Compliance

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 confidential whistleblowing system are investigated and number of cases reported in 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 which 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.
• Speaking Up and reporting concerns incl. the whistleblowing channel.

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.

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.