HR POLICIES

HR POLICIES

BUSINESS ETHICS POLICY FOR SUPPLIERS / VENDORS

At Mrs Bectors’ Food Specialities Limited, will only do business with suppliers, contractors, and consultants (collectively herein referenced as “Suppliers”) that comply with applicable and controlling laws, rules, and regulations (collectively herein referenced as “applicable laws”) and at a minimum, with standards of business conduct.

MBFSL expects the following; including respecting the human rights of employees from all its Suppliers and that Supplier shall not use any form of forced labour including prison, indentured, bonded, military, slave or any other forms of forced labour.

Supplier shall not participate in the recruitment, transportation, transfer, receipt of any persons by means of threat, use of force, or any other forms of coercion, abduction, fraud, deception, abuse of power or position of vulnerability, or the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.

Suppliers shall not retain an employees’ government-issued identification, passports or work permits as a condition of employment and shall allow employees to resign from their positions at any time.

CHILD LABOUR - Supplier shall ensure that no underage labour to be used in the production or distribution of their goods or services. Employees must not be younger than the minimum employment age established by the respective country or local jurisdiction.

Supplier’s employee working hours must comply with all applicable laws and regulations. Suppliers should encourage employees to receive at least one day off every seven days in compliance with all applicable laws.

WAGES AND BENEFITS - Suppliers must have a system in place to verify and accurately record payroll, deductions and the hours worked by legally authorized employees. Suppliers must comply with all applicable wage and compensation requirements as defined under applicable labour laws for regular work, overtime, maximum hours, piece rates, and other elements of compensation and employee benefits.

Freedom of Association and Collective Bargaining Supplier must adhere to applicable laws regarding the right to affiliate with lawful organizations without interference.

NODISCRIMINATION - Supplier shall maintain a workplace free of unlawful discrimination, which includes, but is not limited to, race, gender, sexual orientation, age, pregnancy, caste, disability, union membership, ethnicity, religious belief or any other factors protected by applicable law. Employees shall not be subject to verbal, physical, sexual or psychological abuse or any other form of mental or physical coercion and shall be treated with respect and dignity.

HEALTH AND SAFETY Working Environment Suppliers shall provide safe and healthy working and housing environments (if Supplier provides housing) to prevent accidents and injury to health. Suppliers shall minimize employee exposure to potential safety hazards by identifying, assessing and minimizing risks by developing and implementing plans and procedures.

ENVIRONMENT Environmental Impact Suppliers shall be sensitive to its impact on the environment (including but not limited to air emissions, water discharge, toxic substances and hazardous waste disposal) and local communities. Supplier shall comply with the environmental laws and standards within its facilities. Suppliers must use care in handling hazardous materials or operating processes or equipment that use hazardous materials to prevent unplanned releases into the workplace or the environment.

BRIBERY AND CORRUPTION Anti-Bribery and Anti-Corruption Suppliers shall not engage in any form of corrupt practices including without limitation to, extortion, fraud, impersonation, false declarations, bribery, money laundering, supporting or involved with terrorist or organized crime organizations or activities. Suppliers shall not offer bribes, kickbacks, illegal political contributions or other improper payments to MBFSL representative or agency, any customer, government official or third party, with the intention of obtaining or retaining a business or other improper advantage.

CREMICA HUMAN RIGHT POLICY-CONVERTED

Mrs. Bector Food Specialities Ltd Theing Road Phillaur

Human Rights Policy

Policy Manual

04/04/2018

We believe that business can only flourish in societies where human rights are protected and respected. We recognise that business has the responsibility to respect human rights and the ability to contribute to positive human rights impacts.

This is an area of growing importance to our employees, workers, contractual workers, vendors, shareholders, investors, customers, consumers, the communities where we operate and civil society groups. There is therefore both a business and a moral case for ensuring that human rights are upheld across our operations and our value chain. This Human Rights Statement contains over-arching principles which we embed into our policies and systems.

Our Policy

In line with the UN Guiding Principles on Business and Human Rights, we base our human rights policy commitment on the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights) and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. We are committed to respecting all internationally recognised human rights as relevant to our operations.

Our principle is that where national law and international human rights standards differ, we will follow the higher standard; where they are in conflict, we will adhere to national law, while seeking ways to respect international human rights to the greatest extent possible.

Our Vision

MBFSL’s vision is to double the size of the business, whilst reducing our environmental footprint and increasing our positive social impact.

Our Code of BUSINESS ETHICS states that we “conduct our operations with honesty, integrity and openness, and with respect for the human rights and interests of our employees and that we shall similarly respect the legitimate interests of those with whom we have relationships.”

In our business dealings we expect our partners to adhere to BUSINESS ETHICS consistent with our own. We prohibit discrimination, forced, trafficked and child labour and are committed to safe and healthy working conditions and the dignity of the individual. Also the right to freedom of association and collective bargaining and effective information and consultation procedures.

We conduct our Security operations in alignment with the Group Security Framework, national legal requirements and international standards. We recognise the importance of land rights. We are committed to the principle of free, prior and informed consent, and support its implementation by national authorities.

Responsible Sourcing

We have a large and diverse extended supply chain and we recognise the critical role our suppliers play in helping us to source responsibly and sustainably. Our Business Ethics Policy sets out our expectations with regards to the respect for the human rights, including labour rights, of the workers in our extended supply chain.

We will only work with suppliers who implement our Business Ethics Policy . They must agree to ensure transparency, to remedy any shortcomings, and to drive continuous improvement.

Our Business Ethics Policy contains clear requirements and guidance on grievance mechanisms.

Addressing Human Rights Impacts

We recognise that we must take steps to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships. We manage these risks by integrating the responses to our due diligence into our policies and internal systems, acting on the findings, tracking

our actions, and communicating with our stakeholders about how we address impacts.

We understand that human rights due diligence is an ongoing process that requires particular attention at certain stages in our business activities, such as when we form new partnerships or our operating conditions change, as these changes may create new potential or actual impacts on human rights.

We recognise the importance of dialogue with our employees, workers, contractual workers, and external stakeholders who are or could potentially be affected by our actions. We pay particular attention to individuals or groups who may be at greater risk of negative human rights impacts due to their vulnerability or marginalisation and recognise that women and men may face different risks.

Remedy

We place importance on the provision of effective remedy wherever human rights impacts occur through company-based grievance mechanisms. We continue to build the awareness and knowledge of our employees and workers on human rights, including labour rights, encouraging them to speak up, without retribution, about any concerns they may have, including through our grievance channels. We are committed to continue increasing the capacity of our management to effectively identify and respond to concerns. We also promote the provision of effective grievance mechanisms by our suppliers.

Empowering Women through Rights, Skills and Opportunities

Around the world many women face discrimination and disadvantage, lack access to skills and training, and face roadblocks to their active participation in the economy. They often lack the protection of basic rights and laws. Poverty, discrimination and violence against women are major barriers to opportunity.

Women are integral to our business model and growth ambitions. We seek to manage and grow socially responsible businesses where women participate on an equal basis. We believe that women’s rights and economic inclusion are priorities to win long-term.

Our approach starts with the respect of the rights of women and extends to their promotion as well as helping to develop skills and open up opportunities, both in our own operations and our value chain.

Our Governance

Our work in this area is overseen by the Executive Director of MBFSL, supported by the MBFSL Leadership Executive including the Vice President Operations, Sr. Manager HR, VP-HR Corporate. This ensures that every part of our business is clear about the responsibility to respect human rights.

Going Forward

As part of our ambition to Enhance Livelihoods, we state our commitment to Fairness in the Workplace, Opportunities for Women and Inclusive Business.

We continually evaluate and review how best to strengthen our approach to addressing human rights, including labour rights. We believe that working through external initiatives and partnerships, for example with other industry, NGO, Works committee, contractors, supplier and other business partners, is often the best way to address shared challenges.

This Human Rights Policy Statement consolidates our existing commitments and brings increased clarity on our processes and procedures. Its principles are implemented across our operations and value chain.

Factory Manager/ Sr. Manager HR Executive Director