Responsible entrepreneurship

Framework for behaviour

Code of Conduct for cooperation partners

AS OG Elektra was established on 07.10.1991. We opened our first two stores in 1992 in Rakvere.

in 2002 , when we had entered the market in Ida-Virumaa and Harju County and the number of stores had grown to twenty, we applied to the Patent Office for registration of the trademark Grossi Toidukaubad.

2023 Finally, Grossi Grocery stores are present in 11 counties, in 52 different settlements with 79 food and grocery stores and two stores specialising in industrial goods.

In order to inform Employees and Collaboration Partners (hereinafter referred to as Partners) of the principles of responsible business conduct applicable in the day-to-day activities of the company, an “Ethical Conduct Framework” and a “Code of Conduct for Collaboration Partners” have been drawn up as standard terms and conditions for the contracts of Collaboration Partners.

Mission, can be summed up in a nutshell – to be a strong player in our field with the best prices, good quality and home cooking.

The company now employs more than 1,600 people whose daily lives are strongly influenced by the company’s culture and management policies. For an average family of 4, around 6400 people are influenced by the company’s activities on a daily basis, who in turn influence their friends and relatives. This is a large number of people whose choices are influenced. That is why we are paying increasing attention to the foundations of sustainable business performance, including fair competition, zero tolerance for corruption and bribery, a secure supply chain, a safe working environment and environmental sustainability.

In addition to employees, other stakeholders – customers, the local community, suppliers, shareholders, financial markets and the public sector – are affected by the company’s values and business principles. Around 30 million customers visit the store chain every year and more than 300 suppliers are involved in the distribution of around 30 thousand products.

Stakeholders play an important role in assessing double materiality. This means that OG ELEKTRA itself, through its business activities, influences stakeholders and stakeholders influence us. In such an interaction, it is important to understand the expectations of stakeholders and to express our own expectations to them.

In our core activities, we have always been guided by the well-being of the environment and of people, which has resulted from an ethical management culture and a sense of responsibility towards our employees, customers and society. In order to better understand the value chains of the company and the risks and impacts they entail, we have developed an initial sustainability strategy in addition to the business strategy, which is an important step in preparing for sustainability reporting. While the strategy may evolve over time, we have mapped out our own priority SDGs (Sustainable Development Goals). Based on stakeholder expectations, we have divided the key issues into three groups following ESG (Environmental, social and corporate governance) principles – environmental (E), social (S) and governance (G).

To make stakeholders aware of the principles of responsible business conduct that apply to the company’s day-to-day activities, a concise “Ethical Conduct Framework” and a “Code of Conduct for Business Partners” have been drawn up as standard terms and conditions for business partner contracts.

Grossi Grocery, a family-owned store chain, is committed to sustainable business management based on ethical values such as respect for the law, honesty, loyalty, transparency and fairness. These values are firmly embedded in the corporate culture and provide the principles for building our reputation and maintaining the trust of our customers, the public and our employees.

From competition. Fairness determines our relationship with the market and competition. The company does not engage in illegal price-fixing practices with distribution partners or enter into illegal contracts with suppliers;
Zero tolerance for corruption and bribery.The company’s activities are based on objective performance parameters such as quality, performance, service, prices and reputation, and never on corrupt practices;
Secure supply chain. We gain access to markets by complying with legal requirements such as customs, export and import rules. The aim is to improve the reliability of partners throughout the supply chain, from raw materials to the delivery of the product to the customer;
We work in a safe environment. Together, we strive to maintain a healthy workplace in a safe environment. The Safety Officer continuously monitors and analyses all events related to the working environment and provides updates on safety and working standards as necessary.Employee motivation, health and well-being are important to the company We provide a safe working environment for our employees; Employee motivation, health and well-being are important to the company We provide a safe working environment for our employees;
- support work-life balance;
- Competitive pay and equal opportunities for all, both in terms of work and development;
- free sport and physical activity facilities;
- discounted access to a masseur and saunas;
Sustainably protecting the environment. The company is environmentally sustainable in its consumption of natural resources and energy, in the packaging and transport of goods, and in the recycling of materials, and avoids pollutants, including a focus on energy efficiency and carbon neutrality.

We respect each other. The company does not tolerate discrimination on the basis of ethnic background, culture, religion, age, disability, colour, sexual identity, ideology, gender or any other personal attacks on individuals and helps potential victims to protect their rights.
The company remembers all employees on important occasions – whether it’s the completion of a long service contract, the birth of a child or a decent Christmas present every year. At least once a year, the company tries to find a way for all employees to get together to have fun in a non-work environment.
We treat company assets with respect. Employees have a duty of care when handling company assets such as equipment, materials, tools, facilities and buildings;
We protect confidential information. The types of information that employees must protect include the business strategy of AS OG Elektra and its affiliates, products and/or orders under development, customer and supplier lists, production techniques and sensitive financial information;
We avoid conflicts of interest. Professional and personal interests must be kept separate and business decisions must be made in the best interests of the company;
Responding to requests. We respond to requests from public authorities and other legitimate persons by providing information in a timely and accurate manner;
We follow the company’s Code of Conduct. All employees are required to be responsible at work and to comply with the company’s Code of Conduct, including the work rules, management’s legal instructions, privacy policy and other values approved by the company.
Sustainably protecting the environment. The company is environmentally sustainable in its consumption of natural resources and energy, in the packaging and transport of goods, and in the recycling of materials, and avoids pollutants, including a focus on energy efficiency and carbon neutrality.

In the context of energy efficiency

Replace daylight bulbs throughout the company with more energy efficient luminaires;
Fitting rooms with motion sensors to avoid unjustified use of lighting;
Introduction of carbon sensors;
Upgrading of technical equipment in the production units of shops and associated companies to more environmentally friendly equipment;
To reduce the share of electricity generated from fossil fuels:
- Installation of solar panels on the company’s headquarters and logistics centre;
- Equipping existing shops with solar panels, allowing the creation of local electricity generation capacity;
- From 2023 onwards, the roofs of new commercial buildings will be covered by solar panels;

To achieve carbon neutrality

An action plan has been set up to reduce the consumption of single-use plastic food packaging and beverage cups by:
- Collects plastic, paper, wood and glass waste and sends it for reprocessing to Tootjavastutusorganisatsioon OÜ under a contract with:
  - Shop customers are directed to return used single-use plastic packaging to the nearest packaging container for recycling or reuse;
  - Shop customers have been made aware of the impact on the environment, particularly the marine environment, of the dumping of single-use plastic products and their inappropriate disposal;
  - Thin plastic bags will not be handed out free of charge to customers at checkouts.
- Promotes the reduction of single-use plastic packaging, with:
  - food sold in bulk in shops can be packed in paper as an alternative to thin plastic bags;
  - We want to change the behaviour of our customers so that they do not pack fruit and vegetables in separate plastic bags by type.
  - The customer has the option to buy bulk food in their own packaging;
  - At the point of sale, there are instructions for the co-sale of loose food in the customer’s own packaging;
  - Expansion of the product portfolio of mono-material packaging, including food safety and quality assurance;
  - Customers can also choose a paper or cloth shopping bag in addition to a plastic bag at the checkout;
  - In addition to recycled fabric and paper carrier bags, we offer customers the possibility to bundle their purchases in cardboard boxes that have been used as group packaging.
We have reduced the amount of material that needs to be printed, including printing of paper only for documents that must be kept on paper, printing of cashier’s cheques only at the customer’s request, processing of invoices as e-invoices, digital archiving;
We have discontinued direct mailing of leaflets, the leaflet is distributed only in the chain’s stores, which means that the footprint of printing and distributing leaflets is significantly smaller. In addition, the leaflet is also produced from environmentally friendly paper;
More efficient planning of logistics has reduced the number of freight round trips, which has also reduced the amount of emissions released into the environment;

Purpose and provisions
The Code of Conduct has been drawn up on the basis of national and international guidelines and principles that AS OG Elektra’s employees (hereinafter referred to as the Company) and its Partners are obliged to follow in their activities.
The Code of Conduct is the basic requirements of the Company and the legal persons directly or indirectly controlling it, with the aim of creating the preconditions for achieving the highest standards of work ethics in the supply chain. The Code of Conduct expresses the Company’s respect for human rights and promotes work ethics and environmental protection.
Compliance with the principles of the Code of Conduct is mandatory for all the Company’s Partners and is a prerequisite for doing business with the Company. Failure to comply with the principles is grounds for termination of cooperation with Partners.
A Partner’s compliance with the principles of the Code of Conduct is a prerequisite for insisting on the same principles in its business relations, i.e. that its partners comply with the same principles.
Employees of a Partner are encouraged to report possible violations of the Code of Conduct through internal reporting channels, without threat of sanction, or directly to the Company by sending an email to info@ogelektra.ee.
In the event of inconsistencies with applicable law in this Code or other agreements between them, their actions will be guided by stricter requirements.
Ethics
2.1. Business Justice / Anti-Corruption Action
Honest communication between business partners is essential for a trusting business relationship. The Company and the Partner will conduct themselves in an ethical, fair and professional manner in all their dealings.
The Company and the Partner will conduct themselves in an ethical, fair and professional manner in all their dealings.
The Company is firmly opposed to all forms of money laundering and will apply all measures to prevent financial transactions from being used for money laundering, and compliance with this requirement is a prerequisite for the Partner’s cooperation with the Company.
2.2. Ethics and conflict of interest
The Company and the Affiliate shall have zero tolerance for all forms of corruption, including the offer or acceptance of bribes or other forms of illegal payments, gifts of any kind, hospitality tokens or other illegal benefits, as well as the offer, promise, agreement or acceptance, directly or indirectly, of any valuable consideration or other benefit. The purpose of giving, receiving or reciprocating gifts in a business relationship is only to promote goodwill and friendly working relationships, not to influence anyone to engage in any preferential conduct or activities. The giving, receiving and receiving away of gifts must be governed by the law in force and by the more specific internal rules of the company and must avoid in any way any situation where it could be interpreted as illegal or any suspicious practice. No party shall use its position to benefit or give an unfair advantage to any third party.
Employees and Partners of the Company shall behave in a prudent manner and avoid situations where their personal interests would directly or indirectly conflict with the interests of the Company or where they cannot act in the best interests of the Company. The parties shall base their decisions only on objective criteria.
Partner and Employees shall promptly inform the competent persons of the Company of any such situation where a conflict of interest has arisen or is likely to arise.
2.3. Confidentiality and protection of intellectual property rights
Partner will only protect and use confidential information in a manner appropriate to protect the privacy rights of Company and Partners;
Company requires that Partners who collect, process, use, store personal information received from Company about employees, customers, suppliers and other Collaboration Partners use such information only as necessary to comply with all applicable data privacy and data protection laws.
Partner respects and is responsible for the protection of intellectual property rights.
Partner shall not disclose, use or reproduce any Confidential Information without the prior written consent of Company.
Any information or data relating to Company shall always be treated as confidential.
Legal compliance
3.1 Compliance with national and international laws and regulations.
The Partner shall comply with all applicable national laws, regulations and minimum industry standards, other requirements imposed by relevant mandatory legislation, including those expressly referred to in this Code of Conduct, whichever are stricter.
3.2. Complying with national and international trade and customs laws.
The Affiliate will comply with all applicable local and international trade control practices and laws under which the Affiliate conducts business.
The Affiliate will discourage and will not permit any activity that is in violation of customs laws, international treaties or foreign laws, including but not limited to false declarations, fraudulent visas or illegal transhipment, in order to avoid trade restrictions and import quotas.
3.3. Free competition
The Company and the Partner shall at all times and in all respects support free and fair competition in all their activities and shall not prevent, restrict or distort free competition in the conduct of their business.
The Partner and the Company’s employees shall act in compliance with the competition rules and shall not enter into unlawful agreements or act in concert with anyone in a manner that would harm fair competition.
Social Responsibility
4.1 Child labour / discrimination
The Company and the Partner will treat all persons equally in their activities and will respect internationally recognised human rights. No group or individual shall be discriminated against on any grounds, including, but not limited to, sex, age, race, sexual orientation, nationality, ethnic origin, disability, political opinion, membership of an association or religious belief.
The Company is firmly opposed to forced labour, including prison labour, child labour, bonded labour and other forms of bonded labour, which it expects the Partner to respect. Only workers who meet the minimum age requirements in force are permitted to be employed.
Cooperation is subject to the Partner’s compliance with the International Labour Organization (ILO) Conventions No. 138 (Convention concerning the minimum age for admission to employment) and No. 182 (Immediate prohibition of child labour and other forms of work unsuitable for children)
The Company and the Partner shall pay appropriate remuneration for work and results achieved, taking into account the responsibility of the employees and the labour market situation, in accordance with the applicable local laws. The obligation to pay all employees at least the minimum wage established by local legislation.
The Company and the Partner shall create a safe and healthy working environment in accordance with applicable laws and regulations and shall support in every way the personal and professional development of employees. Creating an environment that eliminates the risk of physical or psychological violence, verbal or psychological harassment and/or sexual violence and coercion. Not discriminating against workers’ right to freely join unions, form organisations of their choice and engage in collective bargaining. Ensuring a safe and healthy workplace for workers, including the adoption of appropriate measures to prevent occupational diseases and accidents.
4.2. Salaries, benefits and working conditions
Wages will be calculated as a minimum in accordance with applicable laws and paid promptly according to a schedule in accordance with local regulations.
Prohibition of circumvention of statutory labour and social security provisions. The Partner shall not use work-only, subcontracting or work-from-home arrangements, apprenticeship schemes or other diversionary methods if such measures are taken to avoid regular employment that would oblige the Partner to comply with applicable labour or social security laws.
The Partner shall not make deductions from wages that are unauthorised or not permitted under national law.
The Partner shall establish working hours that comply with national laws, standards or are relevant to the international standard, whichever provides greater protection for the health, safety and welfare of the employees.
The Company expects that the Partner will ensure that overtime worked by the employee is voluntary, agreed with the employee and appropriately compensated in accordance with local and international regulations and collective agreements.
4.3. Health and safety
The Partner is obliged to fully comply with the applicable national health and safety laws.
The Partner must take adequate steps to prevent accidents and injuries to health by remedying work-related or work-related deficiencies, minimising as far as reasonably possible the causes of hazards inherent in the working environment.
Environmental awareness
The company and the Partner are environmentally sustainable in their operations and always strive to do no harm to the environment. In their activities, they value and support recycling, sustainable consumption habits, including saving electricity, water, heating, as well as the environment.
The Company and the Partner comply with environmental laws, regulations and standards, are responsible for the environmental impact of their activities, do not use technology that harms the environment and follow ecologically clean business practices.
5.1 Waste management, disposal of chemicals
The Company and the Partner highly value environmental protection and are committed to doing their part to help conserve the Earth’s finite resources.
Ensure that waste management, chemical handling and disposal procedures and standards, and other hazardous materials, discharges, and wastewater treatment meet the minimum levels required by law.
The Company expects the Partner to strive to develop and implement environmental management and monitoring to promote the recycling and reuse of materials and products and to implement environmentally sound technologies.
5.2. Environmental inventories and registrations, reporting requirements
The Partner must obtain, maintain and keep up to date all relevant environmental permits and registrations required by local regulations and comply with their operation and reporting requirements.
Partner and subcontractor audits and consequences
The Partner is expected to communicate the principles of this Code of Conduct to its subcontractors and third parties and to take its provisions into account when making choices with subcontractors and third parties.
The Partner will establish periodic self-assessments to ensure compliance with the Code of Conduct.
The Company may conduct audits, if necessary, with the involvement of appropriate experts, in order to remedy any deficiencies in the Partner’s performance in a timely manner.
Failure to comply with the terms of the Code of Conduct may result in penalties for the Partner, including, but not limited to, fines, withdrawal of accreditation, reduction of orders, reassignment and/or termination of the business relationship.
Code of Conduct for Responsible Business Cooperation Partners enters into force
The Responsible Business Principles and Code of Conduct are published on the Company’s website https://www.grossitoidukaubad.ee/en/responsible-entrepreneurship/. As of the date of publication, these principles shall be considered as standard terms and conditions, which shall be in addition to the contract to be concluded with the Partner, and which the Partner shall be bound to comply with as of the date of signing the contract.
By signing the contract, the Partner confirms and warrants that its activities are in compliance with the principles discussed and shall ensure that its employees are informed of the rights and obligations under the principles.
The Partner shall provide, at the request of the Company, accurate information or documentation on its activities, including in the areas of labour, health, ethics, safety and the environment, without falsification or concealment of the facts.
The original version of this Code of Conduct is in Estonian. It may be translated into the language of the Partner’s place of business. In the event of any discrepancy between the original version and the translation, the original Estonian version shall prevail.
The Company reserves the right to amend and supplement the terms of the Code of Conduct at any time. The amended terms and conditions of the Code of Conduct shall enter into force upon their publication on the Company’s website at https://www.grossitoidukaubad.ee/en/responsible-entrepreneurship/.