Actions

[ESRS G1-3; GRI 2-16, 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.

Compliance Management System

The objective in setting up and continuously developing the Compliance Management System is to prevent, detect and respond to compliance violations against the interests of the company, as well as avoid liability risks and damage to the company’s reputation. Furthermore, it aims to advise and safeguard the company’s management, executives and employees, and to increase efficiency by coordinating existing compliance activities. The Compliance Management System corresponds to the following structure (figure “Elements of the Lenzing Compliance Management System”):

Elements of the Lenzing Compliance Management System

Compliance is based on the corporate values of the Lenzing Group and the measures it takes to promote integrity within the company. Formal structures, such as the assignment of responsibilities, ongoing monitoring and structures for communication, evaluation and documentation are essential components of the Compliance Management System.

The ongoing compliance program is based on the following pillars:

• Measures to prevent misconduct
• Measures to detect compliance risks and weaknesses
• Measures to respond to misconduct and identified weaknesses in order to avoid them in future.

At the meetings of the Supervisory Board’s Audit Committee in February, September and November 2024, the Compliance Officer reported on the content, objectives and status of the compliance organization, the structure of the Compliance Management System, training, internal and external investigations and various compliance measures (communication, surveys) in a separate agenda item.

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. For more details (ESRS 2 MDR-A), please see the “Detective measures” (G1-1) section in this chapter.

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 is important. For more information on this, please see the Lenzing Group’s Annual Report (Corporate Governance Report).

Availability of policies

All publicly available policies of the Lenzing Group are available under the following link: Compliance – Lenzing – innovative by nature. Policies and Directives are available to all employees via Lenzing’s intranet. They are provided in the following languages: German, English, Czech, Chinese, Bahasa, Portuguese and Thai.

The document manager (“caretaker”) in Compliance is the Group Compliance Officer, who therefore has the responsibility to disseminate a document to relevant business units. Compliance guides and materials are stored in Lenzing’s intranet and made available to compliance stakeholders. The resources are managed, updated and supplemented by Lenzing Global Compliance.

Compliance training

Understanding rules and regulations is a fundamental requirement for “correct” behavior. Hence, eLearning was continuously expanded during the reporting year to efficiently convey the most important content of the compliance directives to the relevant target groups. New employees receive welcome folders containing the Lenzing Code of Business Conduct. In addition, at all sites employees with IT access (approx. 6,000 employees) are assigned mandatory eLearning courses once per year. To ensure that the content of the eLearning has been understood, it can only be completed if at least 80 percent of points are achieved in the final quiz. The mandatory eLearning subjects for every employee, including the Managing Board, are: the Global Code of Business Conduct, the whistleblowing system and know-how protection. While some employees may be trained in these issues face-to-face, 89 percent of employees assigned to the eLearning training sessions completed them in 2024 (out of 6,181 employees).

All white-collar employees and the Managing Board (3,405 employees) were also assigned the mandatory ABC Directive training, of which 97 percent completed the training.

Specific trainings were assigned to functions-at-risk. 267 employees were assigned the Antitrust training, of which more than 92 percent fulfilled the training. A new Anti-Money Laundering training was assigned to 354 employees and was completed by 83 %.

The Supervisory Board completed the e-Learnings Global Code of Business Conduct and ABC Directive trainings in 2024. The goal was to give them an understanding of their responsibilities in regard of overseeing the Managing Board implementing compliance, Lenzing`s values and as well as the risks related to corruption.

Compliance cockpit

In 2024 the so-called “compliance cockpit” was approved, which aims to improve business conduct efforts. The package includes the improvement of the whistleblower tool and the gift and hospitality tool as well as the implementation of a conflict of interest registration tool and a policy manager (receiving, reading and acknowledging policies). The action is expected to finish in the first half of 2025.