(Step 3 OECD Guidelines | UNGPs 13, 17 and 19 and Step 4 | UNGPs 17 and 20)
Human Rights
Suppliers of Private Brand products and perishables are audited both during the selection process and on a regular basis, with the aim of monitoring the management and control of production processes, particularly regarding the quality and food safety systems they have in place. These audits are conducted by internal teams and supported by independent external entities. They cover areas such as quality and food safety, environmental and labour practices management, among others.
Social audits, conducted by an external and independent entity, aim to monitor and ensure compliance with national and international legislation, as well as to promote the application of best practices shared by the Sustainable Supply Chain Initiative of The Consumer Goods Forum. They also seek to ensure compliance with the Resolution and Priority Principles1, in force since 2015, of the Human Rights – Working to End Forced Labour Coalition, also under the CGF. These social audits include more than 120 assessment criteria, some of which are categorised as “zero tolerance”, particularly those relating to the eradication of forced and child labour, emergency preparedness, health and safety, and anti-corruption, among others.
Audits are preceded by training and result in a rating following on-site verification of facilities and interviews with workers. If necessary, a corrective action plan is developed with a deadline for implementation, established according to the severity of the non-conformities identified. In the agri-food sector, these audits apply to three types of activities: primary production, operations at sea and processing industry.
For more information on the audits we conduct with our suppliers, see “Selection and monitoring of suppliers”.
As a complement to the initiatives developed with our suppliers, we encourage the adoption of sustainability certifications. These systems follow standards that include environmental and/or social requirements verified by external entities and may apply to one or more ingredients, the product itself and/or its packaging. Their adoption ensures the implementation of environmental best practices throughout the value chain – ensuring, for example, that no deforestation or conversion of High Conservation Value ecosystems occurred in the production of products, that production processes to mitigate pollution are best in class, and/or that human rights principles are respected (no child or forced labour, fair payment to producers, among others). The presence of specific symbols on products and other consumer touchpoints also facilitates communication of these attributes and raises awareness for more conscious choices.
Information on products with sustainability certification can be found in “Consumers and end users”.
Internally, as a way of preventing and mitigating risks of labour rights violations in Portugal, we ensure frequent human resources operational audits covering working hours, rest periods and holidays, medical examinations, workplace conditions and other criteria whose compliance and monitoring aim to promote the dignity of work and employee well-being. If non-conformities are identified, a corrective plan is defined, with actions closely monitored by the human resources team, and the next audit is brought forward to confirm implementation of the plan. In Colombia, Ara’s teams also monitor a criticality map that enables the tracking of priority labour rights indicators and triggers audits of stores with identified risks.
Preventing and fighting corruption
Whenever we hire new employees in any country, and in order to inform them about the Group’s ethical values and principles, we ensure that they formally acknowledge having read and understood the Code of Conduct and the Anti-Corruption Policy. In addition, we provide regular communications on these topics.
We have developed a training programme on the Anti-Corruption Policy in two participation formats (e‑learning and advanced training for critical functions), with content reviewed periodically to ensure it remains up to date. In 2025, 28,995 hours of training were delivered on this topic (16.3% more than in 2024), and we reached 96.4% of employees through communication campaigns. In addition to general training on the policy, at different levels of depth, specific training sessions were delivered for targeted audiences For example, in Portugal, training sessions were conducted for human resources and quality and food safety teams; in Poland, for logistics, expansion and technical teams. In Colombia, training focused on the self‑control and risk‑management system for money laundering and terrorism financing, and on the Business Transparency and Ethics Programme (PTEE), a Colombian legal framework.
Third parties that interact with the Group’s companies are also subject to communication actions. In this context, the communication of the Anti-Corruption Policy to suppliers is highlighted, as well as the Supplier Code of Conduct and the Sustainable Sourcing Policy, which are published on the Group’s website and/or included in contracts.
In addition, we periodically verify the effectiveness and proper implementation of our policies, procedures and internal controls through, for example, audits that include analysis of risk management (among which operational risks that may be associated with fraud and/or corruption events), in order to identify any potential non‑conformities and areas for improvement. This information is detailed in “Internal Control and Risk Management”.
Taxation and fair competition
The Group adopts a collaborative approach with the tax authorities in the countries where it operates and has participated, for example, in several initiatives of the Portuguese Tax Authority regarding tax transparency and cooperative compliance.
Risks associated with tax and legal matters, as well as disputes with tax and competition authorities, are continuously monitored by the management team and the Audit Committee.
With regard to fair competition, the Jerónimo Martins Group supports all actions aimed at prohibiting restrictive free trade practices, unfair practices or the abuse of bargaining position. The Group believes in strong and fair competition and strictly complies with the competition laws of the markets in which it operates.
Internal Control and Risk Management Systems
The Group’s internal control system is ensured by a set of areas dedicated to monitoring critical processes at both central and operational levels, involving the following bodies:
Board of Directors
Audit Committee
Chief Executive Officer, supported by the Executive Management Team
Risk Committee
Internal Audit Department, reporting hierarchically to the Chairman of the Board of Directors and functionally to the Audit Committee
Strategy and Innovation Department
Business Unit Risk Manager
All employees responsible for carrying out and/or controlling specific processes or activities within a business unit or the corporate structure, who are accountable for managing the risks associated with those activities
The Internal Audit Department assesses the quality and effectiveness of internal control systems within the scope of risk management (operational and non‑operational) established by the Board of Directors, promoting compliance with Group-wide procedures and policies, as well as those of each business unit. This area is also responsible for promoting compliance with applicable legislation and regulation governing operations.
Internal control processes are formalised in policies and procedures, as described in item 50, “Persons, Bodies or Committees Responsible for Internal Audit and/or the Implementation of Internal Control Systems”, and item 55, “Main Elements of the Internal Control and Risk Management Systems Implemented by the Company in Relation to the Disclosure of Financial Information”, of this report.
1 The CGF Priority Principles concern the protection of labour rights on global supply chains, focusing on topics regarded as critical: freedom of movement (workers must be able to move freely and should not have this freedom restricted by their employer through abuse, threats, or practices such as the retention of identity documents or personal belongings); the voluntary nature of employment (no worker should pay for a job, must be aware of the terms and conditions in advance, and must be regularly remunerated as agreed, with contractual arrangements based on debt or bonded labour strictly prohibited); and freedom of contract (no worker should find themselves in a situation of indebtedness or coercion arising from fees or costs associated with recruitment and employment, which should be borne by the employer and not place any financial burden on workers).