Our commitment to compliance and integrity
Responsible business conduct is the foundation of our license to operate. We in Elopak take this responsibility very seriously. As a global company, it is our policy to act in accordance with applicable laws and regulations and high ethical standards across our value chain. We build and maintain trust of one another, our customers, business partners and communities where we operate by working responsibly and safely, caring for environment, acting with integrity, treating others with respect and honoring our commitments.
Our Code of Conduct
Elopak’s Code of Conduct reflects our commitment to applying ethical business practices and legal compliance throughout our global organization wherever we operate and conduct business on behalf of Elopak. To help us apply the Code of Conduct to our daily work, we have developed related policies and procedures to provide more detailed guidance on compliance requirements. Our Code of Conduct, supported by policies among others Anti-Corruption Policy and procedures, reinforces our commitment to integrity and compliance and sets expectations for the highest ethical standards for us all and it is implemented and followed- up by Elopak’s compliance system.
Our compliance system
Our compliance system is based on a clear governance structure defining roles and responsibilities regarding compliance and compliance-related activities undertaken throughout the company.
The progress of compliance program actions as well as any non-compliance matters reported through the line or via the whistleblowing system are addressed in the management meetings and Board meetings and an annual compliance report to the Board of Directors.
Compliance is a line responsibility in Elopak supported by the relevant corporate staffs. To enhance the efforts on providing guidance and implementation of the compliance system, Elopak established a role of Chief Compliance Officer (CCO) some years ago. CCO reports to the Group CFO and additionally has an independent reporting line to the Board of Directors through the Board Audit and Sustainability committee.
Our compliance system is designed to help us promote a culture of ethical and responsible business conduct, and prevent, detect and respond to breaches of laws, regulations or internal policies (non-compliances/ misconduct). Key elements of our compliance system include:
- Elopak Compliance program
- Working with Business Partners
- Speaking Up and reporting concerns incl. the whistleblowing channel.
Compliance program
The compliance program is our tool to ensure a structured approach, monitoring and follow-up. Our program is based on best practice principles for managing compliance programs given by external regulators and market standards. The main goal of the program is to continuously uphold our business ethics and compliance culture.
Elopak implemented an annual, mandatory compliance training for all employees called PureEthics. This is our Code of Conduct and Anti-Corruption Policy e-learning program in order to continuously focus on ethical behavior and compliance. A more in-depth dilemma training workshop concept has also been developed for selected target employee groups.
PureEthics completion 2020
|
Employee group |
Number |
Percentage (%) |
|
Top management Management Employees Grand total |
9 238 952 1198 |
100% 88% 51% 56% |
Working with business partners
Elopak’s success is dependent upon cooperation from our business partners – suppliers, customers, sales agents, distributors or joint venture partners and others. Our business partners are expected to comply with all applicable laws and regulations. Suppliers that have a direct contractual relationship to Elopak have to adhere to the principles and expectations set out in our Global Supplier Code of Conduct which sets out the minimum standards in key areas including among others business ethics and anti-corruption, as well as human rights, labour conditions and environmental and social aspects. We carry out risk-based due diligence processes to ensure that the business partners’ reputation, background and abilities meet our standards.
In accordance with the UK Modern Slavery Act we publish a transparency statement (read here). Please find more information on Elopak’s Responsible Supply Chain here.
Results
Elopak’s anti-corruption policy and the Code of Conduct have been communicated to all employees. Elopak’s governing documents in this area are easily available to all emloyees on Elopak’s intranet and to all other stakeholders on Elopak’s external website. Additionally, these policies are communicated annually through our online mandatory compliance training PureEthics. All employees are asked to complete this annually.
In 2020, 100% of the Group Leadership Team (9 out of 9) completed the PureEthics training program. Of the total workforce, 56% (1198 out of 2133) completed the training in 2020. The number is higher for corporate/office functions (see more details in the data table here). We will further enhance the importance of all employees completing the program annually, and improve procedures to implement this during 2021.
Our Anti-corruption Policy has been communicated to 100% of our business partners, specifically including: sales agents (7), licensees (2), distributors (4) and JV partners (3). Anti-Corruption policy and compliance standards requirements are communicated via contractual clauses including in the contracts with all our business partners as specified here.
Speak Up and reporting concerns
Elopak is committed to building a culture of trust where employees are comfortable to ask questions, seek guidance raise concerns and report suspected violations.
Employees and external stakeholders are encouraged to report suspected or actual breaches of laws and regulations or cases of misconduct and unethical business conduct. Such reporting can be done through the line management or through Elopak’s whistleblowing channel. The whistleblowing channel permits a secure and confidential reporting option. Elopak’s whistleblowing channel is managed by an external professional service provider. The service provided ensures that Elopak employees and external stakeholders can report their concerns anonymously with no ability to trace back to the notifier. Elopak takes all reported concerns seriously and internal investigations are carried out as required. Elopak has zero tolerance for retaliation against whistleblowers who raise concerns in good faith. All reported cases are taken seriously and carefully followed-up and investigated as needed.
In 2020, there were no confirmed incidents of corruption in Elopak. There were no confirmed incidents of corruption, and no contracts with business partners were terminated due to cases of confirmed corruption or other material compliance violations. There were no public cases regarding corruption brought against Elopak or its employees during the reporting period.