lenzing.com

Business ethics

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

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