Code of Ethics

Purpose

Le Nouveau Chef is a reputable, high-quality chef and catering clothing company that prioritizes integrity and high ethical standards. Le Nouveau Chef’s Code of Ethics ensures employees, officers, and directors uphold these values and comply with laws. Le Nouveau Chef also expects third parties, including consultants, agents, distributors, and vendors, to adhere to their ethical standards. This Code of Ethics is part of the employee handbook. Employees will be informed when the employee handbook is updated.

Le Nouveau Chef's commitment extends globally, applying their Code of Ethics universally. By maintaining these principles, Le Nouveau Chef fosters trust, builds relationships, and contributes positively to society. As a trusted leader, Le Nouveau Chef upholds their Code of Ethics to excel in the chef and catering clothing industry with integrity. In addition, training courses in the field of ethics are offered to employees on a regular basis.

Global applicability

The Code of Ethics has global applicability and must be adhered to in all company operations, regardless of the location or prevailing local laws, customs, or business practices.

How to use this code

This code sets out the standards everyone at Le Nouveau Chef is expected to live by. It is written to be read, not filed away. You are not expected to memorize it; you are expected to know it exists, recognize when a situation calls for it, and know where to go for help.

If you only remember three things:

• Act honestly, in everything you do for the company.
• Speak up, if something looks wrong, raise it. You are protected when you do.
• When unsure, follow the Grievance procedure.

What's in this code?

1. About this Code: who it covers, who to contact, your responsibility.
2. Our standards of conduct: the rules, grouped by theme.
3. Raising concerns: how to report something and how you're protected.
4. Responsible lobbying & political contributions.
5. Violations & consequences.

Personal accountability

At Le Nouveau Chef, every employee, officer, director and external stakeholder bears personal responsibility for upholding the Code of Ethics. This code is rooted in key principles, including:

• Compliance: Observing all applicable laws and regulations governing our business activities.
• Integrity: Demonstrating honesty, fairness, and trustworthiness in all interactions and relationships.
• Conflict of Interest: Avoiding conflicts between personal affairs and work responsibilities, including refraining from giving or receiving gifts that could improperly influence business decisions.
• Fair Employment: Cultivating an environment where fair employment practices extend to every member of our organization.
• Workplace Safety: Striving to create a safe workplace and ensuring our vendors maintain the same commitment.
• Accurate Reporting: Timely and accurately recording and reporting business and financial information in a completely transparent way.
• Leadership: Exemplifying leadership at all levels, fostering a culture that recognizes and values ethical conduct.

Our standards

These are the rules, grouped into five themes. Each is written as a standard you can apply. Compliance with laws and regulations is essential for upholding Le Nouveau Chef's integrity. All individuals associated with Le Nouveau Chef must have knowledge of and adhere to the laws and regulations relevant to Le Nouveau Chef's operations.

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1. People & the workplace

Employment and workplace standards

Overall, Le Nouveau Chef's commitment to maintaining a positive work environment, complying with legal and ethical standards, and prioritizing employee well-being underscores its dedication to excellence and integrity in all aspects of its operations.

Preventing discrimination and harassment

Le Nouveau Chef places great importance on maintaining a positive work environment that fosters success. Valuing its diverse workforce, Le Nouveau Chef strives for inclusivity and acceptance, ensuring employees and stakeholders feel safe and secure. Discrimination and harassment are strictly prohibited, and employment decisions are based solely on individual skills and efforts, free from bias.

Compliance with wage and hour laws

Compliance with wage and hour laws is a core principle for Le Nouveau Chef. Le Nouveau Chef ensures proper compensation for employees, adhering to regulations governing off-the-clock work, meal and rest breaks, overtime pay, termination pay, and child labor restrictions.

Workplace safety

Workplace safety is of paramount concern. Le Nouveau Chef is committed to providing a safe and healthy environment, implementing comprehensive training programs for employees across all manufacturing facilities. Le Nouveau Chef complies with all relevant laws and industry standards to protect the well-being of its workforce and stakeholders.

Through upholding these employment and workplace standards, Le Nouveau Chef creates an environment conducive to employee growth and collective success. Le Nouveau Chef's dedication to inclusivity, fairness, and safety reflects its commitment to the well-being and professional development of its employees. By fostering a positive work atmosphere, Le Nouveau Chef encourages employee engagement, productivity, and a shared sense of purpose.

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2. Integrity & avoiding conflicts of interest

Act in the best interests of Le Nouveau Chef

We prioritize acting in the best interests of Le Nouveau Chef to safeguard its reputation and credibility. Employees, officers, directors, and third parties must make decisions aligned with Le Nouveau Chef's best interests, comply with applicable laws, maintain accurate records, and engage in appropriate communication.

Avoiding conflicts of interest is paramount

Employees, officers, and directors should steer clear of situations where personal or financial interests may compromise their loyalty to Le Nouveau Chef. They must disclose any actual or potential conflicts of interest to their manager in writing, including situations where personal gain could be derived from Le Nouveau Chef's business dealings.

Conflicts of interest arise when an employee, officer, or director, or their family members, hold ownership in or engage with outside enterprises involved in or competing with Le Nouveau Chef, serve in capacities with such enterprises, act as intermediaries benefiting third parties in transactions involving Le Nouveau Chef, or face any arrangements or circumstances that hinder them from acting in Le Nouveau Chef's best interests, with exceptions requiring approval from the Le Nouveau Chef's confidant.

Avoiding improper gifts, favors, and payments

Employees, officers, and directors of Le Nouveau Chef may encounter situations where they have the opportunity to offer or accept gifts, meals, travel, or other valuable items in their interactions with customers, vendors, and third parties. While such activities can foster positive working relationships, they can easily give rise to actual or perceived conflicts of interest and even allegations of bribery if not handled appropriately. Moreover, dealing with government representatives often necessitates even stricter standards.

Company expenditures: gifts, favors, entertainment, and payments

• Expenditures for gifts, favors, entertainment, and payments may be incurred by Le Nouveau Chef, provided they satisfy the following criteria:
• They align with accepted local business practices.
• They are of limited value, approved within the allocated department budget, and presented in a manner that avoids any perception of bribery or payoff.
• They comply with applicable laws, widely recognized ethical standards, and the recipient's organization rules.
• Public disclosure of these expenditures will not bring embarrassment to Le Nouveau Chef or create the appearance of impropriety.
• Accurate records are maintained, ensuring transparency and reflecting the true nature of the transaction.

Receiving gifts, favors, entertainment, and payments by company employees, officers, and directors

Employees, officers, and directors are prohibited from seeking or accepting, for themselves or others, any gifts, favors, entertainment, or payments from personal or business entities that currently or potentially engage in business with or are competitors of Le Nouveau Chef, unless there is a legitimate business purpose. Employees of Le Nouveau Chef are strictly forbidden from accepting any funds or assets, including preferential treatment, in exchange for securing business or obtaining special privileges from Le Nouveau Chef. Engaging in or facilitating bribery, kickbacks, or unlawful payments, or attempting to initiate such activities, will result in termination and potential criminal prosecution. It is the duty of all employees to promptly report any actual or attempted instances of bribery, kickbacks, or fraud to Le Nouveau Chef.

Acceptance of gifts, courtesies, and entertainment by employees, officers, and directors

Employees, officers, and directors are permitted to accept customary courtesies in line with local business practices, up to a value of €250 EUR (or equivalent in local currency), or the amount allowed by applicable law in the given country, whichever is lower. Such courtesies may include items like calendars, pens, pads, or perishable goods typically exchanged during holidays, such as hams, cookies, nuts, and light alcoholic beverages. Any gifts exceeding this limit must receive approval from the Le Nouveau Chef's confidant and may include:

• Lunches and dinners with vendors of reasonable value, occasionally including spouses, provided the invitation originates from the vendor.
• Tickets to events, including sports and arts, offered by the vendor.
• Gift cards.
• Overnight stays, day outings, or golf activities, contingent upon the presence of individuals from other companies or vendors, with prior authorization from the relevant company officer.
• Accepting cash gifts of any amount is strictly prohibited

Furthermore, management employees, officers, or directors must exercise discretion when receiving gifts from subordinates, ensuring they are of limited value.

Prohibition of improper payments

No individual acting on behalf of Le Nouveau Chef is permitted to offer or accept any form of value with the intention of improperly influencing a business decision, including bribes, kickbacks, facilitation payments, or fraudulent activities. Le Nouveau Chef strictly prohibits bribery in all commercial engagements and acknowledges that numerous countries, including the Netherlands, have specific regulations regarding the provision of anything valuable to government officials, encompassing government agencies and entities owned or controlled by the government (such as public utilities, telecommunications companies, or news agencies). All payments or gifts provided to government officials or business partners must be legitimate, well-documented business expenses and must not seek to gain an improper business advantage. Employees, officers, and directors are responsible for ensuring that any individual or organization representing Le Nouveau Chef (e.g., consultants, agents, sales representatives, distributors, or contractors) adheres to this Code of Ethics and relevant legal requirements.

Ethical and professional dealings with vendors, customers, competitors, and third parties

Le Nouveau Chef is dedicated to fostering a business environment that upholds the utmost standards of professionalism and ethical conduct. It is expected that all employees, officers, and directors engage in honest, fair, and ethical interactions with Le Nouveau Chef's vendors, customers, competitors, and fellow colleagues. This Code of Ethics is specifically designed to align with the guidelines set forth by the EU legislation on anti-corruption and anti-bribery laws (EU conventions 1997/2003) and other relevant anti-bribery laws applicable in the jurisdictions where we conduct business.

Report it: any actual or attempted bribery, kickback, or fraud must be reported promptly (see ‘raising concerns’ part). Involvement can lead to termination and criminal prosecution.

Safeguarding the confidentiality of material non-public information

Sharing material non-public information is strictly prohibited. Employees, officers, and directors should maintain confidentiality and refrain from using or disclosing such information for personal or financial benefit. This includes trading securities based on insider information or sharing it with others who may act upon it. Le Nouveau Chef emphasizes the importance of maintaining the confidentiality of company information, only disclosing it when necessary for business purposes and to authorized individuals within Le Nouveau Chef.

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3. Protecting the company

Protect confidential information

Le Nouveau Chef places great importance on protecting confidential information, which encompasses a wide range of valuable assets including strategic plans, financial data, trade secrets, and intellectual property, all of which must be kept confidential and secure to ensure Le Nouveau Chef's ongoing growth and competitiveness. Every employee, officer, and director bears the responsibility of safeguarding this information and must not disclose it externally unless authorized by a non-disclosure agreement or required by law. It is equally vital to maintain the confidentiality of information from other companies, including vendors and customers, and inquiries from third parties, such as media or securities professionals, should be directed to a local facility manager or the Le Nouveau Chef's director. This Code of Ethics does not restrict reporting company information to government agencies or impede employees' rights to collective action under applicable law.

Safeguarding company assets

Le Nouveau Chef prioritizes the protection of its valuable assets, which include intellectual property, equipment, materials, and technology resources, as their theft, loss, carelessness, or misuse directly impacts Le Nouveau Chef's financial performance. Employees, officers, and directors are prohibited from using company assets for personal benefit or for the benefit of others, and it is crucial to maintain the security of technology resources to prevent potential cyber threats.

Respecting data privacy

Le Nouveau Chef is committed to respecting data privacy, complying with privacy laws and policies when handling personal data of employees, customers, and vendors, ensuring that such data is used solely for legitimate business purposes and only shared with individuals having a legitimate business need, unless legally compelled to disclose.

Maintaining security measures and establishing crisis management strategies

Le Nouveau Chef is dedicated to safeguarding the security of its employees, facilities, and information, and employees, officers, and directors are expected to adhere to security protocols, including wearing proper identification, allowing only authorized personnel into work areas, and promptly reporting any signs of workplace violence or potential security breaches to the appropriate manager.

Maintain accurate records and ensure transparent financial reporting

Le Nouveau Chef emphasizes the importance of maintaining precise and up-to-date information for making informed business decisions and fulfilling legal obligations. Therefore, all company records and accounts must adhere to relevant regulations and standards, accurately reflecting the true nature of transactions. It is the duty of every employee, officer, and director to uphold this responsibility. In order to ensure the accuracy of Le Nouveau Chef's records, employees, officers, and directors must refrain from engaging in activities such as creating false entries, establishing undisclosed accounts, disbursing funds without proper documentation, manipulating quality or safety results, improperly recording expenses, providing false information to accountants, or attempting to influence auditors in a fraudulent or misleading manner during audits or financial statement reviews.

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4. The marketplace & third parties

Ethical vendor relationships

Le Nouveau Chef maintains relationships with vendors that adhere to lawful, efficient, and equitable practices. Compliance with all applicable laws regarding vendor relationships is mandatory, and Le Nouveau Chef engages only with vendors who agree to comply with legal requirements, treat workers fairly, ensure a safe work environment, and protect the environment. Vendors conducting business with Le Nouveau Chef are also required to sign the Responsible Business Conduct.

Fair treatment of customers

Statements regarding company products and services must always be truthful, accurate, and devoid of any misleading information. It is crucial to avoid taking unfair advantage of anyone through manipulation, abuse of confidential information, fraud, or any other unfair practices. Compliance with these principles is essential for upholding Le Nouveau Chef's esteemed reputation.

Commitment to open and fair competition

Le Nouveau Chef is committed to surpassing competitors through fair means by providing superior products and services, refraining from unethical business practices. In all the countries where Le Nouveau Chef operates, competition laws, also known as "antitrust laws," regulate competitive activities to safeguard customers and the public against unfair practices that hinder competition. These laws may vary across different countries. Employees, officers, and directors are strictly prohibited from engaging in activities that collude with competitors to restrict competition or trade. This includes:

• Agreeing to establish or maintain prices or terms and conditions of sale.
• Engaging in bidding collusion.
• Dividing markets, territories, or customers.
• Discussing the boycott of a third party.
• Partaking in any other form of contact that may give the appearance of improper agreements or understandings.
• If a competitor initiates a conversation involving any of these prohibited topics, regardless of the casual nature, it is crucial to promptly end the discussion and report the incident to a company manager or Le Nouveau Chef's confidant.

Never seek competitor's confidential information and comply with international trade controls

Gaining insights into competitors is crucial, but Le Nouveau Chef values ethical conduct. Employees, officers, and directors must refrain from soliciting a competitor's confidential information from vendors, customers, or new hires. If inadvertently received, report it immediately. Adherence to international trade control laws is vital. Employees, officers, and directors must meticulously comply with import/export regulations, ensure accurate declarations, verify product classifications, and screen transactions to comply with rules on restricted exports. Participation in prohibited restrictive trade practices or boycotts is strictly forbidden.

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5. Society & the environment

Human rights and the environment

Le Nouveau Chef acknowledges its duty to the local communities where it operates globally. As a responsible global corporate citizen, Le Nouveau Chef upholds ethical business practices. Upholding human rights, Le Nouveau Chef strictly prohibits the use of forced, involuntary, or child labor in any of its facilities or throughout its supply chain. Respecting the Environment: Full compliance with local environmental laws is mandatory at all company locations worldwide, and this expectation extends to the supply chain. Ensuring Vendor Compliance, Le Nouveau Chef enforces ethical standards through a dedicated Responsible Business Conduct, conducting periodic audits (SMETA) to verify vendor compliance.

Communities & giving back

Le Nouveau Chef promotes a culture of giving back through its philanthropic initiatives. Le Nouveau Chef encourages employee participation by providing policies that allow them to contribute to charitable causes. By supporting donations and philanthropy, Le Nouveau Chef aims to make a positive impact on communities and foster a sense of social responsibility among its employees.

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6. Raising concerns

If you see or suspect something that breaks the law, this Code, or another company policy, you have a responsibility to raise it. Speaking up early lets us put things right.

How to raise a concern

Addressing concerns

Every stakeholder of Le Nouveau Chef holds a personal responsibility to familiarize themselves with the Code of Ethics, seek guidance in the face of legal or ethical dilemmas, and report any observed or suspected non-compliance with applicable laws, Le Nouveau Chef's Code of Ethics, or other company policies. Managers carry an additional duty to lead by example, fostering an ethical culture and displaying exemplary conduct in all their actions. They also serve as a trusted resource for team members seeking guidance on challenging situations.

Various external options are available for discussing concerns or reporting issues, including: Concerns can be submitted through the “Grievance Form” on Le Nouveau Chef’s website. This is outlined in the External Grievance Procedure.

Whistleblowing procedure

Le Nouveau Chef upholds a whistleblowing procedure, valuing employees who raise concerns to facilitate prompt issue identification and resolution. Le Nouveau Chef strictly prohibits any reprisals against those who raise business practice concerns in good faith. Raising concerns in "good faith" means providing honest and accurate information, even if later found to be mistaken. Reports made in good faith are safeguarded, ensuring they do not lead to disciplinary action or discrimination.

Employees facing retaliation should report incidents promptly to their supervisor or the Le Nouveau Chef's confidant. Le Nouveau Chef takes retaliation allegations seriously, conducting thorough reviews of complaints involving retaliatory actions, threats, or attempts.

We foster a supportive environment where employees can freely voice concerns without fear of reprisal. Le Nouveau Chef promotes open communication and takes decisive measures to address any instances of retaliation.

Non-retaliation and encouraging reporting

At Le Nouveau Chef, employees play a crucial role in identifying and rectifying issues within Le Nouveau Chef. Any employee who raises concerns about business practices in good faith will be protected against retaliation. "Good faith" refers to providing honest and accurate information, even if the employee's understanding is later found to be incorrect. Reports made in good faith cannot be used as a basis for disciplinary action or discrimination. If an employee believes they have experienced retaliation, they should report it to their supervisor or the Chief Ethics Officer. Le Nouveau Chef takes allegations of retaliation seriously and will thoroughly investigate all complaints.

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7. Responsible lobbying & political contributions

How we engage with public affairs and the political process matters as much as how we run day-to-day operations. We engage responsibly, transparently, and in line with our values, our B Corp commitments, and the law.

Le Nouveau Chef recognizes that business conduct extends beyond day-to-day operations to include how the company engages with public affairs, political processes, and external organizations. This policy sets out Le Nouveau Chef's approach to responsible lobbying and political contributions, ensuring that any engagement in these areas is consistent with our values, our B Corp commitments, and applicable law.

For the purposes of this policy, lobbying means direct or indirect engagement with policymakers, regulators, public authorities, trade associations, or other organizations for the purpose of influencing legislation, regulation, or public policy.

Commitment to responsible lobbying

Le Nouveau Chef will only engage in lobbying activities, whether directly or through intermediary organizations, where such activities are aimed at contributing to a positive impact on society or the environment. We will not lobby for positions that conflict with our stated values, our Code of Ethics, or our B Corp principles.

Any lobbying position taken by Le Nouveau Chef will be grounded in reliable data, scientific evidence, or both. We do not support or promote positions based solely on commercial self-interest where these would conflict with broader societal or environmental well-being.

Relevant lobbying activities, policy positions, and associated expenditures shall be documented and made available for internal review and, where appropriate, external disclosure.

Financial and in-kind political contributions

Le Nouveau Chef takes a cautious and transparent approach to political contributions:

No employee, officer, or director may make financial or in-kind contributions to political parties, candidates, or campaigns using company funds or assets without prior written approval from the management team.

Any approved contribution must be documented accurately, serve a legitimate purpose, and not seek to gain an improper advantage.

Personal political contributions by individual employees, officers, or directors using their own funds remain a matter of personal choice and are not governed by this policy. Personal political activities must be undertaken outside working time, without use of company resources, and without representing Le Nouveau Chef unless explicitly authorized.

Le Nouveau Chef will not make contributions, financial or otherwise, that could be perceived as an attempt to improperly influence a political decision or public official.

Anti-corruption and anti-bribery

All lobbying activities must comply fully with Le Nouveau Chef's anti-corruption and anti-bribery commitments as set out in Clause 18 of this Code of Ethics. Specifically:

No payments, gifts, or other items of value may be offered to public officials, political representatives, or their associates in connection with lobbying activities.

Any engagement with government representatives in the context of lobbying must be conducted transparently and in accordance with applicable law.

Employees involved in lobbying activities are required to report any request for improper payments or gifts immediately to the confidential advisor.

Lobbying via intermediary organizations

Le Nouveau Chef may engage in lobbying indirectly through trade associations, industry groups, or other intermediary organizations. When doing so:

Le Nouveau Chef will assess whether the lobbying positions of such organizations are consistent with this policy before joining or contributing to them.

Where an intermediary organization adopts lobbying positions that are materially inconsistent with this policy or Le Nouveau Chef's values, Le Nouveau Chef will raise its concerns with the organization, seek to influence the organization toward alignment, document any material divergence, consider communicating its position transparently to relevant stakeholders, and, where appropriate, withdraw its participation or financial support.

The management team is responsible for periodically reviewing Le Nouveau Chef's memberships and financial contributions to intermediary organizations to ensure ongoing alignment with this policy.

Governance, accountability & review

The following governance structure applies to this policy:

Le Nouveau Chef identifies and manages risks of non-compliance with this policy as follows:

• Any planned lobbying activity or political contribution above a de minimis threshold must be pre-approved by the Managing Director and documented in writing.
• The management team conducts an annual review of all lobbying activities and political contributions made during the preceding year to evaluate compliance with this policy.
• Breaches of this policy will be treated as violations of the Code of Ethics and may result in disciplinary action, including termination, in accordance with Clause 4.

Raising concerns

Any employee, officer, director, or external stakeholder who has concerns about Le Nouveau Chef's lobbying activities or political contributions, or who suspects a violation of this policy, is encouraged to raise these concerns through the following channels:

• Internal concerns: via the confidential advisor or through the Internal Grievance Procedure
• External concerns: via the External Grievance Procedure publicly available on the Le Nouveau Chef website
• Serious misconduct or legal violations: via the Whistleblowing Procedure.
  Le Nouveau Chef strictly prohibits retaliation against anyone who raises concerns in good faith under this policy.

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8. Violations & consequences

Code of ethics violations and consequences

At Le Nouveau Chef, violations of the Code of Ethics may result in disciplinary measures, including termination. We are committed to reporting such violations to authorities when necessary, upholding our commitment to ethical business practices.

Investigation and resolution of potential violations

At Le Nouveau Chef, we take reports of potential violations seriously and are committed to conducting thorough investigations. Upon receiving information about an alleged violation, Le Nouveau Chef will carefully evaluate the details and determine whether an informal inquiry or a formal investigation is necessary and permitted by applicable laws. We will take appropriate disciplinary measures, if required, and when appropriate, report the findings to the management team or refer the matter to relevant government authorities. It is the responsibility of every employee, officer, and director to fully cooperate with any inquiry or investigation. Failure to comply with this obligation or violations of the Code of Ethics may result in disciplinary action, including termination of employment, in accordance with the law. Le Nouveau Chef may also report violations to criminal and civil authorities when deemed necessary.