Introduction
Within business carried out by Beer Sten AS worldwide we are committed to be socially and environmentally responsible for all our actions. We have this responsibility towards all who buy our products or take part in their production or distribution.

Based on our commitment we have set up this Code of Conduct to make our position clear for all our suppliers, for our own staff and for other partners. Our Code of Conduct contains labour-and environment requirements, as well as other ethical requirements, which accord with provisions in international conventions and instruments, such as the ILO Core Conventions.

In many cases the Code requirements are the same as provisions specified in National laws and regulations. Should the provisions of national law and the requirement of our Code of conduct differ, the highest standard shall apply.

The requirements of our Code of Conduct are non-negotiable and shall be complied with by our suppliers, and their subcontractors, through all their activities. Yet, we stress that we will not terminate business in case of non-compliances. If non-compliances occur, we expect corrective actions to be taken within a reasonable time frame agreed upon between the supplier and Beer Sten AS.

We understand that not all changes can be attained overnight and we believe in a process approach. Only after repeated failure or unwillingness to carry out corrective actions, may business with the supplier be terminated.

Nevertheless, when placing new orders, the level of compliance with our Code of Conduct and willingness to make improvements will be an important criterion for selection of suppliers. The principle aim of our Code of Conduct is to help improve the social and environmental conditions of our suppliers. A high quality product will, eventually by definition be produced in compliance with CSR-norms.

Supplier is the contractual partner responsible for the product, process or service supplied to Beer Sten AS.

Subcontractor is a business entity in the supply chain directly or indirectly providing the supplier with goods and/or services integral to, and utilized in/for the production of the supplier’s goods and/or services.


Principles
The business relationship between Beer Sten AS and its suppliers shall be based on mutual respect, and all parties shall communicate in a good and constructive manner throughout the process.


Beer Sten AS goal
Our goal is to influence the work for respect for Human & Labour Rights and environmental protection both within the company and towards our business partners.

Favouring of producers and producing countries
Beer Sten AS will, when choosing suppliers, in addition to other competition aspects, consider social and environmental standards. Compliance with these standards, and demonstrated will to improve these aspects of the operations, is considered as a competitive advantage and will be taken into consideration when choosing suppliers and vendors

Boycott of individual countries
Beer Sten AS aim avoiding buying from countries where there is broad international consensus to boycott because of the country’s human rights situation.

Corruption and bribery
Beer Sten AS, including all employees, do not accept the offer, gift or acceptance of a bribe in any form, including kickbacks, on any portion of a contract payment, or the use of other routes or channels to provide improper benefits to customers, agents, contractors, suppliers, or employees of any such party or governmental officials

Continuous evaluation and improvement of Beer Sten AS internal policies and practices
Beer Sten AS will continuously evaluate and, if applicable, improve our own policy and purchasing practices in order to facilitate suppliers and subcontractors compliance with this Code of Conduct.


Requirements – own business
Beer Sten AS acknowledges that our business conduct can potentially have negative impact on people, society and the environment. At the same time, we see the potential to contribute to positive development in the supply chain. With this in mind, we have compiled the following principles and criteria guiding our own business:

Due diligence
Beer Sten AS shall conduct due diligence for responsible business conduct. This involves; conducting risk assessments to identify potential negative impact on people, society and the environment and to stop, prevent and reduce such impact. The measures put in place are monitored and their effect evaluated. The measures are communicated to those affected by our actions. If our activities are found to cause or contribute to negative impact on people, society or the environment, we will stop the activities and seek to provide remedy. If our supplier is responsible for the negative impact, the supplier is responsible for providing remedy.

Responsible purchasing practices
Beer Sten AS considers responsible purchasing practices to be one of our most important tools for responsible business conduct. Beer Sten AS shall adapt our purchasing practices in order to strengthen, and not undermine, our suppliers’ ability to deliver on our requirements related to people, society and the environment. We strive towards lasting supplier relationships with suppliers who show a particular willingness and ability to create positive developments in the supply chain.

Freedom of association and worker representation
Beer Sten AS supports the right to freedom of association and other forms of democratically elected worker representation. We shall involve worker representatives and other relevant stakeholders in our work with responsible business conduct.

Supplier development and partnership
In dialogue with suppliers we will consider, if needed, to contribute with capacity building or resources that enable our suppliers to comply with Beer Sten AS’s requirements related to responsible business conduct. This way we lay the foundation for collaboration with suppliers that show the willingness and ability to work on positive development for people, society and the environment in the supply chain.

Anti-corruption
Beer Sten AS ,including all employees, shall never offer or receive illegal or inappropriate monetary gifts or other remuneration to achieve private or business benefits in their own interest or in the interest of customers, agents or suppliers.

Countries affected by trade boycott
Beer Sten AS , including all our suppliers and partners, shall avoid trading with partners that have activities in countries where a trade boycott is imposed by the UN and/or Norwegian Government authorities.

Requirements - conditions in the supply chain
We expect our suppliers and partners to work focused and systematically to comply with our guidelines for suppliers, hereunder our code of conduct, that covers fundamental requirements on human rights, labour rights, anti-corruption, animal welfare and the environment. Our suppliers shall:

  • Follow our guidelines for suppliers, hereunder the code of conduct.
  • Conduct due diligence for responsible business conduct. This involves; conducting risk assessments to identify potential negative impact on people, society and the environment and to stop, prevent and reduce such impact. The measures put in place must be monitored and their effect evaluated. The measures taken must be communicated to those affected by your actions. If the supplier is responsible for the negative impact/damage, they are responsible for providing remedy.
  • Show willingness and ability to continuous improvement for people, society and the environment through collaboration.
  • At the request of Beer Sten AS be able to document how they, and potential subcontractors, work to comply with the guidelines.
  • If the supplier, after several requests by Beer Sten AS, does not show the willingness or ability to comply with the guidelines for suppliers, the contract may be cancelled.

    Code of Conduct- Principles for responsible business conduct
    These principles for responsible business conduct are based on UN and ILO conventions and provide minimum, not maximum standards. The relevant legal framework at the place of production shall be respected. Where national laws and regulations address the same subjects asthese guidelines, the most stringent shall apply.

    1. Forced and compulsory labour (ILO Conventions Nos. 29 and 105)
    1.1. There shall be no forced, bonded or involuntary prison labour.
    1.2. Workers shall not be required to lodge deposits or identity papers with their employer and shall be free to leave their employer after reasonable notice.

    Example of verification:

    Evidence from third party organisation interviews, of employees expressing that they are not forced to work or stay with the company to work

    2. Freedom of Association and the Right to Collective Bargaining (ILO Conventions Nos. 87, 98, 135 and 154)

    2.1. Workers, without distinction, shall have the right to join or form trade unions of their own choosing and to bargain collectively. The employer shall not interfere with, obstruct, the formation of unions or collective bargaining.

    2.2 Workers’ representatives shall not be discriminated and shall have access to carry out their representative functions in the workplace.

    2.3 Where the right to freedom of association and/or collective bargaining is restricted under law, the employer shall facilitate, and not hinder, the development of alternative forms of independent and free workers representation and negotiations.

    3. Child Labour (UN Convention on the Rights of the Child, ILO Conventions Nos. 138, 182 and 79, and ILO Recommendation No. 146)
    3.1. The minimum age for workers shall not be less than 15 and comply with the national minimum age for employment, or; the age of completion of compulsory education, whichever of these is higher. If local minimum is set at 14 years in accordance with developing country exceptions under ILO Convention 138, this lower age may apply.

    3.3. There shall be no recruitment of child labour defined as any work performed by a child younger than the age(s) specified above.

    3.4. No person under the age of 18 shall be engaged in labour that is hazardous to their health, safety or morals, including night work.

    3.5. Policies and procedures for remediation of child labour prohibited by ILO conventions no. 138 and 182, shall be established, documented, and communicated to personnel and other interested parties. Adequate support shall be provided to enable such children to attend and complete compulsory education.

    Example of verification:

    The company documents the date of birth of all young employees with valid documentation
    such as, for example, school leaving certificate, passport or, dental report from approved surgeon.

    4. Discrimination (ILO Conventions Nos. 100 and 111 and the UN Convention onDiscrimination Against Women)
    4.1. There shall be no discrimination at the workplace in hiring, compensation, access to training, promotion, termination or retirement based on ethnic background, caste, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

    4.2. Measures shall be established to protect workers from sexually intrusive, threatening, insulting or exploitative behaviour, and from discrimination or termination of employment on unjustifiable grounds, e.g. marriage, pregnancy, parenthood or HIV status.

    Example of verification:

    Evidence from third party organization interviews.

    5. Harsh or Inhumane Treatment (UN Covenant on Civil and Political Rights, Art. 7)
    5.1. Physical abuse or punishment, or threats of physical abuse, sexual or other harassment and verbal abuse, as well as other forms of intimidation, is prohibited.


    6. Health and Safety (ILO Convention No. 155 and ILO Recommendation No. 164)
    6.1. The working environment shall be safe and hygienic, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Hazardous chemicals and other substances shall be carefully managed. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in, the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

    6.2. Workers shall receive regular and documented health and safety training, and such training shall be repeated for new or reassigned workers.

    6.3. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

    6.4. Accommodation, where provided, shall be clean, safe and adequately ventilated, and shall have access to clean toilet facilities and potable water.

    Example of verification:

    The company has documented and implemented a health and safety program and provides
    adequate funding and attention to the programme. Inspections carried out by competent authority or independent
    inspection company.

    7. Wages (ILO Convention No. 131)
    7.1. Wages and benefits paid for a standard working week shall as minimum meet national legal standards or industry benchmark standards, whichever is higher. Wages should always be enough to meet basic needs, including some discretionary income.

    7.2. All workers shall be provided with a written and comprehensible contract outlining their wage conditions and method of payments before entering employment.

    7.3. Deductions from wages as a disciplinary measure shall not be permitted.

    Example of verification:

    The company to have an employment register listing the name of the employee, the nature of
    work performed, the wages paid and hours worked(including overtime).

    8. Working Hours (ILO Convention No. 1 and 14)
    8.1. Working hours shall comply with national laws and benchmark industry standards, and not more than prevailing international standards. Weekly working hours should not on a regular basis be more than 48 hours.

    8.2. Workers shall be provided with at least one day off for every 7 day period

    8.3. Overtime shall be limited and voluntary. Recommended maximum overtime is 12 hours per week, i.e. that the total working week including overtime shall not exceed 60 hours. Exceptions to this are accepted when regulated by a collective bargaining agreement.

    8.4. Workers shall always receive overtime pay for all hours worked over and above the normal working hours (see 8.1 above), minimum in accordance with relevant legislation.

    9. Regular Employment (ILO Convention No. 95, 158, 175, 177 and 181)
    9.1. Obligations to employees under international conventions, national law and regulations concerning regular employment shall not be avoided through the use of short term contracting (such as contract labour, casual labour or day labour), sub-contractors or other labour relationships.

    9.2. All workers are entitled to a contract of employment in a language they understand.

    9.3. The duration and content of apprenticeship programmes shall be clearly defined.


    10. Marginalized Populations (UN Covenant on Civil and Political Rights, art. 1 and 2)
    10.1. Production and the use of natural resources shall not contribute to the destruction and/or degradation of the resources and income base for marginalized populations, such as in claiming large land areas, use of water or other natural resources on which these populations are dependent.

    11. Environment
    11.1. Negative impact on the environment shall be reduced throughout the value chain. In line with the precautionary principle, measures shall be taken to continuously minimize greenhouse gas emissions and local pollution, the use of harmful chemicals, pesticides, and to ensure sustainable resource extraction and management of water, oceans, forest and land, and the conservation of biodiversity.

    11.2. National and international environmental legislation and regulations shall be respected and relevant discharge permits obtained.


    12. Corruption
    12.1. Corruption in any form is not accepted, including bribery, extortion, kickbacks and improper private or professional benefits to customers, agents, contractors, suppliers or employees of any such party or government officials.

    13. Animal welfareg
    13.1 Animal welfare shall be respected. Measures should be taken to minimize any negative impact on the welfare of livestock and working animals.

    13.2 National and international animal welfare legislation and regulations shall be respected.


    14. Management system
    The supplier shall take positive actions to implement the requirements of this standard, to incorporate the standard into all of its operations, and to make the standard an integral part of its overall philosophy.

    The supplier shall assign responsibility for all matters pertaining to this Code of Conduct to a manager within its organisation.

    Top Management of the supplier shall periodically review the operation of the requirements of this standard.

    The supplier accepts responsibility for observing the requirements of this standard with respect to all employees and workers that it supervises and agrees to:
    a – assign responsibility for implementing this standard at each place that it owns or controls to an employee.
    b – ensure that employees and workers are aware of the standard by communicating its contents an a language understood by them.
    c – refrain from disciplining, dismissing or otherwise discriminating against any employee for providing information concerning observance of this standard.

    The supplier shall maintain appropriate records to demonstrate conformance to the requirements of this standard, and shall be able to provide reasonable information and access to parties approved by Beer Sten AS seeking to verify conformance.

    The supplier will make observance of this Code of Conduct a condition of all agreements that it enters into with subcontractors. These agreements shall oblige these subcontractors to conform to all requirements of this standard and participate in the supplier’s monitoring activities as requested.

    Regarding the use of agents, or several factories or suppliers that have sub-contractors, all links shall be traceable concerning manufacturing location with respect to the manufactured goods delivered to Beer Sten AS. Any sub-contracting shall be agreed upon by Beer Sten AS prior to any production.


    15. Auditing and monitoring
    To evaluate the compliance of this Code of Conduct Beer Sten AS will make use of audits either by own personnel or by approved third parties. We reserve the right to monitor the compliance of this Code of Conduct by systematic, unannounced or announced inspections, conducted by Beer Sten AS personnel or independent auditors.


    16. Corrective Action and Non-Compliance
    Beer Sten AS Code of Conduct sets the standard expected to be met by all our suppliers and partners during operation and manufacturing. We are fully aware that all expectations can’t be met immediately, but these as well as non-compliances are to be settled by corrective actions by the supplier. If repeated violations are established without any effort by the supplier to take appropriate actions, it is our duty to terminate the cooperation with such suppliers.