Our Code of ethics

WHY HAVE A CODE OF ETHICS?

FOREWORD BY METTE

Dear all,

Too Good To Go has a strong mission: to inspire and empower everyone to fight food waste together. This is supported by our values which are integrated into the way we work everyday at Too Good To Go.

Our values are:

• We Win Together
• We Raise The Bar
• We Keep It Simple
• We Build a Legacy
• We Care

Our culture at Too Good To Go is dependent on us putting these values into practice every day. We are proud of our culture, and we want to preserve it as we continue to grow as a business, to make Too Good To Go a great place to work for everyone.

We strive to always do what is right for our partners, customers and the communities we work in. The Code of Ethics ensures that our partners and customers know what ‘right’ means for us and how to comply with it.

All Too Good To Go employees are also expected to comply with the Code of Ethics. We will have annual training on it to help you understand it in full and how it is important to you.

Too Good To Go is a good business and a business that does good. We are proud of this, and we all have a responsibility to continue to promote this through our work, with the help of this Code.

Mette Lykke, CEO

INTRODUCTION

Too Good To Go's mission and core values

At Too Good To Go, we have a clear mission which extends beyond our bottom line. Our mission is to inspire and empower everyone to take action against food waste together to achieve our vision of a planet with no food waste.

We believe that the way we do things is key to achieving our mission. Our actions must always comply with applicable laws and regulations. Beyond that, we expect everyone involved with Too Good To Go to make decisions that reflect strong ethics and fit with our values:

• We win together
• We raise the bar
• We keep it simple
• We build a legacy
• We care

The purpose of this code of ethics

Our simple business model creates impact at scale, but we are committed to doing good far beyond our mission, as a B Corp. This Code of Ethics reflects our commitment to conduct our business in accordance with the highest ethical standards.

We put forth this code of ethics not because we anticipate bad behaviour, but because we believe in the already exceptional level of respect among the team. We believe that articulating our values and accountabilities to one another reinforces that respect and provides us with clear avenues to correct our culture should it ever stray. We commit to enforce and evolve this code as our team grows.

This Code of Ethics shares our core values with our stakeholders and partners and provides a framework of fundamental principles to guide behaviour and help everyone do the right thing. Everyone covered by the Code of Ethics is expected to read, understand and follow it, and non-compliance can have serious consequences.

Who this code of ethics applies to

All of Too Good To Go’s employees and Board Members are expected to read, understand and follow this Code of Ethics. All permanent and temporary employees should review the Code of Ethics during their onboarding and at least annually.

Certain topics of the present Code of Ethics might be reflected or be subject to local internal policies or internal rules applicable to our employees. If this is the case, the content of such local internal policy or internal rules shall prevail. Therefore, regarding topics treated by both the Code of Ethics and a local internal policy or internal rules, only the local rules shall apply to Too Good To Go employees.

Any provision of the present Code of Ethics that is prohibited or unenforceable under local law shall, as to that jurisdiction, be replaced with the relevant minimum standard of that legislation if there is any, without affecting the validity of the remainder of the Code of Ethics. If the local law does not provide for a minimum standard, the provision shall be ineffective to the extent of the prohibition or unenforceability without affecting the remaining provisions of the Code of Ethics or affecting the validity or enforceability of such provision in any other jurisdiction.

We also expect that anyone providing services for Too Good To Go or partnering with Too Good To Go shall also read, understand and follow this Code of Ethics. This would include in particular consultants, agents, freelancers and any other person or third party working with us.

Too Good To Go’s Code of Ethics openly shares our values with our stakeholders and partners, and provides a framework to help everyone guide their own behaviour.

APPLYING OUR CORE VALUES

THE WAY WE BEHAVE

We have five key values at Too Good To Go, supporting the way we behave:

• We Win Together
• We Raise the Bar
• We Keep It Simple
• We Build a Legacy
• We Care

All Too Good To Go employees as well as the partners and third parties working with Too Good To Go must:

• Comply with all applicable laws and regulations as well as with the principles set forth by the present Code of Ethics which apply to them;
• Comply with the guidance provided by Too Good To Go relating to conduct.

Further, our employees represent Too Good To Go in their professional capacity both internally and beyond the workplace. We expect them to act in a way that reflects our values and builds trust in our company.

Therefore, Too Good To Go employees have to:

• Comply with this Code of Ethics, knowing that gross failure to do so may result in disciplinary action;
• Comply with all Too Good To Go’s policies, knowing that failure to do so may result in disciplinary action;
• Not be under the influence of alcohol during work hours, with the exception of work celebrations and team events. Never to be under the influence of drugs during work hours, celebrations and/or team events.

Further, our employees are strongly invited to promptly report dishonest, unethical or illegal activities through Too Good To Go’s global and local Complaints & Grievance process or Whistleblowing process as applicable.

WITH RESPECT TO PARTNERS AND THIRD PARTIES, APPLICATION TO OUR CORE VALUES IMPLIES RESPECT OF THE FOLLOWING PRINCIPLES:

• We are committed to empowering our partners and third parties we are working with to raise the bar in the fight against food waste and work with them to ensure all options have been considered for minimising food waste from their businesses.
• Too Good To Go expects our partners and third parties working with us to align with our ethics and values.
• Too Good To Go expects our partners to treat their workers lawfully, ethically and respectfully.
• We expect anyone doing business with us to encourage and facilitate practices that promote equality and avoid discrimination and harassment.
• We do not tolerate aggressive behaviour, coercive language, abuse or threats against Too Good To Go employees, users and store personnel.
• Third parties, partners and suppliers must fully comply with all relevant anti-corruption laws of the countries in which we do business. For example, this includes the U.S. Foreign Corrupt Practices Act (FCPA) and the United Kingdom Bribery Act of 2010, which apply globally.
• Too Good To Go will not tolerate modern slavery or child labour in any form. Everyone who works with us should fully comply with all relevant modern slavery laws of the countries in which we do business.

FOR TOO GOOD TO GO EMPLOYEES, OUR VALUES PROVIDE FOR THE FOLLOWING RIGHTS AND OBLIGATIONS:

WE WIN TOGETHER

• We can only achieve our mission if we win together, guided by our common vision, not our egos. We ensure we have involved the relevant people in our work and we give and ask for feedback on a regular basis.
• We value having a diverse group of people at Too Good To Go and aim to be fully inclusive. We are committed to maintaining a safe, inclusive, equal, harassment-free and discrimination-free work environment for all Too Good To Go employees. You can read more about what we are doing to be diverse, equitable and inclusive here.
• Too Good To Go is an equal opportunity employer and prohibits discrimination or harassment against our employees or applicants for employment on the basis of an individual’s race, colour, religion, creed, sex (including pregnancy and maternity or gender reassignment), national origin, age, disability, marital status, veteran status or any other status protected by applicable law. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and is free from discriminatory practices, including without limitation harassment. Violations of this policy will not be tolerated and will have consequences. Please see the Non-Discrimination and Anti-Harassment policy for full details.
• We do not tolerate aggressive behaviour, coercive language, abuse or threats from or against Too Good To Go employees, users and store personnel.
• To avoid any actual or potential misuses of authority and to ensure an equitable environment for all, romantic or sexual relationships between a manager/supervisor and an employee whom they supervise is prohibited. For example, a romantic relationship between a Head of Key Accounts and an Independent Sales Specialist is allowed, but between a Head of Independent Sales and an Independent Sales Specialist is not. If you think this may happen, you should make People & Culture aware of the situation.

WE RAISE THE BAR

• We have high expectations for what we do and we want to deliver excellence. We do this in the correct way:
• We are committed to empowering our partners to raise the bar in the fight against food waste and work with them to ensure all options have been considered for minimising food waste from their businesses.
• Too Good To Go has a zero tolerance approach to bribery and corruption. Too Good To Go prohibits bribes in any form, including kickback and gifts, and adheres to Anti-Bribery laws in the countries where we do business. Our zero-tolerance approach does not prohibit normal and appropriate hospitality to or from customers or business partners provided that it complies with local law, is not made with the intention of influencing a third party to retain or obtain business, and is appropriate in the circumstances (e.g. a small Christmas gift).
• Too Good To Go will not make financial and in-kind contributions to political parties, politicians and lobby groups. Too Good To Go will only make financial and in-kind contributions to charitable organisations and advocacy groups in accordance with applicable law and public disclosure requirements.
• Our employees and Board members must fully comply with all relevant anti-corruption laws of the countries in which we do business. For example, this includes the U.S. Foreign Corrupt Practices Act (FCPA) and the United Kingdom Bribery Act of 2010, which apply globally.
• Too Good To Go employees are committed to complying with antitrust and competition laws in order to promote free and fair competition. We strictly prohibit any business activities which may restrain trade, abuse intellectual property rights or that uses market power unfairly.
• Too Good To Go shall comply with any applicable U.S and international trade laws that control where we can make our products and services available.
• Where a Too Good To Go employee recognises that a conflict of interest arises between their personal activities, interests or relationships and the work they are doing at Too Good To Go which would affect their professional duties, the employee shall raise this situation as soon as possible to their manager or the appropriate contact at Too Good To Go.

WE KEEP IT SIMPLE

• We call it like we see it and direct issues and feedback directly with those involved. We state our opinions in an open, honest, empathetic and professional way. That way, we stop things from escalating and find solutions together.
• We emphatically listen first to others in any circumstances before we get our point across. We always start with good intentions, trust and empathy.
• We use a professional tone of voice in speech and in writing.

WE BUILD A LEGACY

• We require our employees to promote and maintain ethical behaviour in the work environment. We expect our employees to act in a fair, responsible and professional manner, to conduct their duties honestly and with integrity, and to treat others with respect. We are committed to reflecting this in all of Too Good To Go’s working culture and processes, anchored by our values.
• Too Good To Go understands the link between food waste and food insecurity in many of the countries we work in. We will support action to fight food insecurity alongside our mission of fighting food waste to build a legacy for people suffering from food insecurity. We are committed to providing 1% of profit from a positive bottom line, along with time through our volunteering programme, to good causes tackling food insecurity.
• As a social impact business, we aim to enhance the communities we work in through our App and community work.
• Beyond the positive environmental impact we are making through our mission, we are committed to minimising our impact on the environment as a business.
• Building a legacy also means that we protect Too Good To Go for the future. In practice this means we ensure that any business is conducted in a way that protects confidentiality around any information that Too Good To Go has not disclosed or made generally available to the public.
• We respect all copyright, fair use and intellectual property laws and we ensure that we protect Too Good To Go’s assets - like our name and branding. We also respect the intellectual property rights of others that work with us and we avoid any inappropriate use of others’ assets.

WE CARE

• At Too Good To Go, we look out for each other and set each other up for success. We always treat each other with respect and communicate in a constructive way. This means reaching out if you see someone who needs help, and telling your colleagues when they are doing a good job.
• At Too Good To Go, we take the time to care, to listen, to understand and to be around - because we are all human after all. If any employee witnesses something that does not align with our values or these standards, always be caring towards your colleagues. Even if an incident seems minor, reach out to the person impacted by it to check in.
• We are committed to adhering to human rights commitments, as set out by the UN Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and ILO Principles.
• We operate in line with environmental, health and safety laws. We are committed to providing a safe and healthy environment as a workplace and prohibit any behaviour that poses a risk to the safety, health or security of others working within that environment.

BREACHES AND AMENDMENTS

REPORTING BREACHES OF TOO GOOD TO GO's CODE OF ETHICS

• Too Good To Go employees should report breaches via Too Good To Go’s Complaints & Grievance Process which can be found in local Employee Handbooks.
• Pursuant to the global and local Complaints and Grievance Policy applicable from time to time, any user and any information provided in this context will be kept confidential.
• Partners and third parties are invited to inform their contact person at Too Good To Go regarding any and all breaches observed with respect to this Code of Ethics.
• All material breaches will be investigated promptly and appropriate action will be taken. Cases of material breaches will be reported to Too Good To Go’s Board of Directors.
• At Too Good To Go, we understand that people make mistakes. We own our mistakes and learn from them. However, Too Good To Go employees who are found repeatedly or severely violating this Code of Ethics can and will be addressed by their manager. This can lead to disciplinary actions, including termination.

AMENDMENTS TO TOO GOOD TO GO'S CODE OF ETHICS

We review and update this Code of Ethics and our policies on an ongoing basis. We reserve the right to amend this Code of Ethics at any time, for any reason, subject to applicable law.

Our employees will be updated when the Code of Ethics is amended and should familiarise themselves with any changes when these changes are communicated. Partners and third parties will be provided with the updated Code of Ethics applicable from time to time.

CONTACT DETAILS

Too Good To Go community can raise any questions about our Code of Ethics with their appropriate contact within the People & Culture team.