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528 - Sustainable Procurement Policy
1. Purpose
528 is committed to conducting its business responsibly across its entire value chain.
This Sustainable Procurement Policy defines how environmental, social, and ethical considerations are
integrated into purchasing decisions, alongside quality, reliability, and cost.
As a producer and distributor of premium ice products, 528 recognises that a significant part of its
environmental footprint and social impact lies upstream, in areas such as:
• Energy supply
• Packaging materials
• Refrigeration and technical equipment
• Logistics and distribution
• Key service providers
This policy supports compliance with sustainability expectations and contributes to long-term business
resilience and trust.
2. Scope of Application
This policy applies to all procurement activities at 528, including but not limited to:
• Raw materials and consumables
• Packaging (paper, plastic, insulation materials)
• Refrigeration systems and technical equipment
• Energy and utilities
• Logistics and transport services
• Maintenance, cleaning, and waste management services
• External contractors, agents, and distributors
The policy applies to both new suppliers and existing suppliers.
3. Guiding Principles
528’s sustainable procurement approach is based on the following principles:
• Compliance – suppliers must comply with applicable laws and regulations
• Risk-based approach – focus on suppliers and categories with higher ESG risk
• Proportionality – requirements aligned with supplier size and risk level
• Continuous improvement – encouraging progress rather than exclusion
• Transparency and traceability – clear expectations and documented processes
4. Environmental Responsibility in Procurement
528 integrates environmental criteria into procurement decisions wherever relevant.
We give preference to suppliers who demonstrate:
• Efficient use of energy, water, and raw materials
• Use of renewable or low-carbon energy
• Reduction of greenhouse gas emissions
• Responsible waste management and circular practices
Key focus areas for 528 include:
• Packaging:
o Preference for recyclable, mono-material plastics
o FSC-certified paper and responsibly sourced materials
o Reduction of packaging weight per kilogram of ice
• Refrigeration & Equipment:
o Preference for energy-efficient systems
o Transition toward natural refrigerants (e.g. R-290, COâ‚‚)
o Compliance with EU F-Gas regulations
• Logistics:
o Preference for efficient routing, modern fleets, and lower-emission transport solutions
o Consideration of local or regional suppliers where feasible
5. Social and Human Rights Expectations
528 expects its suppliers and business partners to respect fundamental human and labour rights.
Suppliers must:
• Prohibit child labour, forced labour, and human trafficking
• Respect freedom of association and fair working conditions
• Provide safe and healthy working environments
• Treat workers with dignity and without discrimination
These expectations are aligned with ILO core conventions and international human rights standards.
6. Ethics and Business Integrity
Ethical conduct is a prerequisite for doing business with 528.
Suppliers and partners are expected to:
• Act with integrity and transparency
• Avoid bribery, corruption, and conflicts of interest
• Comply with applicable competition and data protection laws
• Respect confidentiality and intellectual property
528 does not tolerate unethical business practices within its supply chain.
7. Supplier Code of Conduct
528 has established a Supplier Code of Conduct that formalises environmental, social, and ethical
expectations.
• Strategic and higher-risk suppliers are requested to acknowledge or sign the Supplier Code of
Conduct
• The Code forms part of contractual documentation for new suppliers where relevant
• Non-compliance may trigger corrective actions or, in severe cases, termination of the business
relationship
8. Supplier Assessment and Risk Management
528 applies a risk-based supplier assessment approach:
• Suppliers are prioritised based on spend, criticality, and ESG risk
• Key suppliers may be requested to provide sustainability information (e.g. policies, certifications,
EcoVadis scores)
• Results are used to identify risks and improvement opportunities
This approach ensures focus on the most material risks without creating unnecessary administrative
burden.
9. Collaboration and Continuous Improvement
528 prefers collaboration over exclusion.
Where gaps are identified, 528 may:
• Engage with suppliers to clarify expectations
• Encourage gradual improvements and transparency
• Share best practices relevant to packaging, logistics, or energy efficiency
Our objective is to build long-term, responsible partnerships aligned with our premium brand values.
10. Internal Responsibilities
• Procurement decisions must consider sustainability criteria where relevant
• Management oversees the implementation of this policy
• Sustainability performance is reviewed periodically using defined KPIs
Employees involved in procurement are expected to understand and apply this policy in their daily
activities.
11. Monitoring and Reporting
Implementation of this policy is monitored through:
• Supplier assessments and engagement
• Sustainable procurement KPIs (e.g. % suppliers assessed, % spend under Supplier Code of Conduct)
• Periodic management review
Results are reported as part of 528’s sustainability reporting.
12. Review and Continuous Improvement
This Sustainable Procurement Policy is reviewed at least every two years or when:
• Business activities change significantly
• Regulatory requirements evolve
• Material sustainability risks are identified
13. Conclusion
Through this Sustainable Procurement Policy, 528 integrates environmental responsibility, social
standards, and ethical conduct into its purchasing decisions.
By working with suppliers and partners who share our values, we strengthen our supply chain, reduce
ESG risks, and support responsible growth in the premium ice market.