HEINEKEN Policy on BUSINESS CONDUCT - THE CODE OF
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R E S
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THE CODE OF
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HEINEKEN Policy onTable of Contents Page
Employees’ & human rights management 4
A. Implementation
B. Grievance procedures
C. Issues of context
Our standards related to employees’ & human rights
1 Non-discrimination 5
2 Freedom of association and the right to collective bargaining 5
3 Forced labour 5
4 Child labour 5
5 Working hours 6
6 Remuneration 6
7 Health and safety 6
8 Harassment 7
9 Training and personal development 7
10 Security 7
11 Non-complicity in human rights violations 7
2Policy Statement
HEINEKEN is the most international brewer in the world. In all countries and societies in which we operate we
are determined to act according to our Core Values.
‘Respect for People, the Environment and the Society in which we live and work’ is one of these Core Values.
We honor our values by recognizing the responsibility to respect employees’ & human rights and demonstrating
that we act accordingly. The HEINEKEN Employees’ & Human Rights Policy is aimed at supporting and guiding
our management and employees to achieve this goal.
Introduction
In a globalizing world, the role in society of large international companies like HEINEKEN is of increasing
importance. To ensure that HEINEKEN meets its responsibilities in this role, it is – amongst others – necessary to
create and protect a safe and responsible working environment for employees and their direct surroundings. To
this end, HEINEKEN has developed a policy with regard to the basic employees’ & human rights that it respects
and aims to safeguard.
Our respect for individuals and for the well-being of employees is first of all reflected in our Core Values,
Business Principles, Code of Business Conduct and Policies (www.theHEINEKENCompany.com). This HEINEKEN
Employees’ & Human Rights Policy is a further elaboration and articulation of these commitments.
HEINEKEN endorses the principles enshrined within the Universal Declaration of Human Rights1 and the Core
or Fundamental Conventions of the International Labour Organization (ILO)2 based on respect for the dignity
of the individual without distinction of any kind. HEINEKEN supports these human rights and employees’ rights
in line with the legitimate role of business. Where an impact on employees’ rights falls outside the scope of
HEINEKEN’s responsibility, for instance in case of violations by third parties, HEINEKEN will provide assistance to
its best abilities.
This policy is applicable to all Operating Companies and subsidiaries where HEINEKEN holds a majority share
or has management control. The provisions of this policy are further explained and accompanied by additional
guidelines, designed to specify the details and consequences of the provisions. The further explanation and
additional guidelines hence serve as a clarifying background for this policy.
For any specific issues or questions concerning third party employees, agency personnel and contractors, we
refer to the HEINEKEN Supplier Code (www.theHEINEKENCompany.com) and any other policy that may be
applicable and that governs the relationship between HEINEKEN and its suppliers or contractors in specific
cases.
1. The Universal Declaration of Human Rights, General Assembly of the United Nations, 10 December 1948, available at
«www.un.org/en/documents/udhr/». Together with the main instruments through which it has been codified, namely the International Covenant on Civil
and Political Rights and the International Covenant on Economic, Social and Cultural Rights, it forms the International Bill of Human Rights.
2. The eight Fundamental Conventions identified by the Governing Body of the ILO, available at
«www.ilo.org/declaration/info/publications/WCMS_095895/lang--en/index.htm».
3Employees’ & human rights management
A. Implementation
Apart from having formulated eleven clear standards on employees’ & human rights it is important to integrate
and implement this Employees’ & Human Rights Policy and strategy throughout all our Operating Companies in
the world.
We will focus on:
• Education and training
The Operating Companies will be trained to raise their awareness of this policy, and they will be supported in
their efforts to respect the rights of their employees.
• Monitoring performance against our own benchmarks
• Use additional self-assessment tools and develop action plans
• Facilitate dialogue with stakeholders (such as employees and trade unions) including through clear reporting
on the employees’ & human rights performance of our Company
B. Grievance procedures
HEINEKEN will provide grievance-procedures in all HEINEKEN Operating Companies, inform employees about
the existence of such procedures and stimulate the proper use of these procedures, while discretion and
protection will be guaranteed to those who make use of these procedures. In case of grievances employees are
expected to always follow local procedures first, before making use of other channels (e.g. the HEINEKEN Speak
Up procedure).
C. Issues of context
This policy should be viewed as a minimum standard; where local legislation goes beyond the content of this
policy, our Operating Companies will adhere to the local legal obligations. Where compliance with local law
can put the Operating Companies into the position of not being able to comply with the standards of this
Employees’ & Human Rights Policy, the Operating Company is expected to act as follows:
• Seek ways to honour the principles laid down in this Policy and try to act according to these principles as
much as possible, without acting in direct contravention of local law.
• If there is a risk that the Operating Company unwillingly contributes to violation of Human Rights, this risk
should be treated as a legal compliance issue. In such cases, the Operating Company should contact the legal
specialist of Global HR at Corporate Office.
4Our standards related to employees’ & human rights are:
1. Non-discrimination
HEINEKEN respects the right to non-discrimination. People are employed based on the principle of equal
opportunity, without distinction to race, colour, gender, religion, descent or origin. In relation to the appointment
or career prospects of employees, HEINEKEN will pay attention only to the suitability of the candidate
(education, personality, skills, working experience, and other relevant attributes as allowed under local law) and
his or her legitimate demands. HEINEKEN will take its decisions regarding present and future employees on the
basis of objective criteria. HEINEKEN respects cultural and individual diversity and promotes inclusiveness. It
respects personal beliefs / persuasions of present and future employees.
2. Freedom of Association and the Right to Collective Bargaining
HEINEKEN respects the right of its employees to be represented in order to advance their legitimate interests.
This right includes the right of internal and/or external employee representatives to be acknowledged as
partners in negotiations and consultations subject to local laws. Account shall be taken of the nature of
industrial relations in the country and the company concerned. In addition, the needs, size and possibilities of
the company concerned shall be taken into consideration. HEINEKEN considers being represented by a trade
union an employee right, not an obligation (the right to choose not to be represented by a trade union).
3. Forced Labour
HEINEKEN will not engage in or support the use of forced or compulsory labour – such as prison labour, debt
bondage, trafficking or serfdom. HEINEKEN will avoid working with suppliers or employment agencies that are
known to be making use of forced or compulsory labour in their operation.
4. Child Labour
HEINEKEN respects the rights of the child, including the right to education, the right to rest and play and the
right to have the child’s basic needs met. HEINEKEN will therefore not engage in or support the use of child
labour, which means that HEINEKEN will not allow children to work within its facilities.
Furthermore, HEINEKEN is committed to – and maintains programmes aimed at – the elimination of child
labour in its supply chain (please also refer to HEINEKEN’s Suppliers Code at www.theHEINEKENCompany.com).
HEINEKEN follows the ILO definition3 of the minimum age for admission to employment or work. This age shall
not be less than the age of completion of compulsory schooling and in any case not be less than 15 years of
age, except in some developing countries where it is 14 years of age.4 In case local laws set a higher age to
define what is considered a child, HEINEKEN will abide to the local law.
3. ILO conventions on Child Labour: ILO Minimum Age Convention, 1973 (No. 138), available at
«http://www.ilo.org/dyn/normlex/en/f?p=1000:12100:0::NO::P12100_ILO_CODE:C138» and ILO Worst Forms of Child Labour Convention, 1999 (No.
182), available at «http://www.ilo.org/dyn/normlex/en/f?p=1000:12100:0::NO::P12100_ILO_CODE:C182».
4. Article 2, paragraphs 3 and 4 ILO Minimum Age Convention, 1973 (No. 138).
55. Working hours
HEINEKEN recognizes the right to rest and leisure and will therefore always comply with local laws, regulations
and/or local customs with regard to working hours and overtime. Moreover, in line with the ILO-report5 of the
committee of experts on the application of conventions and recommendations concerning working hours
HEINEKEN will generally not require its staff to work in excess of a maximum of 48 hours per week (less in some
cases, depending on local laws) and will provide at least one day off for every seven-day period*.
In this way HEINEKEN aims to ensure safety in the workplace and to promote a healthy balance between
working and home life of its employees.
*In certain exceptional circumstances, there may be specific reasons to deviate from this standard. Prior approval by HEINEKEN’s Chief
HR Officer is required in those cases.
6. Remuneration
HEINEKEN observes the statutory minimum wage set by the government of the country in which it has a local
operation. Where this is not sufficient to meet basic needs, HEINEKEN strives to compensate employees with
remuneration that ensures an adequate standard of living. HEINEKEN maintains a remuneration policy that
emphasizes the internal equity and external comparability within a defined job market. The key elements within
HEINEKEN’s pay and reward policy are:
• pay for responsibility
• pay for performance
7. Health and safety
HEINEKEN provides its employees with a safe and hygienic working environment and working conditions.
HEINEKEN will take appropriate measures to continuously improve safety and health aspects within its facilities,
including the provision of personal protective equipment when and where necessary. Working conditions should
allow for safe working practices and support the occupational health and well-being of employees. We maintain
a policy aimed at continuous improvement of our health and safety performance.
In those countries – particularly developing countries – where basic health care is not sufficiently provided
by the government and/or if there is no possibility for employees to arrange for basic health care from local
service providers themselves, HEINEKEN provides or ensures (access to) basic health care itself. HEINEKEN has
a medical strategy aimed at providing or ensuring (access to) basic health care for its employees and their
immediate families.
5. ILO report of the Committee of Experts on the Application of Conventions and Recommendations (articles 19, 22 and 35 of the Constitution), Report
III (Part 1B) Hours of Work, from fixed to flexible?, 2005
68. Harassment
HEINEKEN considers protecting personal dignity and health at the workplace to be one of its core
responsibilities as a good employer. One aspect of safeguarding the integrity of each employee is to ensure that
harassment in any form does not occur and, if it does occur, to ensure that adequate procedures are readily
available to deal with the problem and prevent recurrence.
9. Training and Personal Development
HEINEKEN acknowledges the importance of training and personal development of its employees.
• Training
In general, HEINEKEN provides for – and bears the costs of - regular training on issues that it finds relevant to
the business and/or to the function of the employee. Training and development opportunities for employees
will be identified on a regular basis and when considered relevant, training is organised for the employee.
• Personal development
Personal development (employability) is regarded as a shared responsibility for HEINEKEN and its employees.
This shared responsibility should be reflected in the contribution both parties are prepared to make in
financial terms and/or in terms of time invested in additional education and training. HEINEKEN encourages
its employees to undertake additional training courses and will support them when additional training is
considered necessary. HEINEKEN will promote policies aimed at the development of skills relevant for its
operation and in line with the talents of its employees.
10. Security
In politically unstable or conflict affected regions, HEINEKEN may be confronted with potential security risks
to its employees, their dependents and its facilities. When managing security in those situations HEINEKEN
will respect the rule of law and will adhere to international human rights principles. The company shall prevent
its hired security guards from unlawfully infringing on the rights of its employees or of others affected by its
operations. When necessary, security guards shall be trained how to behave in such difficult situations and when
and how to intervene in security threatening situations.
11. Non-complicity in Human Rights violations
HEINEKEN recognizes that in countries that are politically less stable or where human rights are compromised
dilemmas may arise, including whether or how it can continue to operate in that country with integrity.
HEINEKEN will act in such a way that none of its operations knowingly contribute to human rights violations by
others.
7Administrative information
Content Owner Global Human Resources
Contact Manager Labour Relations & Employment Law
humanrights@heineken.com
Effective as per 1 January 2012
Version 1.1
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