Purpose
This Business Ethics Policy sets forth the ethical standards and expectations for all employees, contractors, suppliers, and partners of Legacy Bakehouse. Our commitment is to conduct business with integrity, transparency, and accountability, in compliance with all applicable laws and the highest ethical standards, including those outlined in the Sedex Members Ethical Trade Audit (SMETA) guidelines.
Scope
This policy applies to all employees, contractors, suppliers, and business partners of Legacy Bakehouse at all locations and facilities.
Policy Statement
Legacy Bakehouse strictly prohibits all forms of bribery, corruption, and unethical business practices. We are committed to operating fairly, honestly, and in accordance with all relevant anti-bribery and anti-corruption laws, including the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, and the OECD Guidelines for Multinational Enterprises.
Prohibited Practices
The following practices are strictly forbidden:
• Bribery and Corruption: Offering, giving, soliciting, or accepting any form of bribe or improper advantage, whether directly or indirectly, to or from any individual or organization, including government officials, customers, suppliers, or third parties.
• Fraud: Engaging in any act of deception intended to result in financial or personal gain, including falsification of records, misrepresentation of facts, or manipulation of data.
• Tax Evasion: Participating in or facilitating any activity intended to unlawfully evade taxes or misrepresent financial information to authorities.
• Political Involvement: Using company resources for political contributions, or engaging in political activities on behalf of the company without proper authorization and transparency.
• Anticompetitive Practices: Participating in collusion, price-fixing, bid-rigging, or any other conduct that restricts fair competition in violation of applicable antitrust laws.
• Extortion: Using threats, coercion, or intimidation to obtain business advantages or personal benefits.
• Money Laundering: Engaging in or facilitating any transaction that seeks to conceal the origins of illegally obtained funds.
• Improper Influence: Providing excessive gifts, hospitality, or favors that could influence or appear to influence business decisions.
• Conflicts of Interest: Failing to disclose any situation where personal interests could conflict with the interests of the company.
Reporting and Compliance
• All employees and business partners are required to report any suspected or actual violations of this policy through the company’s confidential reporting system.
• Reports will be investigated promptly and thoroughly. Retaliation against individuals who report in good faith is strictly prohibited.
• The company will take appropriate disciplinary action, up to and including termination of employment or contracts, against individuals found to have violated this policy.
Training and Communication
• This policy will be communicated to all employees, contractors, and relevant third parties.
• Regular training will be provided to ensure awareness and understanding of ethical standards and reporting mechanisms.
• The policy will be reviewed and updated periodically to ensure ongoing compliance with legal and ethical standards.
Continuous Improvement and Review
Legacy Bakehouse is committed to continuous improvement in ethical business conduct and will regularly assess and enhance its compliance programs, controls, and procedures in line with SMETA best practices.
Responsibility
The Board of Directors and senior management are responsible for overseeing the implementation and enforcement of this policy. All employees and business partners share responsibility for upholding these standards in all business dealings.
This Business Ethics Policy is designed to meet or exceed the requirements of the Sedex Members Ethical Trade Audit (SMETA) and reflects our unwavering commitment to ethical, legal, and responsible business conduct throughout our operations and supply chain.