Actions

[ESRS G1-3; GRI 2-26, 3-3d, 205-2]

A summary of the “Actions taken” can be found in the management approach at the beginning of this chapter.

Detective measures

Lenzing takes complaints seriously and takes immediate action once it becomes aware of potential negative impacts. Lenzing has established grievance mechanisms. There are various internal reporting channels for employees. Externally, there is the possibility to submit indications via an online tool, which is not only available to all employees of the Lenzing Group but also to customers, suppliers and other third parties throughout the world. The online tool is also accessible through the Lenzing webpage: Compliance – Lenzing – innovative by nature.

Whistleblower directive

The purpose of Lenzing’s Whistleblower Directive is to encourage all employees to speak up in good faith against potential violations of laws, the Global Code of Business Conduct or Lenzing’s internal rules and principles. The directive aims to provide all employees with more concrete guidance and information on how to report compliance concerns about actual or potential rule violations. It emphasizes that for reports which were made in good faith (i.e. with a reasonable suspicion that a potential violation has occurred, is occurring, or is likely to occur), the parties involved are protected from subsequent punishment, discrimination, retaliation, disadvantage, harassment or termination for making reports. Lenzing takes all concerns raised under the Whistleblower Directive serious and defines clear processes in this Directive on how reports are handled internally, who is involved in any necessary investigations, and what the consequences are for identified violations.

Whistleblower system

In order to enable all employees and other stakeholders to report concerns in connection with topics such as corruption, bribery, conflicts of interest, antitrust laws and capital market law, an online-based whistleblower system was established in 2017. Grievances can be reported in-house in person, by phone or email, e.g. to supervisors, the works council or the Group Compliance Officer. In addition, the BKMS^® whistleblower system (“Tell us”) is freely accessible for everyone on the Lenzing webpage to express any concerns anonymously (available in all languages relevant to production sites: English, German, Czech, Chinese, Bahasa, Thai and Portuguese). Reporting an incident not only relates to Lenzing’s employees, but also to customers, suppliers, and other third parties around the world. Reported incidents are assessed by lawyers (if necessary, in cooperation with local partners) and forwarded to the Group Compliance Officer or to the Local Compliance Officer. Recommendations as to whether the investigation should be deepened or terminated are provided. Concerns can be reported anonymously and without fear of retaliation worldwide thanks to this system. The professional handling of the information protects both the whistleblower and the person affected. Reports are processed in a targeted manner in accordance with the internal Investigation Directive. The Audit Committee is informed about the reported incidents once a year.

Communication of critical concerns to the highest governance body

To remain compliant with all policies and react swiftly to any violations, the communication of critical concerns to the highest governance body are important. For more information on this, please see the Lenzing Group’s Annual Report (Corporate Governance Report).