Directives

The Group Compliance Officer is the most senior person accountable for the implementation of the Whistleblower, Antitrust, ABC and Investigation Directives, after been approved by the Managing Board. On the site level, the local directors are responsible for the roll-out and implementation of these Directives. The Anti Money Laundering Directive (AML Directive) is issued by the Group Compliance Officer, after been approved by the Managing Board and the Vice President Corporate Treasure, the Senior Vice President Global Purchasing and the Senior Director Global Commercial Excellence are the responsible for its implementation. On the site level, the local directors are responsible for the roll-out and implementation of these Directives. And for the Know-How Protection Directive the Head of Global Innovation is the most senior person accountable for its implementation. The directives apply to the whole Lenzing Group.

Anti Money Laundering Directive (AML Directive)

The Lenzing Group is committed to the highest standards of ethical business principles and to combating money laundering and terrorist financing (ML&TF). Money launderers aim to introduce money from illegal transactions into legal circulation. Terrorists seek to obtain money from illegal, as well as legal transactions to fund terrorist activities. Lenzing avoids business with criminals and uses a series of preventative measures to ensure that money laundering and terrorist financing are not unwittingly aided and abetted. The AML Directive describes the processes and control mechanisms implemented at Lenzing. The directive was introduced in 2020. In 2022 tools for the KYC (Know Your Counterpart) process were introduced to identify Lenzing counterparties and verify their identities. Furthermore, counterparties can be checked for adverse media, politically exposed persons (PEP) and sanctions to mitigate the risk of business relationships with illegitimate business activities.

The AML directive covers the following two impacts, with the second relating to the value chain aspect: the potential negative impact on business conduct efforts regarding corruption and bribery in the absence of ongoing efforts, training, reaction and clear procedures; while a compliance program is in place, incidents may still occur if individuals are given the opportunity to engage in non-compliant behavior.

Antitrust Directive

Lenzing does not tolerate or participate in any business conduct, transaction or activity that violates the applicable antitrust and competition laws. The company respects applicable trade laws and restrictions as imposed by the United Nations or other national or supranational bodies or governments. To ensure that all relevant antitrust regulations are known and adhered to within the Lenzing Group, Lenzing’s internal Antitrust Directive serves as a supplement to the Lenzing Global Code of Business Conduct. It applies to all business activities and operations in accordance with applicable competition law. It informs all employees how to behave correctly when dealing with business partners and shows which activities may pose an increased risk of antitrust violations. Furthermore, this directive helps to promote trust in business dealings, preserve Lenzing’s reputation and avoid or reduce costs, risks and damages resulting from a violation of antitrust law.

The antitrust directive covers the following impacts: Positive impact on the prevention of corruption, bribery and conflicts of interest by maintaining transparency; Potential negative impact on the morale of employees and stakeholder trust if there is a lack of transparency.

Anti-Bribery and Corruption Directive (ABC Directive)

The ABC Directive supplements Lenzing’s Global Code of Business Conduct by providing global minimum standards to ensure that Lenzing’s activities are conducted ethically and with integrity. The ABC directive is aligned with the United Nations Convention against Corruption. The goal of this Directive is to ensure that all relevant anti-bribery and corruption regulations are known and observed across the Lenzing Group. The Directive applies to all operations and activities in compliance with all applicable anti-corruption laws, including the Austrian Criminal Code, the United Kingdom Bribery Act 2010 and the US Foreign Corrupt Practices Act. The directive clearly defines what bribery, corruption and acceleration payments mean, and provides guidelines on what is considered acceptable behavior. Receiving and giving gifts, as well as accepting and giving hospitality or invitations, require – depending on the monetary value – specific approval within the Registration Tool for Gifts and Hospitalities. Country-specific limits have been defined for all legal entities.

Additionally, the Legal Department is currently developing a new Anti-Bribery and Corruption Policy, which will be effective from the upcoming fiscal year. This policy, building on the existing ABC Directive, will further refine Lenzing’s efforts and provide more specific guidance on issues related to anti-bribery and corruption. This is part of the ongoing commitment to conduct business ethically and with integrity, ensuring compliance with all relevant anti-bribery and corruption regulations across the whole Lenzing Group.

The ABC Directive covers the following three impacts: Positive impact on the prevention of corruption, bribery and conflicts of interest by maintaining transparency; Potential negative impact on the morale of employees and stakeholder trust if there is a lack of transparency; Potential negative impact on business conduct efforts in the absence of ongoing efforts, training, reaction and clear procedures.

Know-How Protection Directive

Specialization and innovative strength are key factors for the worldwide success of Lenzing. In today’s economy, information and know-how as a result of R&D investments, creativity and business initiatives have become the most important factors for developing and maintaining competitive advantages. Lenzing’s know-how is a central asset that must be preserved and protected using all the protective measures at Lenzing’s disposal. The protection of know-how relates not only to Lenzing’s leadership in technology, but also extends to its many different activities worldwide, including business secrets. Every employee is a key factor in Lenzing’s future know-how protection program and is directly affected by the know-how protection process described in this directive.

The Know-How Protection Directive covers the following impacts: Positive impact on the prevention of corruption, bribery and conflicts of interest by maintaining transparency; Potential negative impact on the morale of employees and stakeholder trust if there is a lack of transparency.

Investigation Directive

The purpose of this Compliance Investigation Directive is to set out a framework for the investigation of material and substantiated violations of laws, Lenzing’s Code of Business Conduct or internal Policies and Directives as set forth in the intranet.

The Investigation Directive covers the following three impacts: Potential negative impact on business conduct efforts regarding whistleblowers in the absence of ongoing efforts, training, reaction and clear procedures; the potential negative impact on business conduct efforts regarding corruption and bribery in the absence of ongoing efforts, training, reaction and clear procedures; While a compliance program is in place, incidents may still occur if individuals are given the opportunity to engage in non-compliant behavior.

Whistleblower Directive

In 2024, a revised version of the Whistleblower Directive from 2017 was signed by the Managing Board and came into force. The revised version reflects new regulations and will be reviewed – and revised if necessary – on a recurring basis to ensure relevancy. 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 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 employment termination for making reports. Lenzing takes all concerns raised under the Whistleblower Directive seriously and defines clear processes within it on how reports are handled internally, who is involved in any necessary investigations, and what the consequences are for any violations identified. The directive does not mention monitoring, however the effectiveness, availability and overall acceptance of the whistleblower system are evaluated through an Integrity Survey.

The Whistleblower Directive covers the following impacts: Positive impact on the prevention of corruption, bribery and conflicts of interest by maintaining transparency; Potential negative impact on the morale of employees and stakeholder trust if there is a lack of transparency; Potential negative impact on business conduct efforts regarding whistleblowers in the absence of ongoing efforts, training, reaction and clear procedures; Potential negative impact on business conduct efforts regarding corruption and bribery in the absence of ongoing efforts, training, reaction and clear procedures; While a compliance program is in place, incidents may still occur if individuals are given the opportunity to engage in non-compliant behavior.