List of contents. 1. Scope of application. 2. Background. 3. Responsibility. 4. Goals and measures. 5. Responsibilities and controls

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Fish Purchasing Policy Version: December 2016

List of contents 1. Scope of application 2. Background 3. Responsibility 4. Goals and measures 5. Responsibilities and controls 6. Partners and standards The Fish Purchasing Policy is available in German and English. In case of doubt, the German version shall prevail. 2

1. Scope of application The present Fish Purchasing Policy stipulates the purchasing principles for any resources of own brand products in the range of seafood and fishery products by the ALDI North group (Germany). This also includes any food items containing fish (such as pizza, salads and spreads containing fish) as well as pet food. The Fish Purchasing Policy is a binding framework for us and our business partners. It is the subject of ongoing updates and rigorous examination. Its validity will end with the publication of an updated version on www.aldi-nord.de Cooperation is carried out exclusively with business partners who work in harmony with our Fish Purchasing Policy. 3

2. Background The latest figures demonstrate the increasing importance of fishery for feeding the world s population, concurrently indicating the associated challenges of a more sustainable treatment of the oceans as a resource. The global amount of fish and seafood caught in the wild totals 93.4m tonnes per year 1. At the same time, 73.6m tonnes 1 of fish and seafood are produced in aquaculture every year around the world. Today, nearly one third (31.4 per cent 1 ) of the global fish stock has already been overfished, with the use of certain fishing methods, for instance, or illegal fishery continuing to pose the threat of overfishing to the existing stocks. Although fish from aquaculture is reversing this trend to a certain extent, the conditions of such production often fail to be resource-conserving. Consumers, however, attach more and more importance to the provenance of raw materials. According to a current poll, approximately three quarters of fish consumers in Germany (73 per cent) think that sustainable fishery is a main precondition for the protection of our oceans and fish stocks in the long term 2. 1 SOFIA (The State Of World Fisheries And Aquaculture) report of the FAO (Food and Agriculture Organization of the United Nations), July 2016 2 MSC consumer poll, September 2016 4

3. Responsibility The sustainable and conservative treatment of natural resources is an integral part of ALDI Nord s corporate responsibility. As an internationally operating retail company, ALDI Nord makes use of its leverage to set standards in the supply chain with tools such as productspecific purchasing policies. Through our Fish Purchasing Policy, we strive to promote measures that counteract the endangerment of fish stocks in the world s oceans, conserve ecosystems in oceans and inland waters, contribute to animal welfare and improve working conditions in the fishing industry. A summary of our goals: I. Increasing the proportion of sustainable seafood and fish products as well as protecting endangered fish species I Wild-caught: Full MSC (Marine Stewardship Council) certification of seafood and fishery products from our standard and seasonal ranges in the commodity groups of fresh fish and frozen fish by the end of 2017. I Aquaculture: Seafood and fishery products from our standard and seasonal ranges in the commodity groups of fresh fish, frozen fish, refrigerated items and canned food to be entirely certified in accordance with ASC (Aquaculture Stewardship Council), EU organic label or GLOBALG.A.P. by the end of 2017. I Implementing alternative approaches for non-msc-certified tuna and mandating that our suppliers comply with the minimum requirements. I Banning certain fish species whose stocks are acutely endangered or which fail to meet the requirements of our internal sustainability assessment. I Contractual obligation of our suppliers to comply with internationally recognized social standards. II. Traceability I Ensuring full and continuous traceability of all products throughout the value chain. III. Declaration of products I Providing transparent product information for our customers through indications of origin beyond the legal provisions, as well as labelling all products containing fish with the ALDI Transparency Code (ATC). 5

4. Goals and measures ALDI Nord develops targets and measures relating to the topic of fish and seafood conservation with close coordination between the business divisions of corporate responsibility, purchasing and quality control as well as with its business partners and relevant stakeholders. We strive to offer a supply of sustainable seafood and fishery products throughout our entire range. We have currently defined the following goals: I. Increasing the proportion of sustainable seafood and fishery produce and protecting endangered fish species A great amount of certified seafood and fishery produce is already available at ALDI Nord, thus encouraging the resource-conserving, eco-friendly and socially sound production of these items. The following commodity groups shall be fully certified by the end of 2017: Fish caught in the wild By the end of 2017, seafood and fishery products from our standard and seasonal ranges in the commodity groups of fresh fish and frozen fish will be certified by MSC (Marine Stewardship Council). Moreover, we are committed to the following criteria being complied with: I Avoiding overfished stocks; I Avoiding fish species from critical fishing areas and marine bio-regions; I Minimizing the use of especially critical fishing methods such as bottom trawl nets, dredges or purse-seining with fish aggregation devices [FADs]); I Minimizing the quantity of by-catch; I Keeping the impact on ecosystems to the lowest possible level. 6

Fish from aquacultures By the end of 2017, seafood and fishery products from our standard and seasonal ranges in the commodity groups of fresh fish, frozen fish, refrigerated items and canned food will be certified by ASC (Aquaculture Stewardship Council), EU organic label or GLOBALG.A.P. Moreover, we are committed to the following criteria being complied with: I Reduction of negative impacts on the (surrounding) wildlife; I Implementing innovative approaches for the production of fish feed; I Observing strict environmental guidelines during processing; I No stocking with eggs or young animals caught in the wild; I No use of growth stimulants or hormones; I Ensuring a well-working management system for faeces, waste and waste water; I No breeding of genetically modified animals and no use of forage crops that were genetically modified or cultivated in association with tropical deforestation. For certain species, a comprehensive certification is not permanently feasible. This currently applies to capelin, crustaceans, sardines, tuna/skipjack, squid and zander. In these cases, we are closely co-operating with our suppliers in order to ensure certification in the future and to promote more sustainable production by adopting alternative measures. Tuna/skipjack If the product is not MSC-certified, we and our suppliers will jointly strive to achieve compliance with at least one of the following criteria: I The supplier or processing company, respectively, is a member of ISSF (International Seafood Sustainability Foundation); I The vessel is registered with the ProActiveVessel Register (PVR); I The fishery verifiably supports a Fishery Improvement Project (FIP) that is registered on fisheryimprovementprojects.org and thus meets the requirements of the Sustainable Fisheries Partnership (SFP). Our tuna purchasing policy is solely based on FAD-free resources. FAD-free means that the tuna was caught without fish aggregating devices. Moreover, we encourage the use of the pole and line method. 7

Banning certain fish species We do not sell any fish species that are classified on international species protection lists as endangered and protected or partially protected, or that fail to meet the requirements of our internal sustainability assessment. Our internal monitoring covers each item of our fish ranges as well as various parameters such as the fishing area, the fishing method or the gear used. Internal monitoring at ALDI is an ongoing process, as the fish stocks of single species are constantly changing as well. Some fish species have been banned from our range, partially because their stocks are critically endangered. We refrain from buying and selling the following species: I Eel, arapaima, bluefin tuna, orange roughy, rat tail fish, bigeye tuna, all shark species, lobster, parrotfish, John Dory, ray, red snapper, sturgeons caught in the wild, venus clams, whiting. The following species are only sold with MSC or ASC certification and subject to the requirements of our internal sustainability assessment : I Yellowfin tuna, halibut, cod, krill, golden redfish, plaice, swordfish, monkfish, common sole, spined loach, turbot, Nile perch, white tuna / albacore. 8

The list of fish species banned from sale is subject to regular examination and updating, if required. Additionally, we refrain from buying and selling seafood and fishery products if they originate from stocks that fall below the Blim reference threshold (see definition in the box). In principal, ALDI Nord approves of orientation to the Maximum Sustainable Yield (also see definition in the box). Furthermore, we ban any goods from illegal, unreported and unregulated (IUU) fisheries. Fishing mortality A mathematical expression of death of fish due to fishing, related to a certain age group. Spawning stock biomass Total weight of all adult fish involved in the reproduction process Limit reference point (Blim) Biomass value used to indicate when harvests should be constrained substantially to ensure that reproductive capacity of individual stocks is not impaired. Maximum Sustainable Yield (MSY) The largest average catch or yield that can continuously be taken from a stock under existing environmental conditions. Source of definitions: Thünen Institute and National Oceanic and Atmospheric Administration (NOAA) 9

Commitment to social standards ALDI Nord joined the Foreign Trade Association (FTA) in 2008 and, as a participant of the Business Social Compliance Initiative (BSCI), committed to act in accordance with the BSCI Code of Conduct. The BSCI Code of Conduct is a binding part of our General Terms and Conditions. Compliance with the Code is therefore an obligation we impose on all our suppliers and their production facilities. The codex is based on the standards of the ILO (International Labour Organization), the UN Declaration of Human Rights as well as further supranational, independent guidelines and covers the following issues, among others: I Exclusion of any kind of forced labour or child labour; I Exclusion of discrimination at the workplace; I Guidelines on the regulation of wages and working hours corresponding to national or international legislation and standards; I Ensuring freedom of assembly as well as the right to collective bargaining. For invitations to tender from 1st July 2017, the commissioned production facilities for the industrial manufacturing of canned food (including canned fish) in BSCI risk countries are subject to an additional social auditing (BSCI/SA8000). Moreover, we strive to achieve fair and safe working conditions throughout the supply chain and intend to expand our controlling procedures in a risk-oriented way. II. Traceability We require our suppliers to provide full traceability of all seafood and fishery products which they deliver to ALDI Nord. In this respect, we request a variety of additional information aside from the standard data: our suppliers need to be able to specify the time of catching, the vessel and the port of landing. Furthermore, the supplier shall be in a position to present the entire value chain of a product based on the item specification (batch number in connection with the relevant best-before date). 10

III. Declaration of products Our customers should be enabled to base their purchasing decisions on awareness and comprehensive information. Together with our suppliers, we therefore apply product labelling that goes beyond the legal provisions. This product labelling which is mandatory for our suppliers includes: I the common name of the species (trade name); I the scientific (Latin) name of the species; I the method of production (wild-caught or aquaculture); I the respective method/gear of fishing in the case of wild-caught products as well as the method of aquaculture; I the FAO fishing areas and the specific zones for wild-caught fish as well as the country of farming in case of aquaculture, respectively; I the date/period of catching for wild-caught fish and the day of harvest in case of aquaculture. If possible, the supplier will provide the following additional data on the packaging: I the name of the vessel; I the port of landing. Our comprehensible ALDI fish labelling system and the relevant map section enable consumers to see, at a glance, where the fish originates from and by which method it was caught. 11

Our suppliers are obligated to implement the binding provisions of our customer-oriented, standardized product labelling (see scheme below on the left). Furthermore, the ALDI Transparency Code (ATC) will be introduced in 2017 for our products containing fish. This is a QR code which can be read by a smartphone or a computer (see scheme below on the right). Upon scanning, the user will receive online information on the product such as the name of the processing company or detailed information on the specific fishing method. 12

5. Responsibilities and controls ALDI Nord undertakes regular reviews of its targets in the area of sustainable fish and seafood purchasing and may, where required, formulate additional targets and measures. In doing so, we are in a constant dialogue with external partners such as NGOs, members of the academic professions and other relevant stakeholders. For the purchasers of ALDI Nord, the International Fish Purchasing Policy and the objectives expressed therein are binding in the implementation of tendering and procurement processes. ALDI Nord has informed its suppliers of own brand items containing fish of the content and objectives of the Fish Purchasing Policy. The suppliers of goods containing fish are contractually obliged to comply with these requirements upon receipt of orders. ALDI Nord expects its suppliers to develop appropriate guidelines for the sustainable procurement of seafood and fishery produce and to have a management system in place allowing for the continuous verification of standards. ALDI Nord reserves the right to employ independent institutions to carry out spot checks of its product specifications at the suppliers premises. To achieve its corporate goals, ALDI Nord has always relied on a close and trustful co-operation with its suppliers. With our business partners, we share the responsibility for the conservation of natural resources and therefore joined forces to achieve the targets defined in this purchasing policy. ALDI Nord welcomes its suppliers to promote individual sustainability projects in fishery or aquaculture and to provide information on the approaches taken as well as on the current developments. The management and other responsible staff of ALDI Nord are regularly informed on the current status of implementation. 13

6. Partners and standards Marine Stewardship Council (MSC) The MSC is an international, independent and non-profit organisation managing the internationally recognized MSC label for fish from sustainable fisheries. If a fishery wants to obtain the MSC label, it needs to be assessed according to the MSC environmental standard for sustainable fishery and must meet the respective requirements. Likewise, producers and traders need to undergo assessment by independent certification institutes on a regular basis if they want to sell fish with the blue label. Thus consumers can be sure that MSC-certified fish can be traced right back to a sustainable fishery operating in compliance with the MSC standard. EU organic logo All fish products and seafood bearing the EU organic logo were produced and controlled according to legal provisions of the EU. The organic logo ensures (among other criteria) controlled water quality, protection of the natural wildlife environment and certified organic feedstuffs. Aquaculture Stewardship Council (ASC) The ASC is an independent global non-profit organisation founded by the World Wide Fund for Nature (WWF) and the Sustainable Trade Initiative (IDH) in 2010. The ASC strives to accomplish a higher level of sustainability within the global aquaculture industry. For this purpose, environmental campaigners, representatives of the government, fish farmers and other stakeholders have jointly developed the ASC standards for environmentally friendly and socially responsible fish farming. Upon successful assessment by independent certification institutes, the suppliers will receive a certificate and approval to use the ASC logo. GLOBALG.A.P GLOBALG.A.P. is a private enterprise organisation defining voluntary standards in the certification of agricultural products since the 1990s. The standard involves reduction of polluting impacts by the agriculture and restriction of the use of pharmaceuticals and chemical pesticides as well as the implementation of measures for the safety and health of humans and animals. With regard to fish, the standard certifies aquacultures. Thünen Institute The Thünen Institute conducts interdisciplinary research to develop long term sustainable solutions in agriculture, forestry and fisheries. Thus, the institute links the three dimensions economy, ecology and technology in its approach. The Thünen Institute is an independent federal research agency within the authority of the German Federal Ministry of Food and Agriculture (Bundesministerium für Ernährung und Landwirtschaft [BMEL]). Its scientific activities regarding oceans provide the basis for a sustainable management of fish stocks in the North-East Atlantic. 14

Further information regarding our CR activities can be found on our website www.cr-aldinord.com ALDI Einkauf GmbH & Co. ohg Corporate Responsibility Eckenbergstraße 16 A 45307 Essen ALDI North group 2017