Act ethically

Our commitment to high standards of integrity and ethics ensures that all employees and workers who are not employees feel respected and protected, thus contributing to a work environment that promotes dignity and trust among our people and other stakeholders.

We do this by respecting human rights, laws in force in the countries where we operate and applicable international laws and guidelines, including the Universal Declaration of Human Rights, the International Labour Organization Conventions and those of the Organisation for Economic Co-operation and Development (OECD), and the Guidelines for Multinational Enterprises, among others.

Our Code of Conduct¹ and Anti-Corruption Policy² establish the standards of behaviour that all our structures must take into account throughout the employee life cycle, simultaneously acting as a yardstick of the ethics and good conduct that employees must follow, irrespective of their hierarchical level, function or the country in which they work.

We also have in place 92 Group-wide and local policies that follow and embody these principles in people management rules and processes. Among these policies are the global Labour Fundamentals Guidelines, which serve to guide our Companies and corporate structures in respecting and safeguarding human and labour rights, fostering a healthy, safe and balanced workplace. With these guidelines, we ensure compliance with the following principles and rights:

• principle of equality and non-discrimination;
• right to work;
• right to rest;
• right to equal pay and fair remuneration;
• right of association and collective bargaining;
• right to a safe workplace;
• right to parenthood;
• right to privacy and private life;
• right to remedy.

Also of note is the policy that establishes and shares with all employees in Portugal the guidelines for preventing and combating harassment and discrimination, setting out:

• the rules for preventing and addressing discriminatory behaviour and/or harassment, in any form, in the workplace and/or for work-related reasons;
• the channels of contact between employees and their Companies on this matter;
• the guidelines for assessing and investigating complaints received.

We ensure the prevention of the risk of labour rights violations, inter alia through regular HR operations audits, the audit of working hours, rest and holiday periods, medical exams, workplace conditions, and other criteria with which compliance and control are aimed at promoting the dignity of work and the wellbeing of employees. Where nonconformities are identified, a recovery plan is defined, closely monitored by the HR team, and the subsequent audit is brought forward to confirm that the plan has been implemented. In 2023, a total of 441 audits were carried out in Pingo Doce and Recheio stores.

In Colombia, we have a policy in place that sets out the ten fundamental rules to be followed by the Company in managing people, to ensure that human and labour rights are respected in all situations. In 2023 we began the certification of store managers and other key functions, mandatory for the performance of these roles, and which enabled us to validate the knowledge of 218 people on this policy. In addition, Ara’s teams monitor a criticality map that allows them to control priority labour rights indicators³ and trigger the audit of stores with an identified risk. A total of 630 audits were carried out.

At Jerónimo Martins Agro-Alimentar (JMA) there is a growing dependence on migrant labour and 27.2% of workers come from temporary employment agencies. Accordingly, there is a greater concern in ensuring compliance with the labour and human rights of these workers and in 2023 we began to evaluate our partners.

In the fight against forced labour and as part of The Consumer Goods Forum, we continued our involvement in the Human Rights Coalition – Working to End Forced Labour, aimed at ensuring that by the end of 2025 its members have all of their own operations covered by due diligence systems, as a way to identify, remedy and prevent human rights risks.

Group-wide, we ensure the prevention and eradication of child labour by implementing recruitment and selection procedures that prohibit the hiring of persons under the legally permitted employment age. In 2023, the Global Child Forum, which assesses the policies developed and implemented by organisations to address the impact on children’s rights, ranked us as a “Leader”, in eighth place worldwide and first among Portuguese companies, with a score of 8.9 points out of 10 possible points (1.3 points above the previous year and 3.5 points above the sector average).

With regard to freedom of association and collective bargaining, under the terms of applicable law, all employees are free to form and join organisations without the need for prior authorisation and may be represented by them when negotiating agreements with their employer. Collective bargaining, for now only applicable to Portugal, covers 95.4% of employees in the country⁴. Biedronka has a trade union policy that sets out the main rules and guidelines for conducting an effective social dialogue, in line with the law and based on the principles of transparency, independence and mutual trust.

Communication and training

To ensure that our employees are properly informed about their rights and responsibilities in complying with the ethical standards we set, we ensure regular communication campaigns and training. When new employees join the Group, they are provided with a copy of the Code of Conduct and the Anti-Corruption Policy, and requested to acknowledge receipt thereof. In Colombia, in addition to being made aware of the Anti-Corruption Policy, employees also receive training in the policy during their first two months on the job. In 2023 we trained 15,587 employees in this policy, corresponding to 84.5% more training hours than in the previous year, and we launched communication campaigns that reached 12,787 employees⁵ Group-wide.

We also regularly promote in-person and e-learning sessions on labour law, having trained more than double the number of employees in 2023, compared to 2022, and increased training hours by 24.7%. As a result of the labour reforms in Portugal and Poland, several of our Companies implemented communication campaigns focused on employee rights, reaching 640 people.

Resolution mechanisms

Our efforts to promote the highest standards of ethical conduct culminate in the need to establish and disclose mechanisms for reporting and remedying any irregular situations. We ensure that all situations that are reported are investigated and subsequent action plans designed, activated and implemented, while ensuring the confidentiality and protection of whistleblowers.

In the three countries where the Group has its largest operations, employees have the Employee Assistance Service at their disposal for reporting, clarifying and resolving labour issues and, in the case of Portugal, for receiving and forwarding social requests. This channel ensures confidentiality, independence and impartiality, and safeguards employees against any retaliation, discrimination or loss of rights.

The Ethics Committee is an independent body tasked with monitoring disclosure of and compliance with the standards and principles of the Code of Conduct and Anti-Corruption Policy. To this end, it has its own dedicated website that allows employees, as well as any interested party with whom our Companies work or interact, to confidentially report any instance of non-compliance with or violation of the law, internal policies or principles, in particular related to aggression, harassment, conflicts of interest, corruption, discrimination, fraud, improper business practices or the misuse of information, among other wrongdoing. We also have four Ethics Boards⁶ in Portugal, independent reporting channels which, together with the Ethics Committee, are responsible for ensuring the receipt and follow-up of reports of any wrongdoing related to the Companies, consistent with the violation of European Union law, national law and the Code of Conduct. The Ethics Committee and Ethics Boards act in accordance with principles of independence, impartiality, integrity, confidentiality and absence of conflicts of interest, and have a platform for managing reports of wrongdoing pursuant to law.

In Poland, an Anti-Mobbing, Anti-Discrimination and Sexual Harassment Committee is formed whenever a complaint involving these matters is reported, which is responsible for investigating the complaints and formulating an action plan. In Colombia, the Committee for Labour Coexistence investigate complaints relating to working conditions or other work-related problems.

All situations reported via any of these channels are analysed and investigated, and action plans are drawn up for the resolution thereof whenever necessary. In 2023, we received 3,286 labour-related complaints, all of which were investigated, of which 83.0% were closed and 41.4% required remedy actions.

¹ Our Code of Conduct is available on our corporate website, on the Ethics and Integrity page.

² Our Anti-Corruption Policy is available on our corporate website, on the Ethics and Integrity page.

³ Some examples of the aspects monitored by these indicators include working times, rest times, labour costs, FTEs, turnover, absenteeism and disciplinary procedures. The assessment of these aspects culminates in a criticality score ranging from 1 to 5, assigned to stores, areas and managers, among others.

⁴ Only in Portugal, since there are no collective labour regulation instruments in Poland and in Colombia applicable to the Group’s Companies, thus corresponding to 25.4% of the Group’s total employees.

⁵ Includes access to a communication notice on business courtesies via the Our JM platform in the three main countries where we do business.

⁶ According to Directive (EU) 2019/1937 and with the transposition thereof into Portuguese Law No. 93/2021, companies that have 50 or more workers must establish internal reporting channels, and those that employ between 50 and 249 workers may share resources as regards the receipt of reports and follow-up, which resulted in the establishment of four Ethics Boards in our context in Portugal. At the time of writing of this report, Directive (EU) 2019/1937 has not been transposed into Polish law.