Code of Ethics

INTRODUCTION

Bluebella expects the highest ethical standards from employees and other personnel in carrying out its business. 

This code of ethics outlines our core ethical principles and gives our employees guidelines on how to conduct themselves as a representative of Bluebella. The values in this code of ethics are integral to the conduct of the business and upholding the integrity, responsibility and reputation of Bluebella.

All employees should act honestly, fairly and with transparency and should not act in a manner which could discredit themselves or Bluebella or put themselves in a position which may result in a conflict of interest.

Bluebella respects the rule of law and requires all employees to conduct its business in a way that ensures compliance with the rules that apply to Bluebella.

SUPPORTING POLICIES

A number of the principles in this Code are supported by more detailed policies to guide employees outlined in the staff handbook.

All employees are required to comply with Bluebella’s policies.

SCOPE

This Code applies to all Bluebella employees, temporary personnel, agents and contractors, regardless of their role or position in the company. 

We expect our suppliers to adhere to this Code or adopt similar ethical standards.

BREACH OF THIS CODE

Any breach of this Code may be considered to be a disciplinary matter and could result in disciplinary action up to and including dismissal. It is therefore very important that you read and understand this Code and seek clarification from your manager if there is anything that is unclear. 

KEY PRINCIPLES

Compliance with the law
Bluebella, its employees and others to whom this Code applies must observe both the spirit and letter of the laws and regulations that apply to the company. 

Human rights

Bluebella complies with employment law in every country in which we operate and respects global human rights principles. 

Bribery and corruption
Bluebella does not permit the bribery of any person involved in Bluebella business or any customer, supplier or business partner of Bluebella.

Fraud
Bluebella does not tolerate fraud.

Gifts and hospitality
No Bluebella employee or family member should accept or solicit or give (directly or indirectly) any improper gift.

Confidential information
Bluebella’s trade secrets and other sensitive commercial information must be kept confidential.

Conflicts of interest
Bluebella’s employees and other personnel must avoid situations where personal interests could conflict, or appear to conflict, with Bluebella’s interests.

Suppliers
Bluebella treats its suppliers fairly. We expect the same standards of them as we expect from our employees.

Customers

Bluebella communicates honestly with customers, charges fair prices for our products / services and protects customer data.

Competitors
Bluebella’s businesses and employees must comply with all competition and anti-trust rules in the countries in which they operate.

Shareholders and other stakeholders
Bluebella is committed to high standards of corporate governance, transparency and responsibility.

Health and safety
Bluebella will provide a safe and healthy working environment and does not compromise the health or safety of any individual.

Environment
Bluebella commits to understanding, minimising and mitigating any negative environmental impacts.  Bluebellaseeks to operate in an environmentally sustainable way and to promote biodiversity and habitat protection as key requirements for bee health. 

Employees
Bluebella values its employees and their diversity. We will develop our people and reward them fairly.

GUIDANCE

Many business decisions may involve ethical dilemmas. This Code cannot address every possible situation. It is very important that employees recognise when they are in a difficult ethical situation and that they seek assistance as appropriate.

The principles in this Code are intended to help guide you in the normal course of your work but they are no substitute for common sense and proper internal consultation.

If you find yourself in a situation where you are unsure of the right course of action to take, you may find it helpful to ask yourself the following questions:

• Is it legal?
• Is it ethical?
• Is it consistent with Bluebella company policies and this Code of Conduct?
• Can I explain it to my family and friends?
• Would I feel comfortable if it appeared in a newspaper?

If you still find that you do not know the right course of action to take, if you suspect someone else of acting contrary to this Code, or if you do not understand anything contained in this Code, please speak with your line manager, or one of the Directors.

Never hesitate to ask questions, raise concerns, or seek the guidance you need. Bluebella will not tolerate any retaliation or discrimination against anyone who has reported a concern in good faith.

 

COMPLIANCE WITH THE LAW

Bluebella, its employees and others to whom this Code applies must observe both the spirit and letter of the laws and regulations.

Guidance:

• The laws and regulations that apply to Bluebella are numerous and often complex.
• If you have any doubt whether your conduct – or the conduct of a colleague or your business unit – complies with the law, guidance should be sought from your line manager, or one of the Directors.
• You should immediately bring to your line manager’s attention any request that you think may be illegal or in violation of this Code. It is Bluebella’s policy that employees who raise such concerns in good faith shall not experience any form of retaliation.

HUMAN RIGHTS

As well as respecting employment law in the UK and in any other country in which we operate:

• Bluebella does not use child forced labour.
• Bluebella does not allow or condone physical punishment or abuse.
• Bluebella respects the freedom of individual employees to join, or refrain from joining, legally authorised associations or organisations.
• Bluebella fully complies with all applicable laws prohibiting human trafficking.

THEFT, FRAUD AND BRIBERY

Bluebella does not permit the bribery of any person involved in Bluebella’s business or any customer, supplieror business partner of Bluebella.

Guidance:
You must not, directly or indirectly, authorise, offer, promise, pay or give a:

• Bribe
  A bribe is a reward, advantage or benefit made in order to influence and/or secure an improper advantage. The amount of the bribe offered or paid is irrelevant and it need not actually be paid
• Kickback
  A kickback (e.g. the payment or receipt of a payment in return for securing a contract) is a form of bribe
• Facilitating payment
  A facilitating payment is a relatively small payment or gift to an official or government employee made to expedite routine services or administrative actions to which the company would already be entitled. Such payments should not be made in any circumstances

FRAUD

Bluebella does not tolerate fraud.

Guidance:
All staff have a responsibility to be alert to the signs of fraud and to report suspected fraud.

Bluebella defines fraud as any intentional act committed to secure an unfair or unlawful gain. This includes:

• Fraudulent financial reporting 
• Misappropriation of assets (examples include fraudulent expense claims, burglary and property damage, misuse of customer accounts or customer data)
• Theft
• Bribery or corruption
• Concealing a conflict of interest

Bluebella is committed to the prevention, detection and proper investigation of fraud.

Bluebella will respond to all incidents of fraud, seeking to recover loss, taking action against those who perpetrate fraud and reporting incidents to the authorities as appropriate. This may lead to prosecution or to disciplinary sanctions up to and including dismissal.

We expect our business partners to uphold similar principles for fraud risk management.

GIFTS AND HOSPITALITY

No Bluebella employee or family member should accept or solicit or give (directly or indirectly) any improper gift or hospitality.

Guidance:

• Accepting hospitality from, or providing entertainment to, third parties is acceptable if it is reasonably related to a clear business purpose and is modest
• You should be mindful that the donation or receipt of gifts, hospitality or favours may give rise to embarrassing situations and may be seen as improper inducement to give some concession in return to the donor
• The following principles should be observed:
• The giving or receiving of gifts or hospitality should remain appropriate to the business and should be modest. 
• Employees must obtain the consent of their manager before giving or accepting gifts or hospitality
• Employees must declare and keep a written record of all hospitality or gifts given or received, and must also submit all expense claims relating to hospitality and gifts to third parties in accordance with our expenses policy and record the reason for expenditure
• Gifts, favours or hospitality should never be solicited
• Gifts of money should never be offered or accepted
• When being offered a gift or entertainment, a good test as to whether it is acceptable is whether or not you would be able to, or would feel obliged to, reciprocate.

CONFIDENTIAL INFORMATION

Bluebella’s trade secrets and other sensitive commercial information must be kept confidential.

Guidance:

Commercial information

• Confidential information should not be used for personal gain. You should treat email with the same confidentiality as other forms of communication
• The obligation of confidentiality extends to periods after you cease to work for Bluebella and includes the disclosure of information to others.

Social media

• It is possible you may use social media for work purposes (e.g. LinkedIn) or for personal use outside of work (e.g. social networking sites such as Facebook and YouTube or discussion forums). Any social media use should be respectful to Bluebella, its employees, practices and associated companies. Usage should be relevant, protective of Bluebella’s reputation and should follow the letter and spirit of the law
• When using social media you must not disclose confidential information (including price sensitive information). 
• You should make it clear in social media postings, or in your personal profile, that you are speaking on your own behalf, and that your views do not represent those of your employer (unless you have been authorised to speak on Bluebella’s behalf). You should also be mindful of protecting yourself and your own privacy.
• All social media postings on Bluebella company’ channels must be authorised by the marketing department.

Data protection

• You must only collect and retain personal data for legitimate commercial purposes. You must respect the privacy of personal data relating to employees, customers and suppliers in compliance with current GDPR legislation.
• Bluebella must ensure that its data and information systems comply with current GDPR data protection laws.

CONFLICTS OF INTEREST

Bluebella employees and other personnel must avoid situations where personal interests could conflict, or appear to conflict, with Bluebella’s interests.

Guidance:

• Conflicts of interest arise where a person’s position or responsibilities within their business unit present an opportunity for personal gain above the normal rewards of employment
• They can also arise where personal interests are inconsistent with those of their employer or create conflicting loyalties in respect of transactions between their employer and a third party
• You must not be involved with an activity for personal gain which is in conflict with Bluebellacompany’ business interests. Any of your personal interests or the interests of a member of your immediate family in relation to Bluebella’s  business must be disclosed to your manager immediately
• You must not work simultaneously for any of Bluebella competitors, customers or suppliers. If you are unsure as to whether a conflict of interest exists, please seek advice from a Director.

Accepting gifts, hospitality or entertainment may in some circumstances lead to an impairment of a person’s judgement or independence or be open to misinterpretation.

SUPPLIERS

Bluebella treats its suppliers fairly. We expect the same standards of them as we expect from our employees.

Guidance:   The integrity of our dealings with suppliers is critical to the long-term success of Bluebella.

We will pay our suppliers, contractors and agents in accordance with agreed terms but in all cases will pay in a timely manner.

We will conduct a procurement questionnaire to ensure our major suppliers share similar codes of ethics with regard to employee work conditions, fair and equal pay and commitments to more sustainable environmental work practices.

CUSTOMERS

Bluebella treats customers with fairness and respect.  We are honest in our communications, fair and transparent with our pricing and take great care with customer data.

Guidance:  Our customers’ opinion of us is of the utmost importance.

We will advertise and market our products / services honestly, not over-inflating claims and using clear language and verifiable facts and figures.  

We price our products and services fairly and consistently so that our customers know they are getting good value for money.

Whenever we collect, process or store customer data we ensure we stick to the following principles:

Protected: We keep our customers’ data secure and make sure it doesn’t fall into the wrong hands. 

Appropriate: We only use customer data in ways that customers consider appropriate and responsible. 

Open: We are clear with customers about how we use personal data. 

Choice: We provide customers with choices over how we use their data.

COMPETITORS

Bluebella and its employees must comply with all competition and anti-trust rules in the countries in which they operate.

Guidance:

• Bluebella welcomes and encourages free and open competition in the marketplace
• Bluebella will compete vigorously but fairly and legally

 

SHAREHOLDERS AND STAKEHOLDERS

Bluebella is committed to high standards of corporate governance, transparency and responsibility.

Guidance:
Bluebella engages actively and constructively with all who are interested in the success of its business, and welcome regular and open dialogue. Our Articles of Association enshrine our commitment to having a positive social and environmental impact, as well achieving financial success, and allow us to consider all stakeholders and not just shareholders when making business decisions. 

HEALTH AND SAFETY

Bluebella will provide a safe and healthy working environment and does not compromise the health or safety of any individual.

Guidance:

• Bluebella’s aim is committed to continual improvement in health and safety performance throughout our operations
• Bluebella has high standards of care for the safety of our people, products and operations and for the environment in which our people work
• Bluebella will provide the necessary training and resources to allow for the safe performance of day-to-day activities
• Every Bluebella employee has a legal duty to look after their own health, safety and welfare and that of those around them

ENVIRONMENT

Sustainability is a critical part of Bluebella’s ethos.   We strive to understand, manage and mitigate any negative environmental impacts and to amplify the positive benefits that we have. 

Guidance:

Bluebella company will:

• Prevent, or otherwise minimise, any harmful effects of its operations on the natural environment
• Continually look for ways to reduce the environmental impact of our operations and products
• Publish our annual sustainability report outlining our commitment for management and reduction of energy use, water use, packaging and waste. 
• Encourage all employees to conduct their work with regard to the highest environmental practices and minimise the waste of natural resources.
• Take active steps to promote biodiversity and raise awareness of bee health.

UK MODERN SLAVERY ACT DISCLOSURE STATEMENT 2018 

This Disclosure Statement (“Statement”) has been published pursuant to section 54(1) of the UK Modern Slavery Act 2015 (“the Act”) and is made on behalf of Bluebella company and all subsidiary companies which are in scope for the purposes of the Act.

This Statement sets out the steps taken by Bluebella company during the fiscal year ending 2024  In accordance with the Act, this Statement is published on www.bluebella.com

Bluebella is committed to high standards of ethical conduct and compliance with applicable laws and we fully expect all of our suppliers to conduct themselves in a similarly compliant manner.

Bluebella’s commitment to ethical conduct and compliance with laws includes compliance with laws prohibiting human trafficking and slavery. The UK Modern Slavery Act 2015 defines “modern slavery” as including the offences of “slavery, servitude and forced or compulsory labour” as well as “human trafficking”, all of which are directly opposed to the values and ethics of our company.