Management Approach
Material topic: Business ethics
Importance for Lenzing
- Compliance at the Lenzing Group not only stands for compliance with legal regulations and regulatory standards, but for the active responsibility of all employees and executives as well as a shared culture of values that are firmly anchored in the entire Group
- Lenzing aims to deal honestly and with integrity in its behavior towards business partners and shareholders
Opportunities
- Compliance through a shared culture of values
- Preventive measures via whistleblowing
- Prevent retaliation against those who raise a concern
- Promote trust and confidence in business dealings
- Maintain corporate reputation
- Avoid conflicts of interest, misrepresentation, bias and negligence
- Prevent and report bribery and other forms of corruption
Risks
- A constantly changing internal and external business environment
- Violation of fair and compliant business practices leading to
- Reputational damage and resultant loss of public trust
- Loss of clients and business partners
- Value depreciation in the capital market
- Non-compliance with laws, regulations and obligations
- Costs and damage arising from involvement in bribery or breaches against (antitrust) law
- Fines, invalidity of contracts, claims for compensation from competitors and customers
Guiding principles
- Global Code of Business Conduct
- Global Supplier Code of Conduct
- Policy on Human Rights and Labor Standards
- Modern Slavery Act Transparency Statement
- Sustainability Policy
- Quality Policy
- Policy for Wood and Pulp
- Policy for Safety, Health and Environment (SHE)
- Anti-Bribery and Corruption Directive (ABC Directive)
- Local Guidance Document for the ABC Directive (e.g. registration system for gifts/hospitality) Antitrust Directive
- Whistleblower Directive
- Issuer Compliance Directive
- Anti Money Laundering Directive (AML Directive)
- Know-How Protection Directive
Due diligence processes and (ongoing) measures
- Compliance with Lenzing Global Code of Business Conduct and internal group-wide directives
- Reporting incidents via BKMS® whistleblower system (“Tell us”)
- Following up procedure for reported incidents
- Transparent reporting within Lenzing’s Corporate Governance Report
- Leading by example: supervisors, leaders, and managers act as role models
- Compliance trainings for employees
- Compliance Register Tool (e.g. gifts and hospitality)
Objectives
- Finalization and publication of Compliance Organization
- Continued penetration of compliance throughout the entire Lenzing Group
- Enhancement of compliance training for employees
- Short rule books for compliance issues (e.g. gifts and hospitality)
- Introduction of a new Know Your Counterpart (KYC) system
Achievements/activities in the reporting year
- Internal audit of Compliance Management System
- Updating Issuer Compliance Directive, Antitrust Directive, Anti Money Laundering Directive (preparing for update)
- Implementation of local standards/limits for gifts and hospitality
- Compliance workshops with IT, HR and Corporate Communications
- Compliance workshop with Managing Board
- Employees trained on business ethics issues
- Company-wide anonymous survey on the culture of integrity at Lenzing
- Awareness campaign on whistleblowing
- No corruption incidents
Responsible
- VP Global Legal, IP & Compliance
- Local Compliance Manager
Supporting
- Managing Board
- Corporate Communications
- Corporate HR
- Corporate Audit & Risk
- Corporate Sustainability
- Global Process Information Technology
- Site managers
