Introduction
From our origins in 1923 through to the present day, BlueStar has been guided by our mission of serving and exceeding expectations of all our business partners, whilst keeping people safe, connected, and informed.
BlueStar Europe adheres to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, aiming to contribute positively to economic, environmental, and social progress through sustainable business practices. We encourage our business partners to join us in observing these guidelines to the fullest extent possible. BlueStar Europe will, and expects our business partners to also:
- Respect internationally recognized human rights throughout our supply chain.
- Create and facilitate employment and training opportunities.
- Support and uphold good corporate governance principles.
- Promote awareness and compliance through policy dissemination and training.
- Refrain from discriminatory or retaliatory actions against workers or their representatives who report concerns.
- Prevent and address reprisals against those investigating or raising concerns about adverse impacts.
- Conduct risk-based due diligence.
Environmentally Responsible - Keeping people safe
All enterprises within our supply chain must contribute to sustainable economies and address environmental challenges, including climate change. BlueStar Europe will, and expects our business partners to also, operate within legal frameworks and international standards, striving to avoid and mitigate adverse environmental impacts.
BlueStar Europe will, and expects our business partners to also:
- Implement environmental management systems:
- Identify and assess environmental impacts.
- Set measurable objectives and targets for improvement.
- Monitor progress and review strategies regularly.
- Provide transparent information on environmental impacts.
- Remediate adverse impacts and influence others to do the same.
- Engage with stakeholders affected by environmental impacts.
- Take precautionary measures to prevent serious or irreversible environmental damage, considering human health and safety.
- Maintain contingency plans for preventing and mitigating environmental and health damage, including accidents and emergencies and immediate reporting to the competent authorities.
- Continuously improve environmental performance:
- Adopt best available technologies.
- Develop and/or provide environmentally sound products and services.
- Promote customer awareness of environmental impacts.
- Educate and train workers on environmental, health, and safety matters, and support suppliers in environmental management.
- Contribute to environmentally responsible public policy through partnerships and initiatives.
Socially Responsible - Keeping people connected
BlueStar Europe will, and expects our business partners to also, respect internationally recognized human rights and comply with relevant laws and regulations. This includes:
- Respecting human rights:
- Avoid infringing on the rights of others and address any adverse impacts.
- Prevent or mitigate adverse impacts linked to business operations, products, or services.
- Maintain a publicly available policy commitment to respect human rights.
- Conduct human rights due diligence and cooperate in remediation processes.
- Ensuring fair employment practices:
- Where legally permitted, respect workers’ rights to join representative organizations of their choosing and to engage in meaningful dialogue or negotiation on employment-related matters with management representatives who are authorized to make decisions, through legally recognized channels such as trade unions, workers’ committees, or other mechanisms, in accordance with local laws and customs.
- Contribute to the effective abolition of child labour and the elimination of forced labour.
- Promote equality of opportunity and non-discrimination based on race, colour, sex, age, religion, political opinion, national extraction, social origin, disabilities, or other status. Exceptions may be made when selectivity concerning worker characteristics supports established governmental policies aimed at enhancing employment opportunities or relates to the essential requirements of a job.
- Provide a safe and healthy working environment.
- Facilitating effective communication:
- • Provide necessary facilities and timely, relevant information to workers’ representatives, where legally recognized, to support meaningful discussions on working conditions, employment terms, and workplace improvements, and encourage open and transparent communication between workers and management at all levels.
- Maintaining high standards:
- Observe employment standards, contractual arrangements, industrial relations, and provide fair wages and benefits.
- Maintain the highest standards of safety and health at work.
- Supporting local employment and training:
- Employ local workers and provide training to improve skill levels.
- Enabling collective bargaining:
- Promote constructive engagement between authorized worker representatives and management on labour-management relations issues and matters of mutual concern and where legally permissible, allow such representatives to consult and negotiate with management personnel who are empowered to make decisions. In jurisdictions where formal collective bargaining is not recognized, seek alternative lawful mechanisms to ensure employee voices are heard and considered.
Ethically Responsible - Keeping people informed
Code of Business Ethics
Combating Bribery and Other Forms of Corruption
BlueStar Europe is committed to maintaining the highest standards of ethical conduct and integrity in all our business activities and to combating bribery and other forms of corruption. This Code applies to all employees, officers, and directors of BlueStar Europe and is shared with all relevant personnel. BlueStar Europe will, and expects our business partners to also, implement effective anti-corruption measures to avoid adverse impacts. This includes:
- Ethical Business Behaviour
- BlueStar Europe is committed to conducting all business activities with ethical standards and integrity, ensuring compliance with fair competition practices and avoiding any form of fraud.
- We will compete based on the quality of our offering of products and services, ensuring fair business practices.
- BlueStar Europe will conduct business ethically, avoiding conflicts of interest, and protecting company property and information.
- We are committed to conducting our actions in a manner that upholds the company's reputation and preserves the integrity of our brand.
- Prohibiting Corruption
- BlueStar Europe will refrain from engaging in any acts of corruption, such as bribery or providing undue advantages to public officials, business partners, their relatives, or associates.
- We will not accept improper benefits from public officials, business partners, their relatives, or associates.
- We will not use intermediaries to provide undue advantages to public officials, business partners, their relatives, or associates.
- Implementing Internal Controls:
- We will implement internal controls to prevent, detect, and address bribery and corruption.
- Accurate financial records and conflict of interest registers will be maintained to prevent their use for involvement in or concealment of bribery or other corrupt practices.
- Risks will be regularly monitored and reassessed to ensure compliance.
- Conducting Due Diligence on Agents
- Due diligence will be conducted in hiring and monitoring any agents to ensure their compensation is appropriate and limited to legitimate services only.
- An updated list of agents engaged with public bodies and state-owned enterprises will be maintained.
- Discouraging Facilitation Payments
- BlueStar Europe will implement internal company controls, ethics, and compliance programs to prohibit or discourage the use of small facilitation payments. When any such payments are made, they will be accurately documented.
- Enhancing Transparency
- We will promote a culture of integrity, fully supported by BlueStar Europe’s senior management, and maintain a clear corporate policy in our internal Code of Conduct that prohibits bribery and corruption.
- Reporting any instances or suspicions of bribery and other forms of corruption will be encouraged, with a commitment to transparency regarding the actions taken to address such cases.
- Promoting Awareness and Training
- Anti-corruption policies will be disseminated, and training will be provided for employees.
- Avoiding Illegal Political Contributions
- BlueStar Europe commits to adhering to national laws regarding political contributions and will not make any illegal donations to political candidates or parties. Any political contributions that are made must receive senior management approval. Additionally, employees will not be required to support any political candidate or organization.
- Customer and Supplier Relations
- BlueStar Europe will adhere to competition laws and avoid commercial bribery to ensure fair business practices.
- BlueStar Europe is committed to upholding ethical conduct in our supplier relationships, fostering enduring partnerships founded on mutual trust and integrity.
- Protecting Assets
- BlueStar Europe is committed to preventing conflicts of interest and will manage gifts and entertainment responsibly to ensure that business decisions are influenced solely by legitimate considerations.
…and finally
Honest
Reporting of Concerns – Whistleblowing
We take all reported concerns seriously and work with our suppliers to find solutions that match the severity and scale of the reported issue. Following the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, our approach includes:
- Cooperation with suppliers: Develop plans to prevent, mitigate, and remediate adverse impacts using agreed-upon indicators.
- Leveraging influence: Use our leverage to address adverse impacts and cooperate with other actors to create collective leverage if needed.
- Human rights violations: Engage with rights holders to develop corrective action plans.
- Disengagement: Consider disengagement with a supplier after failed attempts to mitigate or remediate material impacts.
Please report any violations of this Code using our Whistleblowing Portal accessible at https://whistleblowersoftware.com/secure/BlueStar_Whistleblowing_Portal.
Governance and Application
This Code of Business Conduct and Ethics has been formally approved by the Executive Committee of BlueStar Europe Distribution BV on 21st November 2025. It reflects BlueStar Europe’s ongoing commitment to responsible business conduct, integrity, and legal compliance.
The implementation, dissemination, and oversight of this Code is the responsibility of the Trade Compliance Department, which will provide guidance to employees and business partners regarding the interpretation and application of its provisions. Any questions or concerns may be addressed to: compliance@eu.bluestarinc.com.
All employees and officers are expected to read, understand, and comply with this Code. Third parties are expected to act in a manner consistent with the principles of ethical, social and environmental responsibility set out in this Code.
This Code will be reviewed periodically and updated as necessary to reflect changes in applicable laws, operational risks, or corporate strategy.