Policies

[ESRS G1-1; GRI 3-3c, 2-23, 2-24, 2-25]

All publicly available policies of the Lenzing Group are available under the following link: Compliance – Lenzing – innovative by nature. For international regulatory references in the Group’s policies, please see the “Intergovernmental regulation references in policies” table in the Annex. The policies apply to the whole Lenzing Group.

Hierarchy of compliance guidelines and directives

Lenzing’s internal rules and principles

Besides the Lenzing Global Code of Business Conduct, there are additional internal rules and principles of conduct (known as directives) that help to ensure that daily actions are in line with the applicable legal frameworks and Lenzing’s demand for integrity from each individual employee. Directives define rules of conduct that are binding for all employees of the Lenzing Group. Classifying a document as a directive always implicates the decision that non-conformance with the content of the directive may incur penalties and, in the worst case, termination of employment. Important directives include, amongst others, the Anti-Bribery and Corruption Directive, the Antitrust Directive, the Whistleblower Directive, the Anti Money Laundering Directive and the Know-How Protection Directive. For further information on these directives, please see the “Directives” and “Actions” sections in this chapter.

To ensure that no human rights violations occur within the sphere of Lenzing’s influence, Lenzing has a Policy on Human Rights and Labor Standards. For more information on policies stipulating respect for human rights, please see the “Policies” section in the “S1 Own workforce” chapter (refers to GRI 2-23 only).

Lenzing Global Code of Business Conduct

The Lenzing Global Code of Business Conduct covers all of the identified material impacts and risks. Compliance measures and business ethics are crucial for Lenzing to comply with a multitude of legal regulations and standards at various sites and countries around the world. Lenzing attaches great value to the integrity and legally compliant behavior of all employees and business partners. Therefore, Lenzing has anchored its principles for compliant behavior in the Lenzing Global Code of Business Conduct. This code, which was approved by the Managing Board in 2023, has been devised in alignment with the principles of the UN Global Compact, reinforcing the commitment to uphold international standards for human rights, labor and anti-corruption. It serves as a guideline and advisor at the same time, so that all employees know how to react appropriately and in compliance with the rules in every situation. At the same time, it points out to Lenzing employees that violations of the Global Code of Business Conduct have serious consequences (civil, criminal, administrative criminal and/or disciplinary consequences, up to and including termination of employment). The Lenzing Global Code of Business Conduct is available to all employees in the Group languages in the intranet (“Lenzing Connect”) and is also accessible to external stakeholders on the company website. Lenzing’s Global Code of Business Conduct is diligently monitored to ensure adherence to the highest standards of business ethics. The Group Compliance Officer oversees the implementation and adherence to the code within the organization. In addition, Local Compliance Units have been established in various regions to ensure that the code is followed in accordance with local laws and regulations. It is supplemented by the Global Supplier Code of Conduct, which outlines Lenzing’s expectations for supplier conduct with respect to safety and health at work, labor and human rights, environmental protection, ethics and management practices.

Lenzing Global Supplier Code of Conduct

All of the Lenzing Group’s suppliers must comply with the Lenzing Global Supplier Code of Conduct, which was approved in 2017 by the Ethics Committee, the Company’s Executive Committee and the Group Compliance Officer and is available via Lenzing’s website. The Senior Vice President Global Purchasing and the Senior Vice President Commercial Pulp, Biorefinery & Co-Products, Wood, are accountable for its implementation. To ensure compliance with this Code, suppliers are required to allow Lenzing and/or any of its representatives to have access to all their facilities and to all relevant records upon advance notice, and to carry out assessments through supplier assessment tools. These actions ensure that Lenzing can evaluate compliance with the Code’s standards, which outline Lenzing’s expectations for suppliers conduct regarding safety, health, labor and human rights, environmental protection, ethics, and management practice. If Lenzing finds that a supplier has violated the Code, it may terminate the business relationship or require corrective actions. If the supplier fails to take corrective actions, Lenzing may cancel current orders and suspend future orders.

The Lenzing Global Supplier Code of Conduct covers the value chain aspect of the following two impacts as well as a risk: Potential negative impact on business conduct efforts regarding whistleblowers 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; Risk of non-compliance with the Corporate Supply Chain Due Diligence Directive (CSDDD) if internal processes are not implemented (own operations).

Wood and Pulp Policy

In its wood and pulp policy, the company has committed itself to procuring wood and dissolving wood pulp exclusively from non-controversial sources, giving preference to suppliers compliant with FSC^® or PEFC standards. Lenzing’s suppliers also adhere to this policy, conducting all operations with respect to health and safety at work, labor and human rights, environmental protection, ethics, and management practices.

The Wood and Pulp Policy covers the value chain aspect of the following two impacts as well as a risk: Positive impact on the prevention of corruption, bribery and conflicts of interest by maintaining transparency; the potential negative impact on the morale of employees and stakeholder trust if there is a lack of transparency; Risk of non-compliance with the Corporate Supply Chain Due Diligence Directive (CSDDD) if internal processes are not implemented (own operations).

For more information on the ESRS 2 MDR-P of the Wood and Pulp Policy, please see the “Policies” section in the “E4 Biodiversity and ecosystems” chapter.