Join Euro Pool Group on our circular journey – get in touch now.
Euro Pool Group enables supply chain circularity, in order to drive efficiency and sustainability in the retail supply chain with reusable packaging. As a major European pooling operator, Euro Pool Group conducts its business in line with its corporate values and the highest possible standards that exist within the European pooling industry. With an entrepreneurial spirit, drive and commitment, we deal with all our stakeholders and the community around us with respect and integrity. We do what we promise, all in accordance with our values and applicable laws.
This Code of Conduct illustrates these values and provide the tools that will guide us in making consistent, sustainable business decisions. We enjoy the trust and respect of our customers, business partners, and other shareholders. It is good to know that even minor violations of this Code of Conduct could damage Euro Pool Group’s reputation and could inflict economic damage. Therefore, all of us are requested to take the Code of Conduct seriously and to embed it in our day-to-day thoughts and actions.
G. J. Scheringa
Chief Executive Officer
Euro Pool Group
April 2024
Reading and adhering to our Code of Conduct helps each of us to follow the Euro Pool Group way of doing business:
Our business conduct regarding safety, protection of human rights and protection of our planet is based on integrity and respect.
Our customers expect us to deliver high-quality, legally compliant and safe trays and pallets for the food industry. Therefore, our trays and pallets must meet the highest standards for food safety.
Our focus on safety also includes the safety for people: we are committed to a safe working environment in which everyone takes responsibility for their own safety and that of others. Safety always comes first, also for our people.
As an international company operating in many countries, our workforce is very diverse. We embrace diversity and professional and personal development. We need motivated and well-trained employees to reach our goals. We favour an open communication with all employees.
We support and respect internationally recognised human rights for all stakeholders. At Euro Pool Group, employees do not discriminate or harass others based on, for example, race, colour, gender, sexual orientation, age, religion, political opinion, national, ethnic or social origin. We encourage every employee to directly address any form of discrimination or harassment. We do not tolerate child labour and forced labour. Euro Pool Group contributes to the elimination of these wherever we can. We expect all our business partners to do the same and to adhere to our EPG Supplier Code of Conduct.
We are committed to running our business in an environmentally sound and sustainable manner and take pride in being a business that has sustainability at its core and in the hearts of its people. We minimise the impact of our processes and products on the environment and we strive to enable supply chain circularity. We enhance efficiency through reusable packaging solutions, serving as a collaborative partner in retail for circular progress. In this way we contribute together to sustainable development without preventing future generations from fulfilling their own needs. Part of our sustainability goals and efforts will be reported in the so-called Sustainability report and later in the ESG report.
Working at Euro Pool Group means working and acting impartially in the best interest of our company. A conflict of interest can occur when our personal interests (e.g. family, friendships, financial factors or social factors) can compromise or improperly influence our judgement, decisions, performance of our duties or actions in our company. We avoid situations where our personal interests conflict or appear to conflict with the interests of our company. We talk about the existence (or potential existence) of a conflict of interest in a transparent way with our colleagues and manager. We are open, honest and avoid even the appearance of a possible conflict of interest. If necessary, we draw back.
Our business conduct towards our business partners and others is honest and transparent.
As a reliable partner Euro Pool Group stands for trust, solidity and innovation. Our business partners expect Euro Pool Group and its staff to act in accordance with applicable laws and regulations. We follow this responsibility and expect our business partners to do so too.
At Euro Pool Group we stand for honest business practices and therefore we do not commit or allow any form of bribery. We do not provide or promise anything of value to any person with the aim of improperly receiving preferential treatment nor do we request or accept a bribe or request or allow others to do so.
We should be restrictive in providing and accepting invitations to entertainment and gifts and only use gifts and entertainment to develop or strengthen business relations, to show appreciation or to create goodwill when appropriate. The proposed gift or entertainment should be appropriate in value and nature considering local customs, the position of the recipient and the circumstances. In any case, we always check the policies, website or agreement of our business relations to make sure that providing gifts or entertainment is acceptable.
In relations with government officials, we are even more careful. Therefore, at Euro Pool Group, we should not offer or promise any gift or entertainment to any government official, directly or via a third party, to influence such official’s actions or to obtain improper advantage.
For more information and guidelines on providing or receiving gifts, check out our Anti-Bribery page on the internal compliance site and the Gifts & Entertainment Policy.
As a company we do not support political parties nor do we make financial or other contributions (in time or products) to persons in politics. Employees who do so in their spare time should not give the impression that our company provides support. We make community contributions and charitable donations in a transparent and professional way, always in compliance with our internal rules.
We believe in competition based on fair play and an equal playing field. This is why we all conduct our activities in a fair and competitive manner while carefully complying with competition laws. When we have any doubts about an action being fully in line with competition rules, we first discuss this internally with the Legal Department.
The principles of fair competition are described in more detail on our Competition Law page on the internal Compliance site.
We are all ambassadors of Euro Pool Group. Our actions captured via images, posts or comments online can reflect on Euro Pool Group. In all our communications, including social media, each of us is therefore expected to communicate openly, respectfully and prudently and never to jeopardise our excellent reputation. When using social media we do this in a responsible manner, always using common sense and professional judgement, especially when using Euro Pool Group’s name.
Our business conduct aims at careful and honest use of company assets.
Each of us has access to various company resources and we are all responsible for protecting these. These company resources include computers, phones and machines, as well as our brands, innovations and intellectual property rights. We use resources in a careful way only for their intended business purposes and such that our company is not at risk.
We properly handle all confidential information of our company and others and protect it against unauthorised disclosure. Confidential information such as know-how, is a valuable asset that provides a competitive advantage. We only reveal our company confidential information to someone outside the company for an allowed business purpose. Even within our company, we only share confidential information with people who have a business ‘need to know’. We use confidential information of others only in a legal and honest way.
For more information on protection of confidential information check out the Privacy page on our internal Compliance site.
We respect the privacy rights of employees, members, consumers, customers, suppliers and other business partners and therefore we treat personal data confidentially. We only collect, process, transmit and use personal data insofar as reasonably required for communicated business purposes. We respect the confidential nature of any personal data and we take responsibility to keep such data accurate, complete, relevant and secure. We make sure that our collection and processing of personal data complies with the local laws and regulations and with our applicable policies.
For more information on processing of personal data, check out the Privacy page on our internal Compliance site.
We want to make business decisions based on all relevant facts. For this we need reliable data in conformity with our internal guidelines. We all have a duty to ensure that our financial and non-financial documents, records and reports (both internal and external) are accurate, complete, consistent and up-to-date.
We make sure that the financial reporting complies with the local laws and regulations and group accounting policies (Dutch Generally Accepted Accounting Principles (Dutch GAAP)).
We make sure that the ESG reporting complies with the local laws, regulations and the group reporting manual.
We do not accept any behaviour intended to deceive or mislead others. We expect each employee to contribute to preventing fraud within our company.
We must all focus on our targets while respecting our values and adhering to this Code of Conduct. Each of us is responsible for understanding the letter and spirit of this Code of Conduct and for following it. If any part hereof is unclear, it is your personal obligation to ask questions until you fully understand.
And we expect everyone to promote a culture of openness in which we all feel comfortable raising questions, dilemmas and concerns regarding the interpretation of, or adherence to, this Code of Conduct. Remaining silent in the event of a possible violation can only worsen a situation and decrease trust. Therefore, we encourage you to speak up if you ever have a concern or suspicion regarding a possible violation of law, our Code of Conduct or any of our other policies, without the fear of retaliation. To find out who to reach out to, check the Whistleblower page on the internal Compliance site.
Those of us in management positions have increased responsibilities. These include not only implementing the Code of Conduct and its policies but also leading by example. Creating a transparent and open environment, in which concerns or suspicions can be raised without fear of negative consequences, is essential to preserving our reputation and ability to operate.
For more information, check out the Whistleblower page on the internal Compliance site.
The consequences of neglecting or violating the law, this Code of Conduct or its underlying policies as well as not reporting a violation can have serious consequences for our company and the individuals involved. In addition to reputational damages it may lead to imprisonment, personal liability and fines. A violation of this Code may result in appropriate disciplinary action, including dismissal.
Join Euro Pool Group on our circular journey – get in touch now.