Code of Ethics
Applicability
This Policy applies to: all brands under Wheat A/S, Wheat Kids Clothing UK Ltd, Wheat Fashion Ltd, Wheat Norge AS
Each group entity is responsible for implementing this Policy in accordance with applicable national legislation and regulatory requirements.
1. Purpose
This Code of Ethics sets out the principles and standards of conduct that guide how Wheat A/S operates, makes decisions, and behaves as a company. It reflects our commitment to acting responsibly, transparently, and with integrity in all aspects of our business.
The Code of Ethics supports a respectful workplace, responsible governance, and compliance with applicable laws and regulations. It applies to all employees, management, and board members of Wheat A/S, as well as to relevant business partners where applicable.
2. Values and ethical principles
Wheat A/S is committed to:
- Acting with integrity, honesty, and fairness
- Respecting human rights and individual dignity
- Providing a safe, inclusive, and respectful workplace
- Complying with applicable laws, regulations, and standards
- Taking responsibility for the social and environmental impacts of our business
- Encouraging openness, accountability, and continuous improvement
3. Compliance with laws and regulations
Wheat A/S complies with all applicable local, national, and international laws and regulations in the countries where we operate. Employees and management are expected to understand and follow relevant legal requirements related to their roles, including labour law, health and safety, data protection, competition law, and anti-corruption regulations.
4. Respectful workplace and equal treatment
We are committed to providing a workplace based on respect, equality, and inclusion.
Wheat A/S does not tolerate discrimination, harassment, or abusive behaviour based on gender, age, ethnicity, religion, disability, sexual orientation, gender identity, or any other protected characteristic. All employees are expected to treat colleagues, customers, suppliers, and partners with respect and professionalism.
5. Health, safety, and wellbeing
The health, safety, and wellbeing of employees is a priority at Wheat A/S.
We work to provide safe and healthy working conditions and encourage a culture where risks are identified, reported, and addressed. Employees are expected to follow health and safety procedures and to contribute to a safe working environment.
6. Anti-corruption, gifts, and business integrity
Wheat A/S has a zero-tolerance approach to bribery, corruption, fraud, and unethical business practices. Employees, management, and business partners must not offer, give, solicit, or accept bribes, kickbacks, facilitation payments, or any improper advantages of any kind.
7. Gifts and hospitality
Gifts and hospitality must be modest, reasonable, infrequent, and appropriate to the business context. Cash or cash-equivalent gifts are never permitted. Any gifts or hospitality that could create a conflict of interest or the appearance of undue influence must be declined or disclosed to management.
All business transactions must be accurately recorded in the company's books and records.
8. Conflicts of interest
Employees and management must avoid situations where personal interests could conflict with the interests of Wheat A/S.
Any actual or potential conflicts of interest must be disclosed promptly to management so they can be assessed and managed appropriately.
9. Data protection and confidentiality
Wheat A/S respects privacy and handles personal and confidential information responsibly.
Employees must comply with applicable data protection laws, including GDPR, and ensure that personal data, confidential business information, and intellectual property are protected from unauthorised access or misuse.
10. Whistleblowing and grievance mechanisms
Wheat A/S encourages employees and relevant stakeholders to raise concerns about unethical behaviour, misconduct, or violations of this Code of Ethics.
Reports can be made without fear of retaliation. Retaliation against anyone who raises a concern in good faith is strictly prohibited.
Reporting channels, confidentiality safeguards, investigation procedures, and timelines are defined in Wheat A/S's Whistleblower Policy, which applies alongside this Code of Ethics.
11. Responsible business conduct and supply chain
We expect our business partners and suppliers to act responsibly and ethically.
Supplier expectations related to labour rights, human rights, environmental protection, and business integrity are defined in Wheat A/S's Supplier Code of Conduct and related policies.
12. Environment and climate
Wheat A/S's environmental and climate commitments are defined in the Environmental and Climate Policy and are implemented through the Environmental Management System (EMS). All employees are expected to act in accordance with these commitments within their areas of responsibility.
13. Responsibilities and enforcement
Management is responsible for ensuring that this Code of Ethics is implemented, communicated, and enforced.
Violations of this Code of Ethics may result in disciplinary action in accordance with applicable law and internal procedures.
14. Review and updates
This Code of Ethics is reviewed regularly and updated as needed to reflect changes in legislation, business activities, and best practices.
15. Related documents
- Wheat A/S's Environmental and Climate Policy
- Wheat A/S's Environmental Management System (EMS)
- Wheat A/S's Policy on Responsible Business Conduct
- Wheat A/S's Supplier Code of Conduct
- Wheat A/S's Human Rights Policy