Annual Report 2025

Our policies

The table below presents a set of sustainability-related policies. More detailed information is provided on our corporate website.

Code of Conduct

Description of key contents

Outlines the purpose, ethical principles, and values that govern the Group’s operations and relationships with stakeholders. It is directed towards all employees, customers, suppliers, business partners and investors. The Code of Conduct is structured around four fundamental principles: Respect for the Law and Human Rights, Honesty and Integrity, Diversity and Inclusion, and Corporate Social Responsibility.

This policy can be integrated within the scope of the following disclosure requirement: E1-1, E2-1, E3-1, E4-1, E5-1, S1-1, S2-1, S3-1, S4-1 e G1-1.

Most Impacted stakeholders

  • Employees

  • Consumers

  • Suppliers

  • Business partners

  • Investors

  • Local communities

  • Non-governmental organisations and associations

  • Journalists

Environmental Policy

Description of key contents

Prioritises environmental protection in the growth and development of the Group’s activities, including a commitment to promote sustainable production, distribution and consumption practices and to continuously improve the efficiency and effectiveness of the supply chain. The policy integrates environmental performance criteria into operational activities and management decision-making, promotes eco-efficiency and eco-innovation, and encourages participation in multi-stakeholder initiatives. Key priorities include climate change mitigation, protection of water resources, preservation of biodiversity, and the acceleration of the transition to a circular economy. The Group aims to reduce energy consumption, greenhouse gas emissions and waste, while improving the quality and availability of water resources. The policy requires that all initiatives are regularly monitored, evaluated and communicated in order to ensure continuous improvement and compliance with applicable laws.

This policy can be integrated within the scope of the following disclosure requirement: E1-1, E2-1, E3-1, E4-1 e E5-1.

Most Impacted stakeholders

  • Employees

  • Suppliers

  • Business partners

  • Local communities

Anti-Corruption Policy

Description of key contents

Establishes the principles and obligations set out in the Code of Conduct that must be observed in the workplace and in interactions with suppliers, customers and other external parties, with the aim of preventing corruption and avoiding potential conflicts of interest. This policy applies to all Jerónimo Martins Group Companies and their employees, regardless of their contractual relationship, role or the country they work in. In line with the Group’s Code of Conduct, the policy outlines the available reporting channels and establishes that reports of potential irregularities made in good faith will not result in retaliation, disciplinary measures or any other adverse or discriminatory actions.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

  • Suppliers

  • Business partners

  • Governance

  • Local Communities

  • Non-governmental organisations and associations

  • Journalists

Sustainable Sourcing Policy

Description of key contents

Establishes a sustainable approach by integrating social and environmental considerations into the supply chain, contributing progressively to positive impacts while mitigating the actual or potential negative impacts of the Group’s activities. The policy aims to ensure food quality and safety, promote fair pricing, encourage responsible consumption, support social well-being, and contribute to the sustainability of ecosystems and communities. The Group prioritises rigorous supplier selection, fostering long-term ethical relationships and encouraging sound environmental practices. Committed to ensuring compliance with applicable legislation and protecting biodiversity, this policy is aligned with the United Nations’ priority areas aimed at safeguarding ecosystem services and supporting the well-being of communities.

This policy can be integrated within the scope of the following disclosure requirement: E1-1, E2-1, E3-1, E4-1, E5-1, S2-1, S3-1, S4-1 e G1-1.

Most Impacted stakeholders

  • Employees

  • Suppliers

  • Business partners

  • Local Communities

  • Consumers

Supplier Code of Conduct

Description of key contents

Sets forth the ethical standards and principles that suppliers must follow in their business dealings with the Group. It emphasises the importance of promoting efficiency, customer satisfaction, shareholders’ interests, and sustainable development. Suppliers are expected to uphold high standards in labour practices, environmental protection, and product quality and safety. The Code mandates compliance with laws and international treaties, environmentally conscious business practices, and adherence to the highest standards of product quality and safety. It also requires suppliers to comply with labour laws, ensuring the principles of non-discrimination, no forced or child labour, safe and healthy work environment, fair remuneration and compliance with legal working hours, along with respect for workers’ freedom of association. Additionally, suppliers must not offer personal gifts or benefits to Jerónimo Martins’ employees, except for symbolic gifts up to a pre-defined value. This comprehensive Code ensures that suppliers align with the Group’s commitment to ethical and sustainable business practices.

This policy can be integrated within the scope of the following disclosure requirement: E1-1, E2-1, E3-1, E4-1, E5-1, S2-1, S3-1, S4-1 e G1-1.

Most Impacted stakeholders

  • Employees

  • Suppliers

  • Business partners

  • Local communities

  • Consumers

Policy for Supporting Surrounding Communities

Description of key contents

Emphasises the importance of extended responsibility and active contribution to the well-being of the communities where the Group operates. This policy focuses on promoting Humanity, Merit, Enterprise, and Citizenship. It supports projects aimed at fighting malnutrition, hunger, poverty, and social exclusion, particularly among the elderly and deprived children and young people. The policy also considers supporting scientific research related to health through food and preserving cultural and environmental heritage. It establishes that all support measures be monitored and assessed to ensure resources are effectively allocated to make the greatest impact.

This policy can be integrated within the scope of the following disclosure requirement: S3-1.

Most Impacted stakeholders

  • Employees

  • Non-governmental organisations and associations

Nutritional Policy

Description of key contents

Promotes healthy lifestyles through safe, nutritious, and affordable food offerings, focusing on preventing food-related diseases like obesity and diabetes. This includes ensuring product safety, compliance with legislation, offering a variety of healthy products, and providing clear, reliable information to consumers. The policy is based on six pillars: nutritional profile, ingredients, labelling, portion sizes, continuous improvement, and communication. The document also promotes engagement in responsible marketing, especially towards children, and the continuous improvement of products’ nutritional profiles. The policy emphasises that actions must be monitored to assess their impact and accuracy.

This policy can be integrated within the scope of the following disclosure requirement: S4-1.

Most Impacted stakeholders

  • Suppliers

  • Consumers

Product Quality and Safety Policy

Description of key contents

Commits to ensuring the highest standards of product quality and safety for Private Brand and perishable products. The policy focuses on maintaining competitive prices while establishing long-term partnerships with suppliers, ensuring relevant quality management and safety certifications schemes. Key goals include understanding and meeting customer demands, monitoring and optimising internal processes, fostering innovation, maintaining the reputational capital of the brands, controlling product quality, training human resources, strengthening partnerships with suppliers, cooperating with authorities and the scientific community, developing information mechanisms for customers, fulfilling legal and regulatory requirements, continuously improving the Quality Management System, ensuring product safety for human and animal health, and minimising environmental impacts. The policy also includes specific principles such as legal compliance, stakeholder engagement, applying rigorous quality and safety standards based on scientific evidence, and ensuring product safety through legal and scientific support. The Group commits to practices such as prohibiting animal testing except in specific cases, such as sensory tests for animal feed, adopting a conservative approach to GMOs and ensuring transparency in labelling, avoiding the use of nanotechnology in food products and packaging, reformulating products to eliminate microplastics, complying with safety standards for substances of concern and packaging materials, implementing procedures and traceability to ensure product safety, and clearly communicating product information to consumers.

This policy can be integrated within the scope of the following disclosure requirement: E2-1, E4-1, E5-1 e S4-1.

Most Impacted stakeholders

  • Suppliers

  • Consumers

Personal Data Protection Policy

Description of key contents

Ensures the privacy of personal data for all individuals interacting with Jerónimo Martins’ Companies, including customers, employees, suppliers, and partners. Sets the necessary measures to protect personal data and complies with data protection laws across all its operations through a dedicated Privacy Team and Data Protection Officers that are in place to develop, implement, and verify data protection procedures. The policy ensures that personal data is managed lawfully, fairly, and transparently, and only for legitimate purposes that are clearly communicated to data subjects. Therefore, it guarantees that data is processed for specific, legitimate purposes and retained only as long as necessary. The policy also ensures data minimisation, accuracy, integrity, and confidentiality through robust security measures and careful partner selection. In addition, it states that data protection principles are integrated into new projects from the start, involving the Data Privacy Team to mitigate risks. It also recognises data subjects’ rights over their personal data, including the rights of access, rectification, objection, portability, restriction and erasure, which can be exercised through dedicated channels.

This policy can be integrated within the scope of the following disclosure requirement: S4-1.

Most Impacted stakeholders

  • Shareholders and investors

  • Analysts

  • Official bodies, supervising entities and local authorities

  • Suppliers and business partners

  • Employees

  • Consumers

  • Local communities

  • Journalists

  • Non-governmental organisations and associations

Whistleblowing Policy

Description of key contents

Outlines rules for receiving, recording, and handling reports of irregularities within the Group. It ensures effective mechanisms for detecting and preventing irregularities, promotes a culture of transparency, integrity, and responsibility, and encourages ethical, honest, and professional behaviour among employees and leaders. It also ensures compliance with EU law, national law, and the Company’s Code of Conduct, and supports effective risk management. The policy defines who is considered a whistleblower, what themes are considered irregularities, and what can constitute a motive for reporting. It establishes principles of complete privacy, confidentiality throughout the entire process, and non-retaliation. From a procedural point of view, it outlines the steps of the entire reporting process – from the complaint to the communication of the outcome through internal and external whistleblowing mechanisms – and explains how data is recorded and managed.

This policy can be integrated within the scope of the following disclosure requirement: S1-1, S2-1, S3-1, S4-1 e G1-1.

Most Impacted stakeholders

  • Shareholders and investors

  • Analysts

  • Official bodies, supervising entities and local authorities

  • Suppliers and business partners

  • Employees

  • Consumers

  • Local communities

  • Journalists

  • Non-governmental organisations and associations

Labour Fundamentals Guidelines

Description of key contents

Aims to promote employees’ labour and human rights, inspiring the Group, Corporate Areas and Companies to build a healthier, safer and balanced working environment. These guidelines aim to:

  • clarify the fundamental international principles that apply directly to the Jerónimo Martins Group Companies in the management of human resources;

  • establish standard behaviours and key conduct guidelines for all Jerónimo Martins Group Companies;

  • ensure compliance with international laws and principles relating to human rights, labour and human resources management in the adoption of policies, procedures, practices, initiatives or other equivalent actions;

  • ensure and encourage all Companies to adopt mechanisms, such as dedicated communication channels, that enable employees to raise concerns, submit requests or lodge complaints.

With these guidelines, we reinforce 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.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

  • Official bodies, supervising entities and local authorities

  • Shareholders and investors

  • Analysts

Prevention and Combat to Harassment and Discrimination Guidelines

Description of key contents

Aim to formalise the principles of equity and non-discrimination set out in the Group’s Code of Conduct, as well as the principle of preventing workplace harassment. These behaviours are considered unacceptable and must be prevented, addressed and, where necessary, appropriately sanctioned, including through the establishment of:

  • rules for preventing and addressing discriminatory behaviour and/or harassment, in any form, in the workplace and/or in the context of work-related activities;

  • communication channels between employees and their respective Companies in this regard;

  • the guidelines for assessing and investigating complaints received.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

  • Official bodies, supervising entities and local authorities

  • Shareholders and investors

  • Analysts

Recruitment and Selection Policy

Description of key contents

Defines recruitment rules and guidelines to attract and select the adequate candidates, both internally and externally, according to the Group’s recruitment needs, and to provide an exceptional candidate and employee experience, reinforcing Jerónimo Martins’ brand value as a benchmark employer, in all countries we are and want to be present.

The recruitment and selection processes established in this policy are therefore based on promoting and complying with criteria of ethics, fairness, non-discrimination and equal opportunities across all levels of our organisation. The recruitment and selection teams ensure that profiles are analysed impartially and must apply pre-established criteria relating to experience and qualifications, among others, at every stage of the process. They also ensure compliance with the law, regulations, and risk and privacy management rules, observing the requirements of each country, in particular with regard to the minimum working age.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

  • Candidates and potential candidates

  • Suppliers and business partners

Global Training Policy

Description of key contents

Defines rules and guidelines for the identification and implementation of the appropriate training solutions in the different locations where Jerónimo Martins, and different Companies that belong to the Group, are present. It establishes the following objectives, among others:

  • ensuring strong alignment between training plans, Company objectives and the Group’s strategy;

  • aligning training concepts and defining the overarching training process to be followed by all Companies and the corporate structure in the management of training activities;

  • establishing quality standards for training programmes.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

  • Suppliers and business partners

Performance Management Policy

Description of key contents

Defines the process, main rules and guidelines regarding managers’ performance management and alignment with business goals and aims to promote a meritocratic and results-driven culture, based on regular feedback and people development. It aims to ensure that performance and each manager’s individual contribution are aligned with business goals and the Group’s values and expected behaviours.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

Workplace Health and Safety Policy

Description of key contents

Defines the guiding principles for the development and implementation of processes and best practices, ensuring compliance with the law and contributing to maintaining a safe and healthy work environment for employees, customers, service providers, suppliers and communities.

More information about our Workplace Health and Safety policies can be found in “Workplace Health and Safety”.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

  • Customers

  • Suppliers and business partners

  • Local communities

  • Official bodies, supervising entities and local authorities

Engagement Policy

Description of key contents

Aims to promote an organisational culture that fosters high levels of commitment and performance in the Group through a methodology that measures and monitors employee engagement. The goals of this policy are to:

  • build a culture of engagement and commitment to the Group’s vision, mission, values, strategy and objectives;

  • provide a channel available to all employees to assess organisational engagement;

  • act as “Corporate and Companies Advisor” for the corporate structure and Group Companies by providing key insights;

  • support the identification and implementation of strategic initiatives that foster a culture of employee engagement and high performance;

  • enhance the Jerónimo Martins brand’s value as a benchmark employer.

This policy can be integrated within the scope of the following disclosure requirement: S1-1.

Most Impacted stakeholders

  • Employees

The Chief Executive Officer is responsible, at the highest organisational level, for the implementation of all policies and codes. Most of the aforementioned documents are publicly available on our corporate website and on the page dedicated to sustainability policies. However, some policies and guidelines are internal and are not disclosed, as they fall under the ESRS provision allowing the omission of information relating to “intellectual property, know-how, or the results of innovation”.

ESRS
ESRS stands for European Sustainability Reporting Standards. These standards are part of the European Union's efforts to enhance and standardise sustainability reporting across companies. The ESRS provide detailed guidelines for reporting on environmental, social, and governance (ESG) topics, ensuring transparency and accountability in corporate sustainability practices
Ecosystem services
The benefits humans receive from natural ecosystems. These can be divided into four main types: provisioning services (e.g., food, fresh water, timber, fiber and medicinal resources), regulating services (such as climate regulation and flood control), cultural services (including recreation and aesthetic experiences) and supporting services (essential processes like soil formation, photosynthesis and biodiversity maintenance that enable the production of other services).
Greenhouse gases (GHG)
A group of gases contributing to global warming and climate change. The Kyoto Protocol, an environmental agreement adopted by many of the parties to the UN Convention on Climate Change in 1997 to curb global warming, covers seven greenhouse gases: carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF₆) and nitrogen trifluoride (NF₃).
Perishable goods
Products with a limited shelf life and that require proper storage to prevent spoilage, for instance, fresh fruits, vegetables, ready-to-eat food, meat and fish sold at the counter and dairy products.

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