This document sets out Ampère’s Lobbying policy The document includes the following Chapters:
1.Background
2.Policy scope
3.Lobbying policy processrequirements
4.Governance
5.Review and validity
The purpose of this document is to set out a work instruction of the Ahold Delhaize Guidelines for Engaging with Public Policy Makers (Link to policy), its applicability to Ampere, and how Ampere ensures being compliant with the underlying policy requirements throughout the business and operations.
These Guidelines for Engaging with Public Policy Makers or intermediary organizations outline the principles and practices to adhere to when conducting any political activity or outreach.
|
Topic |
Policy requirement |
In scope? |
|
General Approach |
The organization only engages with political parties and officials on the basis of issues that affect our businesses and our associates and not on the basis of preferring one political party over another. Political engagement reflects our interests as a business and not the personal preferences of any individual director, officer or associate. |
In scope for Ampère |
|
The organization is responsible for addressing relevant public policy matters in a structured manner. The goals of the Company1 and the organization are to work with public officials, stakeholders and other groups to achieve policies that help them meet the Company’s business objectives while improving the communities where we work and live.
|
In scope for Ampère | |
|
Engaging (Indirectly) via Industry Associations and Chambers of Commerce |
We routinely review our trade association memberships to ensure that our corporate values and business objectives align on the issues most important to us, though the Company may not always agree with all of the positions taken by organizations of which we are a member. |
In scope for Ampère |
|
Associates and officers who represent the Company or the organization on boards or committees of industry and/or other associations may take positions on behalf of the Company, provided that they respect applicable competition rules, are well informed about the Company's interests at stake and act within their mandate |
In scope for Ampère | |
|
Engaging (Directly) as a Company |
The organization may express its views on international, national, regional and local public policy developments and issues that affect the business. In such cases, Company resources and funds may be used and/or contributed, but only to the extent consistent with relevant internal policies and guidelines, such as the Company’s Anti-Corruption and Bribery Policy, and in accordance with applicable law. Company funds will never be used to reimburse a political contribution by an associate. |
In scope for Ampère |
|
In the U.S., the Company maintains a Political Action Committee (PAC) as permitted by U.S. law. The PAC is a separate segregated fund that pools voluntary contributions from eligible U.S. associates to support specific candidates or issues. […] As a general rule, the Company does not make direct contributions to U.S. federal, state or local candidates using corporate funds even where legally permitted to do so. Political contributions are made through the PAC to support candidates who best represent the interests of our Company and the retail grocery industry. |
n/a | |
|
The organization may host visits of public policy makers, both in and outside times of elections. All such visits should be organized by or together with the relevant Public Affairs department. Those who engage on behalf of the Company or the organization with public policy makers must be well informed about the Company's interests and position relative to the issue(s) being addressed and must consult with Public Affairs of bol prior to engagement to ensure policy continuity and uniformity of effort. |
In scope for Ampère | |
|
Charitable and Other Giving |
In addition to supporting candidates through PACs and membership in industry associations, the organization may also directly support charitable, social welfare and other organizations when it determines that such engagement is in the best interests of the Company and aligned with the Company’s values. Financial support for these organizations is made in line with the Company’s Anti-Corruption and Bribery Policy and in accordance with all applicable national, regional and local laws. |
In scope for Ampère |
|
Engaging as an Associate |
Participating in political activities unrelated to corporate endeavors is entirely personal and must be conducted in the associate's own time and not on Company premises or Company communications channels. Associates should never hold themselves out as representatives of the Company or the organization while engaging in political activities in their own capacity, nor should associates use their authority or position to coerce other associates to support or oppose any candidate or issue for personal purposes. Associates may not use Company or the organization’s facilities or resources, including telephones, computers, company communication channels, copiers and office supplies for any personal political purposes. Additionally, associates shall not make or promise to make a political contribution for the purpose of obtaining or retaining business for the Company. |
In scope for Ampère |
|
Sponsoring of Political Activities |
Neither the Company nor the organization sponsors, in cash or in kind, any political parties, individual politicians or activities related to specific political parties. Other activities that can be linked to general political activities (not linked to one specific political party) are assessed on a case-by-case basis. All such support should be in line with the overall interests of the Company and in accordance with applicable law. The Company will not reimburse or compensate associates for their personal political activities. |
In scope for Ampère |
|
Compliance with the law |
The Company and the organization are committed to ensuring that any public affairs or political activity is done in full compliance with all laws and regulations, in accordance with our zero tolerance approach to bribery and corruption as set out in the Ahold Delhaize Code of Ethics and the Ahold Delhaize Global Anti-corruption and Bribery Policy. The use of Company funds or assets for any unlawful, improper or unethical purpose is prohibited. Associates are strictly prohibited from directly or indirectly promising, offering, authorizing or providing any benefit, payment, or anything of value (referred to collectively as an "improper payment") to anyone in order to improperly influence a government official, to induce an action or forbearance by a government official, or to secure any improper advantage in obtaining or retaining business. |
In scope for Ampère |
|
Reporting Potential Violations |
Anyone who is or becomes aware of a potential violation or a risk of violation or any practice that may violate anti-corruption and bribery laws should report the matter promptly to the Legal department or Compliance and Ethics resource. Associates may also make a report to the Global Compliance and Ethics team through the Speak Up line, and such report may be made anonymously. |
In scope for Ampère |
1. General Approach
* The organization only engages withWe only engage with political parties and officials on the basis of issues that affect our businesses and our associates and not on the basis of preferring one political party over another.
* Political engagement reflects our interests as a business and not the personal preferences of any individual director, officer or associate.*/
We are The organization is responsible for addressing relevant public policy matters in a structured manner and coordinating its overarching public affairs agenda globally.
Disclosure, transparency and accountability
We are always transparent about who we are, the company that we represent, the interests we stand for and the purpose of our outreach.
oIt is a dedicated task of Ampere’s CEO to represent Ampere (e.g. in interactions with relevant external stakeholders)
Truthful information
We only share accurate information with stakeholders, that is based on facts, data or scientifically proved.
We always work via the four-eye principle in sharing information or statements and reaching out to stakeholders.
oIn case of high-level outreach or impactful topics, the outreach or statements are always reviewed by the Public Affairs team of bol.
oIn case of external statements by Ampere signed by a management team member, this is approved by the Public Affairs team of bol.
Ethics
We adhere to the Code of Ethics of the Company. The Code of Ethics applies to all employees of Ampere and forms part of the employment contract that every employee signs before starting work at Ampere.
oThis covers topics such as conflict of interest and gifts but also compliance with the law and speaking up.
Alignment with the Ampere strategy and Company strategy (Ahold Delhaize)
Ampere’s lobbying and stakeholder engagement work are aligned with Ampere’s strategy and purpose: “Zo duurzaam mogelijk en ondersteund door de beste tech, pakketjes van alle ondernemers in Nederland op de dagvoorkeur van de klant bezorgen om bij te dragen aan een leefbare wereld voor de toekomstige generatie”, and helps us focus on the things that matter most.
Internal governance and monitoring
These guidelines are formally reviewed and approved by the Director Ampere B.V., who will review this document on a yearly basis and review and approve any adjustments made.
The Delegated Ampere CEO will yearly evaluate compliance with the governance and control framework of these guidelines
The Director Ampere B.V. and Delegated Director will yearly evaluate this documents and make adjustments if needed.
The Delegated Ampere CEO is responsible for identifying risks of non-compliance with these guidelines. In that case, he or she will report to the Director Ampere B.V., who is responsible for monitoring and managing these risks.
These guidelines will be included in the onboarding of new colleagues that will be involved in public affairs activities. The Delegated Ampere CEO is responsible for ensuring that new colleagues take note and understand this document during their onboarding.
2. Engaging (Indirectly) via Industry Associations and Chambers of Commerce
* We routinely review our trade association memberships to ensure that our corporate values and business objectives align on the issues most important to us.
* Associates and officers who represent the Company or the organization on boards or committees of industry and/or other associations may take positions on behalf of the Company, provided that they respect applicable competition rules, are well informed about the Company's interests at stake and act within their mandate
We are actively engaged in discussions with our trade associations about their agenda, strategy and actions to make sure that they are aligned with our interests and goals, and not breach our corporate values and business objectives.
Where relevant, we provide input to position papers and statements that touch upon topics that are of interest for Ampere.
In case the Industry Association acts contrary to our purpose and/or makes statements or proposals that negatively impact society or the environment, the Delegated Ampere CEO will discuss this with the Director Ampere B.V. and decide on escalation measures, such as (but not limited to) 1) a dialogue with the Industry Association board to express our concerns, 2) in case of a serious breach, an external statement that Ampere does not support these actions, 3) as a last resort, reconsider the Ampere membership.
Colleagues that are actively engaged in Industry Associations have to adhere to our internal policy for outside business activities and to the Ahold Code of Ethics.
3. Engaging (Directly) as a Company
* The organizationWe may express its views on international, national, regional and local public policy developments and issues that affect the business. Resources In such cases, Company resources and funds may be used and/or contributed, but only to the extent consistent with relevant internal policies and guidelines, such as the Company’s Anti-Corruption and Bribery Policy, and in accordance with applicable law.
* Company funds will never be used to reimburse a political contribution by an associate.
* The organizationWe may host visits of public policy makers, both in and outside times of elections. All such visits must be coordinated with the Public Affairs team at Ampère to ensure alignment on positions and key messaging.
4. Charitable and Other Giving
In addition to supporting candidates through PACs and membership in industry associations, the organization may also directly support charitable, social welfare and other organizations when it determines that such engagement is in the best interests of the Company and aligned with the Company’s values.
5. Engaging as an Associate
Participating in political activities unrelated to corporate endeavors is entirely personal and must be conducted in the associate's own time and not on Company premises or Company communications channels.
Associates should never hold themselves out as representatives of the Company or the organization while engaging in political activities in their own capacity, nor should associates use their authority or position to coerce other associates to support or oppose any candidate or issue for personal purposes.
We adhere to the Code of Ethics of the Company. The Code of Ethics applies to all employees of Ampere and is part of and is part of the Wegwijzer that every employee signs in the onboarding.
oOne of the guiding principles is “We act ethically in all our relationships”
oThe Ahold Global Conflict of Interest Policy offers further guidance.
oThis covers topics such as conflict of interest and gifts but also compliance with the law and speaking up.
6. Sponsoring of Political Activities
Neither Companythe Company nor the organization sponsors, in cash or in kind, any political parties, individual politicians or activities related to specific political parties. Other activities that can be linked to general political activities (not linked to one specific political party) are assessed on a case-by-case basis.
We adhere to the Code of Ethics of the Company. The Code of Ethics applies to all employees of Ampere and is part of the Wegwijzer that every employee signs in the onboarding.
oOne of the guiding principles is “We act ethically in all our relationships” and describes the guidelines for gifts and entertainment.
oThis covers topics such as conflict of interest and gifts but also compliance with the law and speaking up.
7. Compliance with the law
The Company and the organization are committed to ensuring that any public affairs or political activity is done in full compliance with all laws and regulations, in accordance with our zero tolerance approach to bribery and corruption.
We adhere to the Code of Ethics of the Company. The Code of Ethics applies to all employees of Ampere and is part of the Wegwijzer that every employee signs in the onboarding.
oOne of the guiding principles is “We follow the law”, we comply with applicable laws and regulations everywhere we do business.
oThis covers topics such as conflict of interest and gifts but also compliance with the law and speaking up.
8. Reporting potential violations
Anyone who is or becomes aware of a potential violation or a risk of violation or any practice that may violate anti-corruption and bribery laws should report the matter promptly to their local Legal department or Compliance and Ethics resource
We adhere to the Code of Ethics of the Company. The Code of Ethics applies to all employees of Ampere and is part of the Wegwijzer that every employee signs in the onboarding.
oOne of the guiding principles is “We have the courage to Speak Up”
Every employee is encouraged to report any misconduct by contacting a local or global Ethics representative or by using the Speak Up line. Additionally, associates also have the option to contact their manager, local HR representative, local or global Ethics representative or use the Speak Up line, in case of questions, concerns or if they want to discuss any issues.
The Ahold Delhaize Global Speak Up Policy provides information about how to Speak Up, the available reporting resources, the reporting process and the safeguards.
The four ethical principles are explained further in the Code of Ethics using various scenarios.
oThis covers topics such as conflict of interest and gifts but also compliance with the law and speaking up are part of the Code of Ethics.
4. Governance
|
Role |
Name |
Function |
Responsibility |
|
Ampere owner |
GJ Janssen M. Zubiaurre |
Director Ampere BV’s |
Responsible for signing off the guidelines Responsible for formally reviewing and approving the guidelines on a yearly basis Monitoring and managing risk of non-compliance |
|
Functional Owner |
W Barkman / CEO Ampere |
Delegated |
Responsible for yearly execution and control mechanism Yearly evaluation of compliance with the governance and control framework Identifying risks of non-compliance |
5. Review and validity
Nothing expressed or referred to in this policy will be construed to give any stakeholder any legal right, claim or expectation with respect to this policy on stakeholder engagement. This policy may be amended or revoked by the management Team of Ampere at any time and without prior notice. The company reserves the right to deviate from this policy.
1 By Company, Ahold Delhaize is meant