Code of Conduct
for Business Partners
Introduction
Being a responsible player holding a key position in the Biogas industry in Denmark and on international markets, Nature Energy, and its direct and indirect subsidiaries (“Nature Energy”) wish to contribute to a social, sustainable, environmental, and economic development within Biogas production and in society.
Nature Energy is signatory to the UN Global Compact - a voluntary initiative that promotes business leadership in support of the Global Compact’s ten principles in the areas of human rights, labour rights, environment and anti-corruption.
In line with Nature Energy’s own commitment to sustainability, Nature Energy wants to collaborate with suppliers and joint-venture partners (“Business Partners”) that are equally responsible. Consequently, this Code of Conduct (“CoC”) is to be adhered to by all Business Partners to Nature Energy.
This CoC has been developed in recognition of international proclaimed principles.
We expect our Business Partners to commit to continuous improvement in all areas covered by this CoC. We recognize that our Business Partners may be at different maturity levels, but we expect all Business Partners to demonstrate continuous progress.
Legal Compliance
Business Partners must comply with all applicable laws, rules, and regulations wherever they operate and/or comply with the provisions set forth in this CoC - whichever is more stringent.
Should legal compliance lead to adverse impacts on human rights, including labour rights, the environment or anti-corruption principles, Business Partners are required to do their best to prevent and mitigate such impacts, without breaching such regulation.
Compliance with this CoC
The provisions of this CoC provide the minimum expectations for Business Partners with whom Nature Energy does business.
Business Partners cover all first tier Business Partners, including any of its Business Partners’ parent entities and subsidiaries or affiliated entities.
It is the responsibility of these Business Partners to ensure and use their leverage so that their Business Partners (Nature Energy’s sub–Business Partners) work in accordance with the international principles outlined in this CoC and thereby enabling Nature Energy's Business Partners to comply with this CoC.
Business Partners must comply with the following international principles in their conduct of business:
- The principles of the UN Global Compact initiative,
- The requirements in the conventions on which the above principles are based or implemented, including the UN Guiding Principles on Business and Human Rights, the International Labour Organization's (ILO's) Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises and
- The specific requirements set out below.
With this CoC, Nature Energy requires its Business Partners to have adequate management systems[1] in place to manage their potential and actual adverse impacts on human rights, including labour rights, environment, and anti-corruption in line with international principles. In order to do so, Business Partners are required to:
- Commit through a formal statement or policy,
- Conduct due diligence[2] in order to identify, prevent, mitigate, and account for how they address their adverse impacts and
- Provide for or co-operate in the remediation of actual adverse impacts that they or their supply chain have caused or contributed to
Nature Energy expects all Business Partners to implement the three requirements but acknowledges that the way they will meet the requirements will vary in complexity with the size of the Business Partner, the related risks the Business Partner faces and the nature and context of its operations.
Implementing these three requirements will enable all Business Partners to avoid and/or address their adverse impacts through an effective management system that lives up to international requirements.
The three areas of implementation
Business Partners must ensure that the above management system including a policy commitment or a formal statement, due diligence and a remediation process is effective in helping them avoid and address their adverse impacts on three areas of implementation[3]:
- Human rights including labour rights
- Environmental principles
- Anti-corruption principles
Human rights including labour rights
Business Partners should support and respect the protection of all internationally recognised human rights, including labour rights and ensure that they are not complicit in human rights abuses.
As such Business Partners should comply at all times with applicable law and international principles in regards of internationally recognised human rights as stated in the International Bill of Human Rights [4].
Furthermore, Business Partners should comply with the labour rights set out in the ILO’s Declaration on Fundamental Principles and Rights at Work, meaning that Business Partners should uphold the freedom of association and the effective recognition of the right to collective bargaining; support the elimination of all forms of forced and compulsory labour; support the effective abolition of child labour and the elimination of discrimination in respect of employment and occupation.
Nature Energy appreciates that the human rights, including labour rights, at risk vary across any supply chain. In practise, this means that Business Partners take all human rights into account when assessing their impacts and to be diligent in addressing the identified adverse impacts.
Environmental principles
Business Partners should support a precautionary approach to environmental challenges; undertake initiatives to promote greater environmental responsibility and encourage the development and diffusion of environmentally friendly technologies.
As such Business Partners should comply with the principles as described in the Rio Declaration on Environment and Development.
In practice, this means that Business Partners must manage the different environmental aspects of their business (including but not limited to): use of scarce natural resources, energy and water; emissions to air and releases to water; noise, odor, and dust emission; potential and actual soil contamination, waste management (hazardous and non-hazardous substances) and products issues (design, packaging, transport, use and recycling/disposal).
Anti-corruption principles
Business Partners should work against corruption in all its forms, including extortion and bribery.
As such Business Partners should establish adequate processes to counter corrupt practices in line with the United Nations Convention against Corruption.
In practice, Business Partners should avoid and address all forms of corruption, including bribery, extortion, and facilitation payments - both in relation to public authorities, partners, and other private stakeholders.
Documentation and collaboration
On request, Business Partners must provide Nature Energy or any third-party representing Nature Energy with relevant and adequate information to demonstrate what efforts are made to meet the requirements of this CoC.
Where relevant, Nature Energy requires Business Partners to complete a self-assessment questionnaire to evaluate their compliance with this CoC.
Nature Energy encourages Business Partners to co-operate in identifying risks and improving performance. Nature Energy is committed to collaborate and support Business Partners as they improve business practices within human rights, including labour rights, environment, and anti-corruption.
Non-compliance with this CoC
Nature Energy acknowledges that adverse impacts exist in any company and in any operation. Simply having adverse impacts does not constitute non-compliance with this CoC. Instead, Nature Energy requests of all Business Partners to identify and address such impacts in an open manner.
If Business Partners identify actual severe adverse impacts that they either cause, contribute to or are linked to, the Business Partner must without undue delay inform Nature Energy about such observations and present the plans to remedy the impacts.
Nature Energy will then initiate a close dialogue with the Business Partner to clarify matters and to influence a stop or mitigation of the non-compliance. Nature Energy will take similar steps in case Nature Energy find it relevant.
In case of a Business Partner's severe and/or repeated non-compliance with this CoC and/or where the Business Partner fails to correct non-compliance within a reasonable timeframe, we will consider suspending or terminating the business relationship.
Questions?
For further information or if you have any questions regarding the content of this CoC, please do not hesitate to contact us on contact@nature-energy.com.
[1] Guidance and definition of management system can be found in the OECD Guidelines for Multinational Enterprises.
[2] As defined in the OECD Guidelines for Multinational Enterprises.
[3] In accordance with the UN Global Compact.
[4] http://www.ohchr.org/Documents/Publications/Compilation1.1en.pdf
