Detective measures
Whistleblower system
[G1-1 10a, 10c; S1-3 32b, 32d, 32e, 33; S2-3 27b, 27d, 28]
To enable all employees and external stakeholders to report concerns related to corruption, bribery, conflicts of interest, antitrust laws and capital market law as well as other compliance matters, a global online-based whistleblower system has been established since 2017. Lenzing’s joint venture LD Celulose also maintains its own whistleblower channel. Concerns can be raised internally, either personally, by phone or email, or through supervisors, the works council or the Group Compliance Officer. In addition, the whistleblower system (“Tell us”) is accessible via the Lenzing website and allows anonymous reporting. It is available in all languages relevant to production sites (English, German, Czech, Chinese, Bahasa, Thai and Portuguese). The system is open not only to employees, but also to customers, suppliers and other third parties worldwide. Concerns can be submitted anonymously and without fear of retaliation as the system’s anonymity safeguards are certified by an independent body. Professional and confidential handling of all reports ensures the protection of both the whistleblower and the persons concerned.
A Whistleblower Directive is in place and ensures that individuals who report concerns in good faith (that is with a reasonable suspicion that a potential violation has occurred, is occurring, or is likely to occur), are protected from any form of punishment, discrimination, retaliation, disadvantage, harassment or employment termination. Although the directive does not explicitly refer to monitoring activities, the effectiveness, accessibility and overall acceptance of the whistleblower system are evaluated through a regular Integrity Survey.
Handling of reported concerns
[G1-1 10c, 10e, G1-3 18b, 18c]
Reports are processed in a targeted manner in accordance with the internal Investigation Directive (see the G1-1 “Directives” section in this chapter). 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. A report is processed by designated employees. The individuals entrusted with conducting the procedure are obligated to maintain confidentiality. If necessary, other departments and individuals are also involved in processing a reported incident. The reports are processed on a case-by-case basis, situation-related measures are defined and, if necessary, an investigation team is formed. These teams comprise employees and managers who are not involved in the incident itself. Confidentiality surrounding the identity of the person concerned is maintained and the procedures provide effective protection from retaliation against the whistleblower. Recommendations as to whether the investigation should be pursued further or be terminated are provided. Monthly reporting on the status of compliance as well as ongoing investigations are provided to the Managing Board. In addition, the Audit Committee of the Supervisory Board is informed about reported incidents on a quarterly basis.
Employees receive training on the use of the whistleblower system (for further information, please see the “Compliance training” section of this chapter). Training is also provided to those responsible for handling reported concerns. The effectiveness, accessibility and overall acceptance of the whistleblower system are evaluated through an Integrity Survey supported by an independent scientific team to ensure objectivity.
If actual negative impacts on employees occur, remediation is provided on an individual basis as no Group-wide remediation process is currently in place.
Training Directive
[G1-1 10g]
All directives related to business conduct include provisions on training. A comprehensive Training Directive is being developed to assign specific training requirements to defined job functions. As part of its design, a risk assessment is carried out to more precisely define and identify functions-at-risk within the organization. These functions will then receive targeted, role-specific training. This approach ensures that employees are well equipped with the necessary knowledge and skills to perform their roles effectively and ethically, thereby further enhancing Lenzing’s commitment to integrity and compliance. The directive is planned for the next fiscal year.
For information on target audience, frequency and depth of coverage, please see the “Compliance training” section under “Actions” in this chapter.