Kleinpeter Farms Dairy, L.L.C. (KFD) is committed to operating with high ethical standards and integrity in all of our dealings with employees, customers, suppliers, competitors and the communities in which we carry out our business. Complying with all applicable laws and managing the social, environmental, and economic impact of our business model is critical to KFD’s success. Our consumers expect KFD to uphold high standards of responsible and ethical behavior in our operations and to encourage a similar commitment by companies with which we do business.
Our Supplier Code is designed to aid us and our Suppliers in making the right choice by providing guidance for appropriate business conduct and explaining the behaviors expected. In the years to come, sustainability will be an integral part of our activities. Our goal is to work with suppliers and vendors to assure compliance with these requirements.
Kleinpeter focusses on 3 important pillars:
- Food safety: This is focused on food and safety and quality guaranteed within the product delivered to KFD.
- People and communities: This is focused on labor standards, community, health & safety and business ethics.
- Environment impact: This is focused on environment and Co2 Emissions own process and products.
Guidelines
We expect our suppliers to be committed to the following guidelines:
1. Food safety
1.1 Legislation and certification:
Businesses involved with Food must meet national safety and hygiene requirements in order to safeguard consumer and animal health. Our suppliers are also required by law to formulate a food safety plan in line with the HACCP system and to be recognized by the competent authority as a food processor or handler. Food suppliers within our supply chain should preferably be certified under a GFSI- supported food safety program. The food material must comply with applicable laws and regulations in the country of destination and EU regulation or the Codex Alimentarius. If the purchaser has determined specific limits for its own needs, the strictest shall apply.
1.2 Food fraud and Food defense:
In addition, the food manufacturers must have conducted a food fraud and food defense risk analysis, adopted a plan and taken appropriate measures to be able to implement that plan.
1.3 Traceability:
Food manufacturers and handlers must be able to trace the origins of the ingredients they use and record the destination of their products. If necessary, they must be able to recall an unsafe product within 4 hours after detection of a hazard.
1.4 Transparency and documentation:
Suppliers will be open and transparent and be able to demonstrate and send supporting documents to prove that their products are safe to use, such as certificates, monitoring results and HACCP documentation. Food manufacturers must demonstrate a commitment by the company to deliver food packaging that is safe. Certificates of conformity, or other evidence, shall be available for primary packaging to confirm that the packaging complies with applicable food safety legislation and is suitable for its intended use.
1.5 Corporate Social Responsibility (CSR) Strategy:
Suppliers will be open in their CSR strategy and will inform KFD about the development and status of their CSR targets.
2. People and communities
We expect the supplier to be a socially responsible partner, acting with integrity towards all their stakeholders and anyone else who may be affected by their activities. The supplier should also observe all applicable laws in the countries where it operates.
2.1 Labor standards
2.1.1 Child labor:
The supplier shall not employ children under the legal age of employment in any country or local jurisdiction. The supplier shall apply a minimum working age of 18 years, even where local legislation permits younger children to be employed. Workers under the age of 18 shall only perform work in accordance with legal requirements of their country of employment (e.g. with regards to working time and working conditions) and subject to any requirement regarding education or training.
2.1.2 Forced/ Bonded labor:
The supplier shall not use any form of forced, bonded, compulsory labor or modern forms of slavery. All labor must be voluntary. Workers must be allowed to maintain control over their identification documents (e.g. passports, work permits or any other personal legal documents). The supplier shall ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. The supplier shall be responsible for payment of all fees and expenses (e.g. licenses and levies) relating to workers, where legally required. Punishment, mental and/or physical coercion as well as any other form of human trafficking are prohibited. Disciplinary policies and procedures shall be clearly defined and communicated to the workers.
2.1.3 Wages and hours:
The supplier should offer their employees fair and reasonable employment conditions in areas as salaries, working hours, permits and leave, in accordance with applicable labor regulations and legislation. All extra work on a voluntary basis will be adequately compensated. Suppliers shall maintain a transparent and reliable system to record all working hours, wages and overtime.
2.1.4 Working conditions:
The suppliers should treat their employees with dignity, respect and integrity. The suppliers shall be committed to equal opportunities and not discriminate or tolerate discrimination or harassment with respect to gender, ethnic and national origin, race, color, religion, age, disability, sexual orientation and identity, or any other characteristic protected by law. Suppliers will ban and shall not engage in or allow any form of harassment or abuse of employees.
2.1.5 Health and safety:
Employees must be protected and prevented from exposure to severe health or safety hazards, which lead to risk on cause death or permanent injury or illness. Suppliers must comply with all applicable laws regarding working conditions and should at least provide the following minimum: Drinkable water, clean and accessible restrooms, fire and emergency exits, adequate and appropriate ventilation, temperatures and lighting, adequate protection measures, properly working equipment and emergency aid kits and access to emergency medical care. The supplier should commit to providing a workplace free of harassment and abuse. They should not subject, or threaten to subject, workers to harsh or inhumane actions. This includes, but is not limited to, verbal abuse, psychological or sexual harassment, and mental or physical coercion. Everyone should be able to have access to grievance systems without fear of reprisals against those reporting a grievance.
2.2 Community
KFD wishes to be aware of, and potentially learn from, any positive impact our suppliers are having on local communities. We encourage all suppliers and their employees to get involved in local social and environmental community charity efforts, by providing volunteer time and/or other types of support. We seek long-term partnerships with suppliers that share these philanthropic values.
2.3 Business ethics
2.3.1 Anti-bribery:
Any situation that may involve a conflict of interest between business and personal interest is to be avoided. Suppliers must not engage in any acts of bribery or violate any applicable anti-bribery laws. Suppliers shall not give, offer or receive anything of value including payments, gifts or favors that could influence the collaboration. Facilitation Payments are explicitly forbidden. All signs of corrupt behavior are to be reported immediately to KFD.
2.3.2 Money laundering -related activities:
Suppliers shall not engage in, or support any form of money laundering, terrorist financing or any other financing for illegal purposes.
2.3.3 Antitrust/ competition laws:
KFD is committed to achieving success through fair competition and strictly prohibits any activity that violates antitrust laws. The supplier shall operate in accordance with the principles of free enterprise and fair market competition.
2.3.4 Privacy and data protection:
The supplier shall adhere to applicable data protection laws, including security of personal data, as well as to respective regulation, e.g. General Data Protection Regulation (GDPR), in particular with regard to personal data of customers, consumers, employees and shareholders. The supplier shall comply with all said requirements when personal data is collected, recorded, hosted, processed, transmitted, used or erased. The information security requirements applicable to suppliers with regards to any data entrusted to their control during and after their engagement with KFD are based on international standards, such as the Code of Practice for Information Security Management. Suppliers should take account of the need to protect the confidentiality, integrity and availability of information. At all times the required level of information security and control to be endured by suppliers must be commensurate with the sensitivity, value and criticality of the information being processed throughout the lifecycle of the information. The supplier shall safeguard and make only appropriate use of confidential information. The supplier shall comply with any contractual requirements on data protection and information security and shall not disclose any information that is not known to the general public.
2.3.5 Conflicts of Interest:
A conflict of interest is any personal or financial interest, any business or personal activity or relationship, prior or current employment, or any obligation that may interfere with the ability to objectively perform job duties and responsibilities or impair independence and objectivity. Such conflict-of-interest situations include critical relationships such as a relationship by blood or marriage, partnership, participation or an investment in business partners or competitors. The supplier shall immediately disclose any actual or potential conflict of interest related to its activities with KFD.
3. Environmental impact
KFD suppliers are encouraged to participate in projects, which seeks to ensure ethical practices in the supply chain, reduce impact to the environment or support workers and communities.
3.1 Energy and waste management:
The supplier should measure, and where appropriate seek to reduce, the environmental impact of their business activities. In addition to complying with local laws, steps should be taken to minimize the use of energy and natural resources and to reduce the generation of waste.
3.2 Water management:
The supplier should commit to sustainable use and management of water resources in all areas over which it has control; and where it can meaningfully do so, support and encourage others to do likewise.
3.3 Greenhouse Gas (GhG) emissions and regenerative agriculture:
Suppliers will be open and transparent about their GhG emissions and plan to reduce GhG Emissions within their process as required by their national legislation.
3.4 Responsible sourcing:
The supplier should endeavor to secure their raw materials from fully traceable sources. Furthermore, in case ingredients, such as palm oil or soy are used for fabrication of a product, the supplier needs to ensure that ingredients are RSPO/RTRS (Roundtable on Sustainable Palm Oil/Round Table for Responsible Soy) certified.
3.5 Deforestation and biodiversity:
The supplier should ensure that while retrieving the supplied ingredients, no deforestation takes place. The supplier will seek to reduce environmental impact and protect biodiversity by taking measures within agriculture.
3.6 Animal care/ well being:
The supplier should safeguard the animal's well-being within the supply chain according to local guidelines and standards.
3.7 Emergencies:
The supplier must have procedures in place for handling emergencies such as fire, spills and natural disasters. Furthermore, suppliers must have suitable plans for notifying local community authorities in case of the release of hazardous materials.
4. Verification and compliance:
Suppliers should have adequate monitoring and record keeping systems to ensure compliance with the KFD Supplier Code of Conduct. KFD reserves the right to monitor, review and verify compliance with the Supplier Code of Conduct.
5. Supplier’s Certification of Compliance:
By its acceptance of any purchase order from KFD, the Supplier acknowledges acceptance of the KFD Supplier Code of Conduct and intention to comply with its requirements.
Respectfully,
SUE ANNE KLEINPETER COX
PRESIDENT & CEO
DATE: 09/02/2025