Sustainability Governance

Our approach to governance is more than a legal formality
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A diverse group of people in suits sitting around a conference table

Our culture is rooted in a strong foundation of integrity and sound governance, and our Twentyby30 program reflects this commitment. We know that operating successfully can only be done when we have the trust of our stakeholders. This includes our associates, customers, suppliers, shareholders, partners, the governmental and non-governmental organizations we work with and the communities where we live and conduct business. 
 
We earn that trust by doing what is right and ethical. We comply with applicable legal, regulatory and industry code requirements and uphold the highest principles of integrity and standards in every aspect of our business and every market in which we operate. That mindset is ingrained into our business culture and is monitored, enforced and improved through our globally deployed Code of Business Conduct and Ethics. Available in nearly 20 languages, the Code outlines the high level of ethical behavior expected from our directors, officers and employees. 
 
Our Board of Directors, senior leadership and outside counsel regularly review our Code of Business Conduct and Ethics to account for any evolving issues and best practices. Any changes to the Code must be approved by the Board of Directors.

New hires are provided a copy of ³Ô¹Ï51±¬ÁÏÍø’s Code of Business Conduct and Ethics. Written acknowledgment is required for all new hires and managed at a local level, ensuring 100% of employees receive proper training upon their start with the Company. Annual acknowledgment of receipt of the Code of Business Conduct and Ethics is required via an online training course designed to reach all employees with an active email address, including those in management positions. This training is administered by our legal department and includes certification of compliance with the Company’s standards of business conduct. It also requires disclosure of any known potential violations
of such standards.

In addition to our proactive ethics training, we offer a reporting mechanism through which any employee can raise concerns about unethical or potentially problematic behavior. Employees are encouraged to report concerns by one of the following methods:

  • Speak directly to their supervisor or plant manager (or equivalent).
  • Contact their HR Manager, the Legal Department or their Regional Compliance Officer for the relevant policy.
  • Contact ³Ô¹Ï51±¬ÁÏÍø’s Business Ethics Line, which is independently operated by a leading third-party provider, using the 24/7 toll-free reporting hotline or web-based reporting portal.

Any inquiries are efficiently and thoroughly investigated, with confirmed violations of the Code of Business Conduct and Ethics addressed with disciplinary action up to and including termination of employment. Those who report concerns will be treated with dignity and respect and will not be subjected to any form of discipline or retaliation for reports made in good faith. To maintain transparency with the Company’s external management structure, senior leadership regularly reports to the Audit Committee of the Board of Directors on the status of significant open Code matters. 

Our Code of Business Conduct and Ethics is supplemented with standalone policies for certain issues covered by the Code, such as Antitrust Law Compliance, Anti-Corruption Law Compliance, Trade Sanctions Law Compliance, Related Party Transactions and Environment, Health and Safety Compliance. 
 
Acting with integrity extends to our suppliers. We direct supplier compliance through our Supplier Code of Conduct which is informed by the ³Ô¹Ï51±¬ÁÏÍø Code and other important public principles, such as the United Nations Global Compact. It is designed to align the ethical objectives and conduct of all of ³Ô¹Ï51±¬ÁÏÍø’s suppliers, all over the world, with the standards that ³Ô¹Ï51±¬ÁÏÍø applies to its own personnel. We expect each supplier to comply with the code’s principles, or comparable provisions of its own code of conduct, in all its dealings with us.

As technology advances, we are aware there are associated risks. ³Ô¹Ï51±¬ÁÏÍø is dedicated to keeping our employees and their data safe. Read about the actions we are taking to support Information Security.

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