At Action, we believe that it is not just about what is on the shelves. Our behaviour – as individuals and as a company – also matters. If people do not trust us, they will not shop at Action. That is why we have a reliable system of governance to ensure we take the right decisions and uphold the highest standards of behaviour and ethics throughout our company.

Alongside our code of conduct, we have extensive internal policies and controls – these cover everything from human rights and pricing to anti-bribery, product safety and tax, ensuring that we have clear rules and always act in a responsible way. Many of our policies are based on internationally agreed standards, such as the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. 

Our code of conduct sets out what we expect from ourselves – in the way we behave and treat others. Based on our six values, the code applies to all Action employees, and covers areas such as customer service, health & safety and product quality. It also explains the importance of complying with all laws and regulations, and how we should behave at all times with fairness and respect. 

In case of a violation of values or standards, people should have a means to report these in confidence. For our Action colleagues, we have our Speak Up platform, available 24/7 in all relevant languages. In 2025, we plan to make this platform available to outside parties, including customers and suppliers. In factories, workers with access to amfori’s Speak for Change programme can report incidents via this programme. All reports are investigated, and we have a no-retaliation rule for all reports made in good faith.

Critical escalation
(due to be introduced in 2025) 

Escalating critical cases, covering alleged bribery and human rights abuses

Tax

Our approach to tax matters, including the principles that we base decisions on sound business criteria rather than potential tax advantages

Human rights and environmental due diligence

Identifying potential human rights and environmental risks across our activities

International standards

UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises and ILO Conventions

Health and safety

Principles for integrating health and safety into everyday operations

Privacy statement

How Action collects, processes and protects personal and customer data and ensures compliance with data privacy regulation

Pricing policy

Pricing Action products and maintaining the lowest prices for our customers

Product safety

Process and commitment to maintaining product quality

International standards

EU General Product Safety Directive^*

Responsible sourcing policies

Standards for suppliers when sourcing raw materials, including cocoa, cotton, palm oil, timber, chemicals, plastics and packaging

International standards

UN Guiding Principles on Business and Human Rights, ILO Conventions, International Fairtrade cocoa standards, Better Cotton, Roundtable on Sustainable Palm Oil and EU Timber Regulation

Ethical sourcing

Standards for our suppliers in areas such as health & safety, fair pay, working hours, and discrimination

International standards

ILO Conventions, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, amfori BSCI Code of Conduct principles

Code of conduct

Standards for behaviour in the workplace

Child labour

Zero tolerance approach to child labour and rules on minimum working age

International standards

UN Convention on the Rights of the Child, ILO Conventions relating to the use of child labour

*The EU General Product Safety Directive is due to be replaced in 2025 by the EU General Product Safety Regulation. 

Anti-bribery and corruption

Zero-tolerance commitment to any form of bribery or corruption

Diversity, equity & inclusion

Action’s commitment to a diverse and inclusive work environment

International standards

ILO Conventions, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Entreprises

We regularly engage with our stakeholders – groups of individuals or organisations close to our business that may be affected by the decisions we take, including our customers, suppliers and those who work with us. Most engagement takes place in the normal course of business through works’ council meetings, customers surveys and supplier assessments, for example. We are now also developing a more strategic plan for engagement, which we expect to be in place from 2025. This will help us better understand stakeholder views and interests, and identify potential risks. It will also serve as a platform to share knowledge and expertise.

Company’s shareholders and creditors

How we engage

• Annual Capital Markets Seminar, face-to-face meetings and industry conferences

Main topics of discussion in 2024

• Financial performance, dividends and implementation of Action’s strategy

• Continued growth of stores and DCs

• Regulatory change

‘Planet and community’, including governments, policymakers, NGOs and local communities

How we engage

• Meetings with both local and national governments and policymakers

• Partnerships with outside organisations, such as Fairtrade International, Better Cotton and the Centre for Child Rights and Business

Main topics of discussion in 2024

• Ethical business conduct

• Environmental impact of Action’s products

• Tax payments, job creation and contribution to local communities

• Potential risks to human or labour rights in Action’s supply chain

Suppliers of products, goods and services to Action – and the people who work for them

How we engage

• Regular contact through our buying teams

• Risk assessments, audits and spot checks for suppliers in at-risk areas

• Quarterly Busines Reviews for suppliers of goods and services

Main topics of discussion in 2024

• Product quality and pricing

• Possible supply chain disruptions and stock management

• Climate action, product circularity and protection of workers’ rights

Customers visiting our stores, or online

How we engage

• Feedback in stores or via our app and website

• Regular market studies, product reviews and consumer surveys

• Price benchmarking and engagement with national consumer authorities in our main markets

Main topics of discussion in 2024

• Pricing, product assortment and promotions

• Quality and availability of products

• Store environment and accessibility

Colleagues working at our stores, offices and distribution centres

How we engage

• Regular consultations with works’ councils, trade unions and other employee representatives

• Voice of Action and Pulse surveys, as well as team and townhall meetings, performance reviews and development programmes

Main topics of discussion in 2024

• Pay, benefits and working conditions

• Workplace health & safety

• Training, skills development and career advancement

The CEO and CFO handle the company’s daily management, ensuring its performance and operations align with Action’s objectives and strategy. They are supported by senior leaders from different areas of the business, known as the Executive Committee, which is set up to foster collaboration, consultation, and information sharing across functions.

Action has a one-tier board, meaning that both management and supervision are combined in a single structure. This governance setup ensures that company decisions consider the interests of all stakeholders.

Our Board of Directors (the Board) consists of two executive directors – our Chief Executive Officer (CEO) and Chief Financial Officer (CFO) – along with eight non-executive directors. The Board meets on average 5 to 7 times per year and oversees Action’s overall strategy, management, and performance.

We have a simple, straightforward operating structure. Our country managers focus on store performance and operations. They are supported by central functions such as Commerce, Supply Chain and Store Operations, as well as departments like HR, Finance and Quality & Sustainability, based at our international headquarters at Zwaagdijk-Oost in the Netherlands.

Risk is an integral part of doing business. Generally, we take a cautious approach to risk, but we are also ready to accept some risks to continue growing our company. Within Action, we have a well-established system of risk management, allowing us to identify risks as they emerge, and to take action if these are risks we do not want to accept. We also address external risks, such as climate change or the potential impact of issues relating to human rights and the environment. At the same time, we monitor compliance with regard to health and safety standards in our supply chain. New EU rules* are making this due diligence mandatory for companies such as ours.

*Under the EU’s Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).

We are committed to making a positive contribution to the communities where we work. One way of doing this is to make sure we pay our taxes in full and on time. In 2024, Action paid €3 billion in tax, an increase from €2.2 billion the previous year.