Carlsberg Group supplier and licensee code of product

The Carlsberg Group is dedicated to contributing positively to society and the environment through ethical business practices and sustainability. This Code sets minimum standards for suppliers, service providers and licensees to reduce supply chain risks and enhance transparency. In partnership with our value chain, we aim to identify, prevent, and mitigate negative impacts on people and the planet, following international standards and national laws while advancing human rights and environmental protection. 

Our commitment

Carlsberg upholds the United Nations Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Responsible Business Conduct. As a UN Global Compact signatory, we are committed to its four pillars: human rights, labour, environment, and anti-corruption. The Code aligns with international standards, such as the UN Global Compact’s Ten Principles, the Base Code of the Ethical Trading Initiative (ETI), the principles of the International Labour Or-ganization (ILO) and ISO 14001. Furthermore, the Code supports the UN Sustainable Development Goals (SDGs). 

Aligned with our sustainability programme, this Code reflects Carlsberg’s commitment to tackling key ESG topics and addressing global challenges, such as inequality, climate change and water scarcity. We collaborate with our suppliers to drive responsible business practices and positively impact society.

Scope

This Code applies to all suppliers, service providers and labour providers as well as their suppliers up to the material source, forming a mandatory part of any agreement with Carlsberg Group members. This includes upstream suppliers and service providers (such as employment and marketing agencies) and downstream partners (such as agents, distributors, licensees, and others involved in sponsorships or collaborations).

The Code covers all workers across the supply chain, including permanent, temporary, contract and migrant workers. Carlsberg will periodically review and update this Code as necessary, notifying suppliers of any changes.

Compliance

Suppliers must comply with all relevant laws and regulations in the markets in which they operate and, where applicable, meet trading requirements in the markets where their products are sold. Where national standards differ, suppliers must follow the highest standard of protection for workers and the environment without contradicting the legal framework of the country. Suppliers must be able to demonstrate compliance with this Code and applicable laws in their own operations and in their supply chains. 

Suppliers are encouraged to have policies aligned with Carlsberg’s principles. This Code includes mandatory requirements and best practices promoting compliance and continuous improvement in sustainability and ethics. Carlsberg reserves the right to verify compliance through self-assessments, audits, or other monitoring methods. The supplier is responsible for covering the cost of compliance verification.

Non-discrimination

Suppliers must ensure non-discrimination in all employment decisions, basing them solely on lawful criteria, regardless of race, gender, religion, sexual orientation, disability, or other traits.

Forced labour

Carlsberg prohibits all forms of forced labour, modern slavery, and human trafficking in line with national laws, the Palermo Protocol, and ILO Conventions. Suppliers must comply with these standards, banning practices such as sex trafficking, torture, state-imposed forced labour, and involuntary prison labour. Prison labour is only allowed with Carlsberg’s approval as part of a reintegration programme and subject to enhanced due diligence. 

Suppliers must uphold anti-slavery laws across their supply chains, ensuring that workers are not subjected to abuse, coercion, or intimidation, including physical or mental abuse. Workers must freely sign employment contracts without fees or deposits and retain their personal documents. Their freedom of movement must not be restricted, and they must be able to leave employment with reasonable notice and without penalty.

Child labour

Suppliers must uphold children’s rights and strictly prohibit child labour, ad-hering to ILO Conventions No. 138 on Minimum Age and No. 182 on the Worst Forms of Child Labour. A child is defined as anyone under 15 or the legal minimum working age in the given country, whichever is higher, with exceptions for specific countries where the minimum age is 14 as allowed by ILO Conventions.

Child labour, including work that exploits, harms, or hinders education, is strictly forbidden. If child labour is identified, suppliers must support initiatives to transition children out of such work. Children may assist in family businesses only if the work is light, age-appropriate and compliant with ILO standards. 

All workers must be at least 15 years old or the legal working age, which-ever is higher. Suppliers must verify applicants' ages and ensure that young workers (under 18) are not exposed to harmful tasks, night work or activities that interfere with their education. Employment of young workers must comply with local laws, include educational benefits, and prioritise safety and wellbeing.

Freedom of association and collective bargaining

Suppliers must respect workers' rights to unionise, participate in union activities and bargain collectively without fear of retaliation, harassment, or termination in accordance with the ETI Base Code, the UNGPs and ILO Convention No. 87, ensuring that these protections are communicated and up-held by management. Suppliers should foster a supportive environment for worker organisations by providing meeting spaces, allowing engagement during working hours and sharing negotiation information, while treating worker representatives fairly by providing access to resources, time off for union duties and management support. Where unions are restricted, alternative forms of representation, such as worker councils, should be established in line with ILO Convention No. 135. Suppliers must also respect the legal right to strike, avoid punitive measures or obstructive policies, and address strikes constructively through dialogue with worker representatives to resolve underlying issues.

Harassment

Supplier must protect employees from: harassment, bullying, abuse, or threats, fostering a safe and respectful workplace. Clear rules on discrimination, harassment, ethics, and disciplinary measures must be established and communicated to all employees. Additionally, suppliers must promote equality and inclusivity by valuing diversity in areas such as gender, age, culture, and lifestyle, and by implementing policies and programmes that support diversity, equality, and inclusion.

Working hours, benefits and wages

Suppliers must comply with national laws, collective agreements, and industry standards on working hours, prioritising greater protection of workers. Working hours must not be excessive, with overtime being voluntary and within legal or collectively agreed limits. Regular working hours should not exceed 48 hours per week, with a maximum of 60 hours, including overtime, in line with ILO and ETI standards. In exceptional circumstances, exceeding 60 hours is allowed, but only if this complies with national law, collective agreements, and health and safety safeguards, and is justified by unfore-seen situations such as production peaks or emergencies. Workers must have at least one day off per week, or two days in a 14-day period if permitted by national law.

Suppliers must ensure that wages and benefits for a standard working week meet or exceed national legal standards, collectively agreed rates or indus-try benchmarks, whichever is higher. Wages must be paid regularly and documented with a payslip. Workers must receive clear written information about employment conditions and wages, including any deductions. Wage deductions as a disciplinary measure or not allowed by law are prohibited. Suppliers must comply with labour laws, including social security, insurance, and benefits such as sick leave, holiday, and parental leave. They must also avoid bypassing these obligations through subcontracting or other schemes.

Employee contracts

At the commencement of employment or service, suppliers must provide all employees with a legally binding contract written in a language they under-stand. This contract must include key information, such as job title, expected wages, working hours, notice period, benefits, leave entitlements, terms and conditions, and any disciplinary and grievance mechanisms.

Suppliers must uphold rigorous health and safety standards, complying with all relevant laws, regulations and industry benchmarks, including the ILO Declaration on Fundamental Principles and Rights at Work. This includes providing a safe working environment, proper accommodation and effective management of chemicals and hazardous substances. Suppliers must also implement emergency response procedures to protect workers, visitors, and surrounding communities from harm.

Occupational heath and safety

Suppliers must comply with all applicable health and safety laws, regulations, and industry standards, including ILO Convention No. 155 on Occupational Safety and Health, ensuring a safe working environment for all employees, subcontractors, and visitors. Health and safety responsibilities should be assigned to senior management at both supplier and site levels, ensuring oversight of health and safety policies, compliance with regulations and prompt action to address any issues. Suppliers must maintain a written health and safety policy accessible to workers, with gender-sensitive procedures to minimise risks. A workplace risk assessment should be conducted to identify potential hazards, including those related to mental health and ergonomics, and appropriate measures must be implemented to mitigate these risks. Suppliers must provide personal protective equipment (PPE) free of charge and ensure that workers are trained in its use and safe work practices. Carlsberg considers health and safety when selecting suppliers and contractors, and contracts will include clear health and safety requirements. Violations of these policies may result in penalties or contract termination.

Emergency response procedures

Suppliers must establish emergency procedures for health, safety and industrial incidents, ensuring that all workers are informed. They must maintain clear evacuation routes, provide audible/visible alarms and train staff in first aid and firefighting. Regular emergency drills, including fire and hazardous material response, must be conducted, with records kept.

Health and safety requirements while on Carlsberg Group sites

Contractors working at Carlsberg sites must have relevant training, be equipped to safely execute tasks and follow Carlsberg’s health and safety policies and procedures. Suppliers and subcontractors must obtain a permit to work for high-risk activities at Carlsberg sites, and violations of these policies may result in penalties or contract termination. 

Carlsberg recognises the need to address climate change and reduce greenhouse gas emissions in line with the Paris Agreement. Suppliers play a key role in minimising climate impacts, enhancing resilience and identifying opportunities related to climate change, water security and other environmental issues. Suppliers must comply with environmental laws, regulations, and international standards, such as ISO 14001, and implement an effective environmental management system (EMS). They must manage carbon emissions, water use and waste, and focus on biodiversity, deforestation prevention, sustainable agriculture, and responsible energy consumption. Environmental actions should respect human rights, including the fair treatment of workers and local communities, and consider the impact of climate change on working conditions and cultural livelihoods.

Management of environmental issues

Suppliers must comply with all relevant environmental laws and requirements, staying current and proactive in preventing and mitigating adverse environmental impacts from their activities, products, and services. They must implement a robust environmental management system (EMS), aligned with standards such as ISO 14001, to monitor and address impacts on resources, energy, water, waste, carbon emissions and biodiversity. Significant environmental incidents or non-compliances with potential impact on Carlsberg must be reported immediately. Suppliers must regularly report on environmental performance, demonstrate measurable progress, and maintain transparency. They must also uphold environmental standards across their own supply chain, set clear environmental policies and provide regular training to ensure effective implementation. 

Carbon emission management

Suppliers must actively monitor and reduce their direct (Scope 1), indirect energy-related (Scope 2) and other indirect (Scope 3) CO2 emissions across their operations and supply chain, following the Greenhouse Gas Protocol. They must support Carlsberg's Scope 3 targets by implementing measurable carbon reduction strategies aligned with Science Based Targets initiative (SBTi) standards. Suppliers should address emissions across the entire product lifecycle, from design and manufacturing to end-of-life disposal. Suppliers must provide regular updates on progress towards carbon reduction targets, including detailed reporting to Carlsberg on Scope 1, 2 and 3 emissions, and share successes and challenges to maintain transparency with stakeholders.

Water and waste management

Suppliers must manage water responsibly, especially in areas with limited resources, by improving efficiency through water reuse and recycling. They must ensure that their operations do not harm local water rights, provide access to water and sanitation, and work with communities to improve access to safe water. 

Wastewater must be treated to meet local standards before discharge, either on site or at authorised facilities, and measures must be in place to prevent contamination of local water sources. Suppliers should regularly report on water usage, recycling, and reduction efforts, and continuously improve practices based on performance metrics and feedback.

Suppliers are required to adhere to established standards and responsible practices in waste and chemical management, strictly following national regulations to ensure environmental protection and safety. They must manage chemicals responsibly from procurement to disposal, regularly reviewing and updating these practices to maintain compliance and meet current best practices. Hazardous waste, including certain chemicals, must not be disposed of in landfills or incinerated on site without proper authorisation, and the use of persistent organic pollutants (POPs) is strictly prohibited due to their long-term environmental and health risks. 

Suppliers are also expected to minimise packaging waste by prioritising recyclable, reusable, renewable or compostable materials, aiming to reduce or eliminate single-use items. Additionally, suppliers should maintain and disclose a comprehensive inventory of all packaging materials, detailing recycled content, recyclability and compostability to support Carlsberg’s transparency and circularity goals for sustainable packaging.

Corruption and bribery

Supplier must comply with all Applicable Laws relating to anti-corruption in connection with its business activities, and in particular, it must not: (i) try to gain an undue advantage by promising, offering or giving anything of value, directly or indirectly, to any public official, business partner or any other third party; or (ii) engage in any other form of corruption, extortion, embezzlement or fraud that seeks to unjustly obtain improper advantages or otherwise influence the outcome of its business dealings. Supplier must ensure that all relevant employees and third parties have knowledge of and comply with Applicable Laws.

Gifts and entertainment

Supplier must not offer, fund or donate lavish gifts, extravagant entertainment or hospitality to any employees of, or other counterparts in, the Carlsberg Group in an attempt to influence business decisions. Supplier must ensure that any gifts and entertainment offered to Carlsberg Group employees are transparent and have a justifiable business rationale. In any event, Supplier must not offer any gifts, entertainment, hospitality or travel to Carlsberg Group employees working in the Carlsberg procurement organisation.

Conflict of interest

Carlsberg Group employees would be exposed to a conflict of interest, if their personal interest may affect their ability to act objectively and in the best interest of the Carlsberg Group. Supplier must not engage in any activity which creates such a conflict of interest or where such a conflict of interest could be reasonably perceived to exist. Supplier shall immediately take measures to stop any such conflict of interest.

Suppliers must not enter into any anticompetitive agreement with competitors (written, oral or tacit, e.g. by remaining silent, shaking hands, giving a wink) or engage in any other form of activity that has as its object or effect the prevention or restriction of competition and/or breaches applicable laws relating to competition or fair trade.

Suppliers must comply with all applicable laws and regulations relating to information and cyber security, data protection and AI. Suppliers are expected to adhere to relevant industry standards and implement state-of-the-art practices in collecting, sharing, and using consumer and employee personal data and confidential business information entrusted to them by Carlsberg, and in the development and operation of AI systems.

Suppliers must design and maintain AI systems to be robust, resilient, and secure. Suppliers are expected to operate AI systems responsibly and transparently, with documented evidence of fair and ethical AI design and use that causes no harm to individuals or society. Suppliers are not allowed to use consumer and employee personal data and confidential business information entrusted to them by Carlsberg for AI model training and advanced analytics purposes without Carlsberg’s specific and express permission. 

At Carlsberg’s request, suppliers must promptly complete relevant assessments and provide information about their information and cyber security, data protection and responsible AI programmes, policies, and controls. Carlsberg has the right to audit suppliers’ policies and practices to confirm compliance with the requirements outlined in this section.

This Code was last updated in March 2025.