A. Introduction

Peterson and Control Union companies provide trust services to the industry. With specialist knowledge and years of experience we are a reliable partner for our clients and stakeholders.

We are a decentralised, diversified group of companies with widespread activities, and each company has wide freedom of action. However, what we have in common is the Peterson and Control Union reputation. Upholding our reputation is paramount. We are judged by how we act. Our reputation will be upheld if  we act with honesty and integrity in all our dealings, and we do what we think is right at all times, within the legitimate role of business.

Peterson and Control Union companies have as their core values honesty, integrity and respect for people, society and environment. We also firmly believe in the fundamental importance of the promotion of trust, openness, teamwork and professionalism between these people, and a pride in what they do.

Our underlying corporate values determine our code of conduct. This code of conduct applies to all transactions, large or small, and describe the behaviour expected of every employee in every Peterson and Control Union company in the conduct of its business. We recognize that maintaining the trust and confidence of employees, customers and other people with whom they do business, as well as the communities in which they work, is crucial to the group’s growth and success.

It is the responsibility of the management to ensure that all employees are aware of this code of conduct and behave in accordance with the spirit as well as the letter of this statement.

Employees can always report (suspected) violations to their manager  without having to  fear for  retribution or penalties, as long as the reporting has been done in good faith. Reporting can also be done anonymously and confidentially to the management team.

Peterson and Control Union companies recognize four areas of responsibility: To those with whom they do business

To win and maintain customers by developing and providing products and services which offer value in terms of price, quality and safety, which are supported by the requisite technological and commercial expertise. To support free enterprise and competition. Third parties are not discredited in a manner that is untruthful or deceptive. To reflect our resources, capabilities, experience and services provided in an accurate and unambiguous way.

To society and stakeholders

To conduct business as responsible corporate members of society, to observe the laws of the countries in which they operate.

To shareholders

To protect shareholders’ investment and provide an acceptable return. To employees

To provide their employees with good and safe conditions of work, and good and competitive terms and conditions of service, to make the best possible training opportunities available, to promote the development and best use of human talent and equal opportunity employment, to encourage the involvement of employees in the planning and direction of their work, and in the application of this code within their company. It is recognized that commercial success depends on the full commitment of all employees.

B. Principles

1. Legal compliance

You must comply with all applicable domestic and international laws and legislations.

2.Business dealings

You must be honest, fair and incorruptible when dealing with clients, colleagues, government officials, the public, suppliers, competitors, shareholders or any stakeholder.

3. Bribery and corruption

You must never offer or accept any bribes, inducements or facilitation payments which may be seen as inappropriate or instrumental to influence your actions or the actions of a third party. Payments made through third parties such as agents or partners are not allowed either. When you have doubts, seek immediate advice with your manager.

4. Conflict of interest

You must avoid  situations that present  an actual or  potential conflict  between  personal  interest and the interest of the company. Contact your manager when you are in doubt or suspect the occurrence of any conflict of interest. You may not acquire (directly or indirectly) an interest in a supplier, client or competitor, except for  shares on  a public stock exchange to  the  extent which does not grant significant influence. You do not hold any position with a competitor or client and do not conduct any company business with any member of their family or associates of their family.

5. Reputation

You must not act in any way that would prejudice the reputation of Peterson or Control Union and acknowledged accreditation bodies related to the inspection and certification business.

6. Gifts

The offer and receipt of gifts or entertainment must always be reasonable in value, quantity and frequency. It must be related to the business interest, permitted under local law and deemed appropriate by objective third parties.

7. Partners

All business partners such as agents, representatives, joint venture partners or any other third parties must comply with this code of conduct, applicable local and international law and company policies. Due diligence must be done on all current and future business partners.

8. Political activities

Political contribution or intervention is not allowed for Peterson and Control Union companies. Employees are allowed to conduct political  activities in their own time and never as representative for the company. It is not allowed to use company resources for political activities. Relations with NGOs are maintained for business purposes only, not to intervene in political matters.

9. Business opportunities

During the course of their career all personnel owe a duty to their employer to advance its interest when the opportunity to do so arises. All these opportunities and ideas are the property of the company and are not allowed to be used by personnel for their personal benefit without prior permission.

10. Confidentiality

All information which is entrusted to the personnel must be kept confidential and unless you are required to do so by law, disclosure is under no circumstances allowed. Any information which is acquired by using illegal or unethical means will never be used. By signing this code of conduct you also sign for confidentiality (non-disclosure).

11. Equal opportunities

All personnel shall be hired or make promotion based on their qualifications, skills, performance, capability and other job-related criteria. No discrimination on the basis of race, religion, national origin, gender, age or sexual preference shall be made. Harassment, violence and intimidation are never tolerated.

12. Management systems, quality, health, safety and environment

You must adhere strictly to the management system and the manuals, procedures and instructions regarding the execution of the work and quality, health, safety and environment. Each employee is responsible and accountable for maintaining a safe and healthy workplace. You have authority to stop the job if it is considered unsafe to continue.

13. Records

All records and accounts shall be maintained in a proper and timely manner in order to comply with all financial, legal, regulatory and operational objectives and requirements. It is never allowed to modify, falsify or destruct any records and accounts. Unrecorded or undisclosed funds, assets or accounts are not allowed, nor to make or receive any unrecorded or undisclosed payments. Where approved test methods make more provisions for tolerances in results, employees may not abuse such tolerances to alter their actual findings.

14. ICT

All lCT facilities must be used in their designated way and are provided to help all personnel to do their job. Limited personal use is acceptable if it does not interfere with your work, this code of conduct or any other regulations or rules that might apply. The company reserves the right to access and disclose all information on our ICT infr ast ruct ure .

15. Competition

All personnel shall never agree, not even informally, with competitors on pricing, production, customers or markets. Care must be taken when meeting competitors.

16. Inspection and certification

Employees must carry out inspections and certification independently and in an unbiased manner. Employees are not allowed to give advice or provide consultancy services to inspection or certification applicants or inspected or  certified operations. There may not  be a commercial interest, like family interest  or the  provision of consulting services to  the  client or related activity for a period within 24 months prior to inspection or certification. For RSPO this period is 36 months.

I understand and agree to this code of conduct by signing this document.