lenzing.com

Business ethics

Management Approach

Material topic: Business ethics

[GRI 3-3]

Lenzing and its people are expected to act with honesty and transparency in line with the Group’s Global Code of Conduct and corporate governance policies. These expectations of compliance reach beyond legal requirements and regulatory standards as the company strives for exemplary quality in all products, processes and dealings with customers, partners and shareholders. It is the responsibility of all employees and contractors to uphold these standards and to help create a culture of tolerance and integrity. Lenzing continues to develop its Compliance Management System to ensure the company acts to prevent misconduct, mitigate compliance risks and effectively safeguard its people. Training in business ethics ensures that all employees understand the behavior expected of them and contributes to an environment where the people feel comfortable raising concerns or reporting misconduct. Suppliers are also expected to adhere to the highest professional and ethical standards in the industry.

Actual and potential negative and positive impacts

Positive

  • 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

Negative

Own activities:

  • 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

Business relationships:

  • Non-compliance with laws, regulations and obligations due to constantly changing internal and external business environment

Policies and commitments

  • Lenzing Global Code of Business Conduct
  • Lenzing 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

Actions taken

  • Updating Code of Conduct, Anti Money Laundering Directive (preparing for update)
  • Implementation of local standards/limits for gifts and hospitality
  • Employees trained on business ethics issues
  • Anonymous management survey on Compliance Risks at Lenzing
  • Awareness campaign on whistleblowing
  • No corruption incidents
  • Working on/Development of a Group-wide compliance eLearning for Code of Conduct
  • Working on concept of ongoing Compliance Risk Assessment
  • Compliance with Lenzing Global Code of Business Conduct and internal group-wide directives
  • Reporting incidents via BKMS® (Business Keeper Monitoring System) 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)

Sustainability targets, measures and progress

For more information, please see the “Sustainability targets, measures and progress” chapter.

Stakeholder engagement

  • Employees
  • Suppliers
  • Governments
  • Customers
  • Membership associations

For more information, please see the “Stakeholder engagement” chapter and focus paper.

Responsible

  • Managing Board
  • VP Global Legal, IP & Compliance
  • Local Compliance Manager

Supporting

  • Corporate Communications
  • Corporate HR
  • Corporate Audit & Risk
  • Corporate Sustainability
  • Global Process Information Technology
  • Site managers

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