Heinz

Ethics and Compliance

 

August 27, 2012

H.J. Heinz Company
Global Operating Principles

 

PURPOSE

To convey to Heinz’s employees globally and to the public Heinz’s values and commitments.

In order to continue to be one of the world’s premier food companies, Heinz has developed these Global Operating Principles. Heinz respects its employees, and these Global Operating Principles are intended to promote the safe and fair treatment of all of its employees while fostering a sustainable culture. Heinz requires that its operating Business Units protect the environment and respect the cultural, ethnic, religious, political, and philosophical differences of people around the world. We recognize that Heinz must be responsible for its Global Operating Principles and we will review our performance with a view toward continued progress and improvement.

SCOPE

These Global Operating Principles apply to the H. J. Heinz Company and all of the facilities owned by, and all employees of, Heinz and its Business Units throughout the world (the “Company”). Heinz has also developed a set of guidelines for firms with whom Heinz and its Business Units worldwide have a contractual relationship, including contractors, suppliers of goods and services, co-packers, and joint venture partners. These Supplier Guiding Principles are set forth separately in a statement of principles for such business partners.

PRINCIPLES

H. J. Heinz Company is one of the world’s premier food companies. As the original “Pure Food” Company, Heinz is a trusted leader in nutrition and wellness, dedicated to providing superior food products and to the sustainable health of people, the planet, and our Company. Heinz strives to follow the advice of its founder, “To do a common thing uncommonly well brings success.”

HEINZ'S RELATIONSHIPS:

Consumers

The needs, health, and well being of our consumers are paramount. Heinz is committed to providing high quality, safe, and “pure food” products for all of our consumers, which include our own employees and their families.

Environment

We value the environment and are dedicated to protecting it. We recognize the relationship of our food processing operations to the environment and the need for sustainable environmental programs. Heinz aims to be efficient in the use of energy, raw materials, water, and packaging and has published specific sustainability goals which it is striving to achieve.

Partners

Our shareholders, customers, and business partners expect that Heinz will conduct its operations ethically and responsibly. Heinz and its employees share these values. Heinz insists on honesty and integrity in all aspects of its business and expects the same in its relationships with its business partners. Heinz prohibits any illegal payments to any person, organization, or government.

Employees

All Heinz employees will be treated fairly and with respect. Heinz is committed to providing a safe and healthful workplace for its employees. Heinz will encourage pride in the workplace and in its products. Heinz employees are required to comply with all applicable laws and regulations and to avoid personal activities and financial interests, which could conflict with their commitment to their job.

Communities

Heinz believes in being a responsible corporate citizen in the communities in which it and its Business Units operate. Heinz values its contribution to the development of the communities where Heinz has operations.

HEINZ'S COMMITMENTS:

Heinz-owned factories and facilities will operate in compliance with applicable laws and regulations in every country in which Heinz operates. In countries where specific laws are not well-defined, Heinz will implement standards that govern its operations, which are consistent with these Global Operating Principles.

Conditions of Employment

  • Minimum Age for Employment – Heinz and its Business Units will not knowingly hire anyone under the age of 16. If the local law requires a higher minimum age limit, Heinz will comply with that requirement.
  • Forced Labor – Heinz will not utilize forced labor or involuntary prison labor.
  • Abuse and Harassment – Heinz does not tolerate any form of physical or sexual harassment or abuse of its employees.
  • Equal Employment Opportunity/Diversity – No person or group of people should be made to feel unwanted or unwelcome in a Heinz workplace because of discrimination or stereotyping. Heinz encourages and fosters a diverse global workforce. Heinz believes that its employees should be employed and promoted on the basis of their ability to do the job. It is therefore the continuing policy of Heinz to afford equal employment opportunities to all qualified employees and applicants. In accordance with this policy, all personnel decisions, including but not limited to those relating to recruitment, hiring, training, promotion, compensation, and benefits, will continue to be made based solely upon an employee’s or applicant’s qualifications, skills, and abilities and without regard to any condition or characteristic that is not job-related. In addition, every Heinz location is required to have a policy prohibiting illegal discrimination, including harassment, and an accompanying set of policies establishing a procedure for reporting and investigating complaints, prohibiting retaliation, and providing for appropriate disciplinary action for violations.
  • Freedom of Association – Heinz recognizes and respects each employee’s right to associate with any legally sanctioned organization. The rights of labor unions must be respected.
  • Work Hours, Work Week, and Payment of Wages – Heinz will comply with all applicable local laws.
  • Training – Reasonable efforts will be made to provide appropriate job training for every employee.
  • Promotion – Preference for any promotion opportunities will be given to employees based on merit, performance, and other equitable standards.
  • Communications – Heinz will take appropriate steps to communicate these Global Operating Principles to its employees, including posting these Principles in the local language in an accessible place. All Heinz locations will encourage constructive communications among employees and management – without fear of reprisal – regarding issues that impact their jobs or the Company in general.

Occupational Health and Safety

  • Occupational health and safety must be managed as an integral part of all operational performance.
  • All Heinz facilities are required to comply with Heinz policies and national and local safety laws.
  • Each Heinz-owned manufacturing location is required to implement the Heinz Safety Process, and manage by its principles.
  • Management must measure performance against safety goals that are related to the Heinz Safety Process, and incorporate safety objectives into annual business plans for safety.
  • Each Heinz-owned manufacturing location must have access to a dedicated and trained safety professional accountable to the location’s operational manager and must facilitate the implementation of the Heinz Safety Process.
  • All Heinz-owned locations will develop the capability to provide occupational health care, whether internally or externally.
  • Each occupational health care facility will comply with all applicable national or local laws, if more stringent than Heinz Occupational Health requirements.
  • All internal facilities for occupational health care will be managed and evaluated against the Heinz Occupational Health process.
  • Environmental, health and safety performance will be reported as part of Heinz’s Corporate Social Responsibility Report.

Security

  • All Heinz facilities are committed to offering secure workplaces providing for the safety of employees and the Company’s products.

Environmental Commitments

  • The following commitments regarding the environment will be required from each Heinz manufacturing location and operating Business Unit.
  • Each Heinz manufacturing location is required to establish and implement an Environmental Management System that is structured in accordance with ISO 14001:2004 standard.
  • Compliance with applicable legal requirements is the minimum standard for operating performance.
  • To promote a sustainable future, environmental impact must be minimized by the efficient use of energy, raw materials, water, and packaging. Environmental objectives, targets, and goals have been established and are published as an important part of the Company’s sustainability goals.
  • Plans to report and handle environmental emergencies must be established, maintained, and updated. Key responsibilities must be assigned to responsible employees.
  • Employees must be trained to understand their role in environmental control and process improvement.
  • Each Heinz Business Unit must ensure that its suppliers and contractors help to identify and reduce the environmental effects of their operations.
  • Environmental performance will be summarized by each Business Unit.
  • Environmental, health and safety performance will be reported as part of Heinz’s Corporate Social Responsibility Report.

Quality and Food Safety

  • Food safety and quality must be managed as an integral part of the entire supply chain process.
  • Heinz facilities and suppliers are required to comply with Heinz policies and with national and local laws regarding food safety.
  • Each Heinz facility is required to implement a consistent quality risk management process focused on continuous improvement and prevention.
  • Compliance with quality and food safety requirements and processes will be continuously measured and included as part of the annual business objectives and reviews.
  • Systems to trace movement of ingredients, packaging, and products throughout the supply chain are critical components of the food safety system.
  • Anti-Corruption

    • Heinz is committed to a zero-tolerance policy with respect to bribery and corruption. Moreover, Heinz follows a policy of no “facilitating payments” to Government Officials. All gifts and entertainment provided by or accepted by Heinz employees shall be in conformance with applicable laws, customs, and Heinz policy.

    Emergency and Crisis Planning

    • All Heinz locations and facilities will have in place a plan for handling crises, such as accidents, natural disasters, or criminal acts.
    • All Heinz locations and facilities will have emergency plans for evacuations, spills, and natural disasters.
    • Crisis plans and emergency plans will be well documented and rehearsed and all lists of key personnel and responsibilities will be up to date and accessible.
    • All emergency signals and plans must be understandable by all employees.

    Accuracy of Communications

    • Heinz is committed to accurate and truthful communications in its business, including financial reporting.

    Charitable Citizenship

    • Heinz recognizes its role as a responsible corporate citizen in the area of corporate charitable contributions.
    • Heinz seeks out opportunities to contribute assistance to worthwhile causes in the communities in which Heinz and its Business Units operate.

    Monitoring and Compliance

    • As part of the implementation of these Global Operating Principles, these Principles will be incorporated into policies and procedures governing the operations of Heinz and its Business Units. Heinz’s operating Business Units will be expected to certify to Heinz management their compliance with such policies and procedures and submit to monitoring by Heinz and its designated agents (including any third parties).
    • When Heinz becomes aware of actions or conditions which are inconsistent with these Global Operating Principles, such actions or conditions will be reviewed and appropriate corrective measures will be implemented by Heinz management.

    REQUIREMENTS

    1.0 Business Units are required to post the H. J. Heinz Company Global Operating Principles in the appropriate local language in an accessible location (e.g., bulletin board to which all employees have access).
    2.0 Employees who are aware of deviations to the H. J. Heinz Company Global Operating Principles must immediately contact the Ethics and Compliance Hotline, - the Vice President – Corporate Governance, Compliance and Ethics, or the Law Department.
    3.0 On an annual basis, all Business Units will be required to certify compliance with these principles. The Vice President – Corporate Governance, Compliance and Ethics will coordinate this compliance request.
    4.0 Certain aspects of the H. J. Heinz Company Global Operating Principles are covered in the following Heinz policies:
     
    • Heinz Communications Policy C.04 (Crisis Prevention and Leadership)
    • Heinz Corporate Governance/Legal Policy CC.01 (Conduct of Business – Ethical and Legal Standards)
    • Heinz Corporate Governance/Legal Policy CC.05 (Equal Employment Opportunity)
    • Heinz Corporate Governance/Legal Policy CC.06 (Policy Prohibiting Sexual and Other Harassment)
    • Heinz Financial Policy FAR.01 (Financial Reporting Standards)
    • Heinz Risk Management, Policy RM.02 (Facility Security and Food Defense Policy)
    • Heinz Risk Management, Policy RM.04 (Safety and Health Policy)
    • Heinz Risk Management Policy RM.05 (Environmental Management)
    • Heinz Risk Management Policy RM.09 (Business Continuity Planning)
    • Heinz Technical Policy T.01 (Quality Foods and Manufacturing Standards)

     

    Business Units are required to ensure full compliance with the above policies.

    ADMINISTRATIVE RESPONSIBILITY

    The Executive Vice President and General Counsel and the Vice President Corporate and Government Affairs are responsible for the supervision and administration of this policy.

    The Vice President – Corporate Governance, Compliance and Ethics is responsible for monitoring and updating this policy.