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Aalst Wilmar Pte Ltd © 2019

 

CODE OF BUSINESS AND CONDUCT ETHIC

Introduction and Application

Aalst Chocolate Pte Ltd ("the Company”) fully recognize that adherence to the highest standards of business conduct is vital to its growth and success as a prominent and reputable supplier in the industry.

This Code of Ethics (the “Code”) establishes the fundamental standards of conduct and values consistent with the principles of good governance and business ethics for observance by all staff, business partners, and suppliers. It does not intend to replace or supersede any applicable legal or regulatory requirement and reads into it existing Company policies, procedures and the corresponding sanctions for non - compliance therewith, as well as those that may subsequently be adopted by the Company in response to prevailing business conditions.

Policies and / or procedures may further be promulgated or revised as the need arises, to give effect to this Code. Thus, this Code shall henceforth be the foundation for all existing and future policies and procedures of the Company that these shall find basis in and supplement the provisions of this Code.
 

This Code shall be reviewed from time to time as may be deemed necessary by Aalst Chocolate Pte Ltd.

Message from the Head – Human Resources

 

Dear Colleagues,

This manual that you have in your hand contains our Company’s Code of Ethics. It illustrates how  a staff of Aalst Chocolate Pte Ltd must act, think and respond to work, circumstances and to society. It provides guiding principles that will help establish and sustain the integrity and image that Aalst Chocolate Pte Ltd as a Company, upholds.

As a staff and a business partner, we are expected to abide by these Codes. As we clock in every working day, and go about our business.

The Code of Ethics helps maintain the integrity of our name. It is our desire to keep the name of the company and its employees and stakeholders intact with integrity and kept in good faith. Maintaining our good name guarantees sustainability of our business because it wins the trust of our business partners – the families worldwide whom we have promised to nourish and nurture through our products and services.

 

Where the right to freedom of association and collective bargaining is restricted under law, our company facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

We uphold a no discrimination policy. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, national origin, religion, disability, gender, marital status, sexual orientation, union membership or political affiliation.

Discuss it freely with colleagues, be accountable to each other and most importantly, learn to live it every day. It is what we are expected to be as part of the Aalst family.

We look forward to your support and to your commitment to the Code of Ethics.

Sherin Tan

Head, Human Resources, 

Aalst Chocolate Pte Ltd

 

Expectations

  • We believe that what is expected in this Code is universal but cognizant of differences in culture and challenges in interpreting and applying the principles globally.

  • We recognize that the methods for meeting these expectations may vary in order to be consistent with the laws, values and cultural expectations of the countries where we operate.

  • The standards of conduct and values in this Code shall guide and define the actions and decisions of the Company

  • We expect all Staff to observe with such values in the performance of their duties, in their relationships with fellow Staff and in all their dealings with shareholders, customers, suppliers, government and the general public.

  • We expect all Business Partners / Suppliers to exhibit these values as a condition to their engagement, and for those existing at the time of effectivity hereof, and thereafter, to align and demonstrate compliance with the principles and standards stated in this Code at all times as a condition to their continued business relationship with the Company, as well as apply the Code to the parties with whom they work in providing goods and services to the Company.

 

 

Our Guiding Principles

Customer Focus

AALST CHOCOLATE PTE LTD is committed to achieve total customer satisfaction, ensure food defense is in place and prevent food fraud occurrence. We are also committed to ensure that the food safety and quality of all our chocolate and compound products meet standards.

 

We are committed to comply with all applicable statutory and regulatory requirements. We shall strive to protect the environment including prevention of pollution to environment, prevent all occupational injuries and ill - health and provide all our employees, subcontractors and visitors with a safe and healthy workplace.

 

This commitment applies to all processes from purchase and receipt of ingredients, raw and packaging materials to product development, production, quality control, storage and shipping of our products.

 

Innovativeness and Continuous Learning

“Doing it right the first time, all the time.”

  • We encourage creativity and ingenuity in our processes and systems, products and services, continuously looking for better ways to do things, always striving to be the first to deliver something better.

  • We create an environment that encourages learning, not only to deliver expectations but also to grow in knowledge and abilities.

 

Meritocracy and Passion for Success

  • We constantly strive for excellence. We aspire to be the best we can be and create value in everything we do. We are proactive and entrepreneurial, propelled by a sense of urgency and competitiveness, with speed and precision in execution, and total dedication to results.

  • We recognize and reward individuals and organizations on the basis of performance and results.

 

Accountability for Actions

  • We take full responsibility for all our actions and decisions, and discharge our duties conscientiously, honestly and efficiently.

  • We uphold and regard as paramount the Company’s interest in the undertaking of business strategies, opportunities and endeavors, with deliberate and full evaluation and management of attendant risks and the end view of enhancing and maximizing shareholder value.

  • We comply with and respect all applicable laws, rules and regulations governing the Company’s businesses, in all jurisdictions where such is conducted.

Integrity and Mental Honesty and Fair Play

  • We conduct business in a manner which is ethical, fair and right.

  • We compete fairly and honestly. Each one of us believes in profit in a fair and level playing field, and is committed to good governance and the highest moral standards in the performance of duties and responsibilities.

  • We ensure the integrity of our records, books and accounting, and endeavor fully, fairly, timely and accurately report and disclose material information in accordance with law and regulations.

  • We build and strengthen business relationships on the basis of merit, mutual interest, candor and fair competition, and avoid profit or gain of competitive advantage through manipulation, abuse of privileged or non - public information, concealment, misrepresentation and other illegal or unethical practices.

  • We exercise utmost discretion in accepting personal favors or gifts from persons seeking or doing business with the Company, and refuse to grant personal favors, or decline any gift or benefit that may compromise the independence of the Company, create a sense of obligation on its part or potentially influence its business judgment.

  • We avoid circumstances and positions that actually or potentially conflict with the interest of the Company or compromise our positions and objectivity in business dealings and relationships.

Transparency

  • We shall strive for transparency, openness and communication and accountability pertaining to operations, policies, processes and records keeping, in our dealing with our customers, suppliers and third parties.

Teamwork and Open Communication

  • We work toward shared aspirations, transcending boundaries along functional and organizational lines with trust and respect for each other and with unity in purpose.

  • We enable Staff to feel free to express opinions, voice concerns, and offer suggestions to their superiors and peers.

 

Respect for People, Authority and Property

  • We recognize each other as individuals and commit to nurturing each other's individual capabilities.

  • We respect and shall preserve the Company’s assets and resources by ensuring that they are used efficiently and solely for legitimate business purposes, and accord the same to the assets and properties of others.

  • We safeguard and maintain the confidentiality of knowledge or proprietary information on the Company’s products, formulations, trade secrets, business strategies, technologies, processes and system.

Labour and Human Right

The Company must comply with Singapore Employment Act.

 

Employment is Freely Choosen

  • There is no forced, bonded or involuntary prison labour.

  • Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

 

Working Conditions Are Safe and Hygienic

  • A safe and hygienic working environment shall be provided, bearing in mind the, prevailing knowledge of the industry and of any specific hazards.

  • Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new and reassigned workers.

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

  • Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

  • The company observing the code shall assign responsibilities for health and safety to a senior management representative.

 

Child Labour Shall Not Be Used

  • There shall be no recruitment of child labour.

  • Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; “child” and “child labour” being defined in the appendices.

  • Children and young persons under 18 shall not be employed as accordance to Ministry of Manpower regulations.

 

Living Wages Are Paid

  • Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

  • All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

  • Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

 

Working Hours Are Not Excessive

  • Working hours comply with national laws and benchmark industry standards, whichever affords greater protection.

  • In any event workers shall not on a regular basis be required to work in excess of 44 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary and in accordance with the national laws which provide compensation at a premium rate.

  • Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

 

Regular Employment Is Provided

  • To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.

  • Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour - only contracting, sub - contracting or home working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed - terms contracts of employment.

No Harsh or Inhuman Treatment Is Allowed

  • Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

 

Social Responsibility

  • We strive towards good corporate citizenship.

  • We contribute positively to the promotion of social responsibility in the community in which we live and work by supporting activities and programs geared towards community welfare and environmental protection.

 

Health, Safety and Environment

Aalst Chocolate and its Business Partners value the health and safety of human beings and the protection of the environment.

Worker Protection.

  • We shall have programs in place to ensure the safety of our workers. Programs must include elimination of occupational hazards in the workplace, provision of protective wear and / or equipment, proper training in the handling and use of machinery and materials, safety reminders and other measures that may be necessary to maintain safety.

  • We shall protect workers from undue exposure to chemical, biological and physical hazards. In case it is necessary to deal with any hazardous material, safety information relating to these must be provided to educate, train and safeguard workers.

  • The company is committed to an injury - free and illness - free workplace that is operated in an environmentally sound manner in compliance with all relevant laws and regulations that protect worker safety and the environment.

Emergency Preparedness / Life Safety

  • We shall identify, assess and prepare for potential emergency situations in the workplace and minimize their impact through prevention and readiness to implement emergency plans and response procedures. In case such an emergency occurs, we must immediately inform the proper authorities of the Company. Emergency exits should be sufficiently remote from each other, and exit routes to be marked with photo luminism tape, panel or paints and details the directions of evacuation with arrows.

  • Our facilities must be equipped with working audible fire/evacuation alarm, and alarm may be activated from various location, throughout the facility, and audible / visible (flashing red lights) if required, from all areas of the facility.

  • Exit Sign should be brightly colored, or illuminated visible from 30 meters, and the letters for Exit at least 6 inches in height.

 

Environmental Authorizations

We shall comply with all applicable environmental regulations. All required environmental permits, licenses, authorizations, registrations and clearances must be obtained and their operational and reporting requirements followed.

 

Waste and Emissions

We shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse or management of waste, air emissions and waste water discharges. Any waste, waste water or emissions with the potential to adversely impact human or environmental health must be appropriately managed, controlled and treated prior to release into the environment.

Hazardous Materials

We shall have systems in place that will ensure safety in handling, storage and releasing of hazardous materials, as well as procedures to manage and contain accidental spills and releases.

 

Management Systems

Aalst Chocolate and its Business Partners adhere to effective and efficient management systems to meet contractual obligations, facilitate continual improvement, and uphold the image and brands of the Company at all times.

Commitment and Accountability

We shall demonstrate commitment to the concepts described in this Code by allocating appropriate resources to fulfill the requirements. We express accountability by taking immediate corrective action in accordance with our contractual obligations.

 

Business Continuity

We shall have training programs that would enable the appropriate level of knowledge and skills among management team and workers necessary to meet our commitments.

Risk Assessment and Management

We shall have mechanisms to identify and mitigate risks in all areas of our operation that may affect our products and services.

Legal and Customer Requirements

We shall identify and comply with applicable laws, rules and regulations, and relevant customer requirements and standards in a responsible and timely fashion.

Documentation

We shall maintain documentation necessary to demonstrate conformance with the expectations set out in this Code, as well as compliance with applicable regulations.

 

Ethical Business Practices

Aalst Chocolate and its Business Partners conduct business with integrity and always in an ethical manner.

Business Integrity / Bribery

Any form of corruption, extortion and embezzlement shall be prohibited. We shall not offer, pay nor accept bribes or participate in other illegal inducements in business or government relationships. We shall work against corruption in all its forms.

 

Fair Competition

We shall conduct our business consistent with fair and vigorous competition and in compliance with applicable laws. We shall employ fair business practices including accurate and truthful advertising.

 

Trade Compliance

We shall comply with all applicable import and export controls, sanctions and other trade compliance laws of the Singapore and applicable laws of country (ies) where transaction(s) occur.

 

Product Quality and Food Safety

We, and any party involved in the supply, manufacturing, packaging, testing, storage and distribution of materials/products on behalf of the Aalst Chocolate, shall uphold compliance with the  Company quality and food safety standards, as well as applicable recognized quality regulations, standards and practices (e.g., Quality and Food Safety Regulations, Good Manufacturing Practices, Good Laboratory Practices, etc.) that are required in the markets where our products are registered and distributed.

 

Accuracy of Business Records / Financial Reporting

All our financial books and records shall conform to generally accepted accounting principles, and shall be accurate, legible, transparent, and reflect actual accounts of events, transactions, payments and other relevant facts about the business.

Protecting Information

We shall protect confidential and proprietary information, including personal information collected for or from the Company.

We shall prevent information loss, misuse, theft, fraud, improper access, wrongful disclosure or alteration, including unauthorized communication and/or publication of information acquired from or on behalf of the Company.

We shall make sure that any unauthorized use, disclosure or loss of the Food Group confidential or proprietary information is reported immediately to concerned Food Group authorities.

 

Intellectual Property

We shall respect intellectual property rights. The use of Company trademarks, copyrights, industrial designs, patents and other intellectual property rights, and the transfer of technology and know - how shall be done in a manner that strengthens the equity and protects intellectual property rights of the registered owners thereof, to maximize value and drive growth and innovation of our products and services.

Conflict of Interest

Staff and Business Partners have a duty to act in the best interests of the Company and shall avoid any action which may involve, or may appear to involve a conflict of interest with the Company.

Staff, while employed by the Company, shall:

  • Not seek employment or be engaged in outside business activities when such employment or activities prevent employees from fully performing work, including overtime assignments for which they are employed, unless otherwise agreed by prior consent.

  • Not act as members of boards of directors of companies with conflicts of interest or participate in competitive business activities.

  • Not have any financial or other business relationships with suppliers, customers or competitors that might impair, or even appear to impair the independence of any judgment they may need to make in the best interests of the Company.

Business Partners shall:

  • Avoid any interaction with any Company or competitor that might conflict, or appear to conflict with that Staff or Business Partner acting in the best interests of the Company.

In the event that the personal interests of a Staff or a Business Partner appear to conflict with the interests of the Company, proper disclosure by such Staff and/or Business Partner shall be made in order for the appropriate authorities to resolve the conflict.

Gifts, Meals, Entertainment

  • We shall not solicit nor accept gifts in any situation that may influence, or appear to influence decision in relation to Business Partners.

  • Modest gifts, meals or entertainment may be accepted provided they are consistent with the Company policy on Solicitation and Acceptance of Gifts.

 

Raising Concerns / Harassment / Abuse / Denied Access / Reporting

  • We encourage everyone to report concerns or questionable activities of Staff and Business Partners without fear of reprisal, intimidation or harassment.

  • Suggestion Boxes to be placed at appropriate location for staff to submit their feedback and suggestions and any reporting and to raise their concerns.

  • Aalst Chocolate will not tolerate any retaliation in any form against anyone who, in good faith, raises a concern or reports a possible legal or ethical violation of this Code. We will investigate and take corrective actions if needed.

  • Employees and Business Partners (including their employees and stakeholders) who believe that the Company Staff or anyone acting on behalf of the Company, has engaged in improper conduct must report the matter promptly to Aalst Chocolate through its “Compliance Committee”, using the following Violation Details Contact Form below:

Violation Details

  • The above link sets out the procedure in reporting concerns, consistent with the other policies and procedures implemented by the Company, as applicable.

  • The Compliance Officer will sort and direct the concerns it receives to the proper channels for necessary action, and shall oversee their resolution.

Compliance with the Code / Sanctions

The Compliance Officer of the Company, shall ensure at all times the observance of the Code and implementation of all relevant policies, including the imposition of all appropriate penalties under such policies, if any, in case of violation.

The Code nor the Committee, however, shall not be used for taking up personal grievances.