.
  2. We will respect each other so that we can fully demonstrate each of our diverse abilities and individualities.
  3. As colleagues who work together, we will foster a free and open organizational culture regardless of employment type, job title, years of experience, etc.,
  4. We will have a sense of ownership, fulfill the roles and responsibilities required of each of us, take on challenges with enthusiasm, and strive for further self-growth and success.

Solving Social Issues in Regions and Communities

Through our business, we will work to solve social issues in each region and community and contribute to the realization of a sustainable society.

  1. In order to coexist with local communities that have businesses from raw material production to consumption, we will deepen mutual exchanges with those communities, respect their culture, customs and traditions, and contribute to their development.
  2. As a good corporate citizen, we will deepen our ties in the areas of “environment (blessings of nature) ,” “food (deliciousness, enjoyment), " and “health (wellness)” and actively engage in social contribution activities.

Policies

Calbee Group Human Rights Policy

The Calbee Group*1 upholds the "Calbee Group Code of Conduct" based on the corporate philosophy, which states, "We are committed to harnessing nature’s gifts, to bringing taste and fun, and to contributing to healthy life styles." We strive to achieve a sustainable society through co-creation with stakeholders, bringing new value derived from nature’s gifts. We acknowledge potential for direct or indirect impacts on human rights in all business activities within our value chain. With the goal of ensuring the human rights for all people involved in our business, we hereby establish the "Calbee Group Human Rights Policy" (hereinafter referred to as “the Policy”).

*1 “The Calbee Group” refers to Calbee, Inc. and its consolidated subsidiaries collectively.

1. Basic Principles

We position the United Nations Guiding Principles on Business and Human Rights as the fundamental framework for respecting human rights. In addition, we endorse and respect the following international principles and standards:

  • International Bill of Human Rights
  • ILO Declaration on Fundamental Principles and Rights at Work
  • OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
  • The Ten Principles of the UN Global Compact
  • Children's Rights and Business Principles

2. Scope of Application

The Policy applies to all executives and employees of the Calbee Group. We also encourage our business partners to collaborate with us in promoting efforts to respect human rights.

3. Responsibility to Respect Human Rights

We strive to ensure that we do not directly or indirectly violate the human rights of all people involved in our business activities. If it is certain that our business activities have caused or contributed to adverse impacts on human rights, we are committed to taking appropriate measures to engage in the remediation.

4. Salient Issues related to Human Rights Initiatives

We recognize and address the following salient human rights issues for the Calbee Group:

(1)Discrimination and Harassment:
We do not tolerate discrimination based on race, ethnicity, nationality, religion, creed, place of origin, gender, age, disability, sexual orientation, gender identity, etc., or any form of harassment, towards any stakeholders.

(2)Forced Labor and Child Labor:
We do not tolerate forced labor, child labor, and any other unfair labor practices.

(3)Excessive or Unreasonable Working Hours:
We comply with international standards on working hours and adhere to all applicable laws and regulations regarding working hours in the countries and regions where we operate.

(4)Occupational Health and Safety:
We ensure a safe and healthy work environment in accordance with laws and regulations related to occupational health and safety.

(5)Freedom of Association and Right to Collective Bargaining:
We respect the fundamental rights of employees concerning freedom of association and collective bargaining.

5. Commitment to Respect for Human Rights

(1)Human Rights Due Diligence
Based on the UN Guiding Principles on Business and Human Rights, we establish a human rights due diligence system to prevent and mitigate adverse impacts on human rights.

(2)Grievance Mechanism and Remedy
We establish and operate an effective grievance mechanism to enable individuals whose human rights haven been adversely impacted to report and seek consultation, thereby taking remedy measures.

(3)Dialogue and Consultation with Stakeholders
Upon the implementation of the Policy, we engage in dialogue and consultation with stakeholders on a continuous basis.

(4)Education and Awareness Raising
To incorporate the Policy into all our business activities, we provide education to our executives and employees. Additionally, we conduct awareness-raising programs on the Policy for our business partners.

(5)Monitoring and Disclosure
We continuously monitor the status of our efforts in respecting human rights, strive for improvement, and disclose information through communication channels such as our website.

6. Human Rights Governance

To implement the Policy, we establish a cross-functional team within the Calbee Group and appoint a person responsible for the execution. We pursue initiatives in respecting human rights under the supervision of the Board of Directors.

March 25, 2024
Calbee, Inc.
Representative Director, President & CEO
Makoto Ehara
The policy has been approved by the Board of Directors of Calbee, Inc.

Calbee Group Procurement Policy

We at the Calbee Group embrace our corporate philosophy: “We are committed to harnessing nature's gifts, bringing taste and fun, and contributing to healthy lifestyles.” As members of the international community, we behave in an ethical manner in accordance with the Calbee Group Code of Conduct. In carrying out procurement activities, we observe social conventions and conduct ourselves in accordance with the Calbee Group Procurement Policy, which is based on our corporate philosophy and the Code of Conduct. In addition, we address and deal with human rights and environmental issues arising in our supply chain as well as social issues facing our communities. We will build a sustainable society in partnership with our customers.

I. Compliance with Laws and Regulations and Social Conventions and Pursuit of Fair Business Activities

  1. We comply with all applicable laws and regulations and social conventions of both Japan and other countries, and strive to build a sustainable society.
  2. We have a system in place that allows any employee or business partner who becomes aware of any actual or suspected compliance violation, such as non-compliance with laws and regulations or fraud, to report or raise their concerns with an external body. We ensure information provided by people who report or raise concerns will be kept confidential, and that they will not be treated unfairly. (A Calbee Group Ethical Conduct Helpline is provided.)
  3. We have a correct understanding of and comply with labor laws and regulations, and the Calbee Group's rules and regulations.
  4. We conclude non-disclosure agreements with regard to any information that we may become aware of in the course of our procurement activities, and manage the information in such a way that prevents data breaches. Furthermore, we take measures to prevent computer network security threats.

II. Respect for Human Rights

  1. We support and respect the protection of internationally proclaimed human rights and prohibit any inhumane treatment. Furthermore, we will not be complicit in any human rights violations and will urge our business partners to do the same.
  2. We respect the human rights of business partners in our supply chain. We will not discriminate against or harass anyone on the basis of race, ethnicity, nationality, religion, creed, place of origin, sex, age, disability, sexual orientation, or gender identity.

III. Environmental Conservation and Protection

  1. In order to mitigate climate change, we seek to reduce greenhouse gas emissions in the supply chain in the course of our procurement activities, and to create a carbon-free society.
  2. We aim to create a recycling-oriented society through waste reduction and the effective use of resources.
  3. We endeavor to conserve the natural environment and support No Deforestation commitments to ensure that future generations will have good lives and plenty of resources.

IV. Ensuring Quality and Safety

  1. We ensure safety and quality management by performing assessments and defining standards and specifications.
  2. We purchase products and services that conform to standards specified by laws and regulations of Japan and/or other countries, and meet quality specifications which may be separately specified.

V. Living in Harmony and Co-creation with Society

  1. We visit, have dialogue, and interact with those who produce ingredients for our products in order to help develop their communities. We respect their local cultures, customs, and traditions and contribute to their preservation.
  2. As a good corporate citizen, we enhance our connection to society through the environment (nature's gifts), food (taste and fun), and health (healthy lifestyles).

Implemented in October 2016
Amended in April 2022

Calbee Group Palm Oil Procurement Policy

The Calbee Group supports No Deforestation, No Peat, No Exploitation (NDPE) commitments. Together with its suppliers, the Group is committed to sourcing certified palm oil from sustainable supply chains by following the principles described below:

  • Protection of High Conservation Value (HCV) forests and High Carbon Stock (HCS) forests
  • No development on peatland regardless of depth, and no land preparation or land clearing using fire
  • Prohibition of the infringement of human rights, including child labor and forced or compulsory labor
  • Respect for the rights of indigenous peoples and local communities and the rights of workers

Implemented in April 2022

Calbee Group Bribery Prevention Policy

We, the Calbee Group (“Calbee” or“we”), clearly state, in our Group Corporate Vision, that “To be a company that is respected, admired,and loved, by customers and business partners, by employees and their families, by local communities, and by shareholders.”Moreover, in our Code of Conduct (including action guidelines), Calbee represents that we will not offer or accept any interest or benefit which conflicts with socially-accepted principles. To obtain further reliance from the society and to ensure sustainable development, Calbee hereby establishes this Policy and will work on preventing bribery in all countries and areas where we engage in business as a group.

1.Prohibition on Offering Bribes

Calbee will not tolerate any act of offering bribes, such as offering, promising or proposing any money or other interests or benefits (collectively “Money, etc.”) to a third party, whether directly or indirectly, for the purpose of achieving or maintaining any business or business benefits for Calbee, inside or outside of Japan.

2.Prohibition on Acceptance of Bribes

Calbee will not tolerate any act of accepting bribes, such as receiving or demanding any Money, etc. from a third party, whether directly or indirectly, for the purpose of achieving or maintaining any business or business benefits for Calbee, inside or outside of Japan.

3.Dealing with Public Officials, etc.

Calbee will engage in business activities in compliance with the Anti-Bribery Laws of Each Country (as defined below), refraining from engaging in any act of offering bribes to the public officials of each respective country and to persons similar thereto, such as officers and employees of national governments, local governments, government enterprises, political parties, and international institutions (collectively “Public Officials, etc.”).

4.Dealing with Third Parties

Calbee will not tolerate any act of offering bribes to Public Officials, etc., which may be conducted through a third party, such as any of our agents or consultants.

5.Thorough Management of Records

Calbee will comply with this Policy and the Anti-Bribery Laws of Each Country and will keep accurate records in accounting books, etc. based on the facts and properly store related books and vouchers, etc. under an appropriate internal control system.

6.Measures Taken Against Violations, etc.

In the event of a violation of this Policy or any of the Anti-Bribery Laws of Each Country, Calbee will take strict measures against the same, by taking necessary internal actions and providing full cooperation to investigations performed by relevant authorities, etc.

7.Modifications

Calbee will promptly modify this Policy where necessary, in order to comply with the Anti-Bribery Laws of Each Country.

Definitions

As used in this Policy, the following terms shall have the following meanings:

  • (1) “Calbee Group” applies to all officers and employees of Calbee, Inc. and its domestic and overseas affiliates.
  • (2) “Money, etc.” means:
    • cash, tradable coupons, gift vouchers, unlisted shares, financing, collateral;
    • gifts, entertainment, invitations (to sporting or theater events, or travel)
    • donations, contributions, sponsorship fees; and ex gratia payments, rebates, etc.
    In addition, in some countries and areas, Public Officials, etc. may demand payments in small amounts other than on the basis of applicable laws or regulations (“Facilitation Payments”), in relation to customs clearance or inspections, the issuance of an entry visa or a visa to stay, an application for the extension thereof, or the like. Such Facilitation Payments are also prohibited as they fall under the offering of bribes to Public Officials, etc
  • (3) “Anti-Bribery Laws of Each Country” means:
    1. Japan Article 18 of the Unfair Competition Prevention Act; National Public Service Ethics Act
    2. United States Foreign Corrupt Practices Act (the “FCPA”)
    3. United Kingdom UK Bribery Act 2010
    4. Others OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

Established on September 1, 2016

Statement Relating to UK Modern Slavery Act

Calbee Group Environmental Policy

We at the Calbee Group embrace our corporate philosophy: “We are committed to harnessing nature's gifts, bringing taste and fun, and contributing to healthy lifestyles.” As members of the international community, we behave in an ethical manner in accordance with the Calbee Group Code of Conduct.
We recognize that all business activities rely upon and affect natural capital, and we aim to build a sustainable society in order to pass on nature’s gifts to future generations. To this end, we co-create with stakeholders in our entire value chain to address the conservation and protection of the global environment.

  1. Compliance with laws and regulations

    We comply with environmental laws and regulations of Japan and other countries.

  2. Offering environmentally friendly products

    We endeavor to offer products that have less impact on the environment at all stages of their life cycle.

  3. Transitioning to a carbon-free society

    We strive to achieve net zero in our entire value chain in order to reduce greenhouse gas emissions which cause climate change.

  4. Promotion of a recycling society

    We carefully use nature's gifts, such as raw materials, water, and other resources, and we aim to develop a system to recycle these resources.

  5. Conservation of biodiversity

    We are a company that relies upon nature's gifts, and we address the conservation and regeneration of biodiversity.

  6. Raising awareness

    We continue to educate all employees on environmental issues to raise their awareness.

  7. Communication with society

    We work with stakeholders to implement environmental conservation initiatives, have active dialogues with them, and disclose information.

Human Resources Policy: Calbee HR Value

1.All Employee Activities

  • Calbee creates frameworks and teams such that all members can be active while embracing diversity (being active means utilizing the strengths of each person).
  • We are increasing psychologically safe workplaces where everyone can be active and take on challenges.

2.Growth Mindset

  • Believing in the potential of its people, Calbee interacts with human resources with the mindset that “everyone can improve their talent and skills through experience and effort”.

3.Human resources that exceed and connect

  • Calbee is fostering the talent for its future by developing those people that “exceed” the person they were the day before, outdated rules, organizational walls, the limits of preconceptions and perceived capability, and above all, customers’ expectations.
  • We are also developing human resources that “connect” people to people, teams to teams, customers to customers, good jobs to business partners, and the present to the future with flavor and fun to create new value.

4.Happiness & Well-Being

  • Our aim is that Calbee employees and their families, customers, business partners, and everyone involved in Calbee, be physically, mentally and socially healthy and happy.

Calbee Diversity Declaration

Harvest diversity. Let’s make it grow, Calbee and I.
Recognizing each other’s values and getting the maximum benefit from them.
It is diversity that powers Calbee’s growth.
Just can’t stop when it comes to both life and work.

Calbee Group Health Declaration

Harvest the bright future.
We value good health while we care for each other, both at work and home.
Wellness is essential for best performance.
It drives Calbee’s growth when it encourages personal growth.
“ Yamerarenai Tomaranai ” enjoy LIFE and WORK.

Calbee Group’s Social Contribution Mission Statement

We, as Calbee Group employees and good citizens,
will contribute to the communities in which
we live and work and also to the global community.

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