Ethics and compliance
Elopak’s global footprint exposes the company to different cultures, values, and conditions. Responsible business conduct is the foundation for our license to operate and ensures we are recognized as a trusted company.
This entails respecting human and labor rights, having measures in place to combat corruption, and complying with applicable laws and regulations. One of the most important governing documents is Elopak’s Code of Conduct, whose purpose is to ensure that as a global organization, we always act with integrity and in accordance with acceptable ethical standards, always take responsibility for our actions and that we comply with international and local laws and regulations.
Approach
Group Legal and Compliance is responsible for Elopak’s compliance program. The department has a key role in managing risks related to corruption, fraud, human rights, competitive information, and our business partners.
As part of our compliance governance model, we have established an Ethics and Compliance Council, chaired by the Chief Legal and Compliance Officer and attended by senior management and personnel in different regions and business areas. The Council meets at least twice a year to ensure an holistic and cross-functional approach to managing and coordinating various compliance risk areas and facilitating efficient implementation across Elopak. Our compliance network supports the implementation of compliance in the line through raising awareness, facilitating training, and providing general guidance. The network consists of Elopak’s compliance champions, which are selected representatives from our different regions and specific business areas.
The purpose of Elopak’s compliance program is to promote a culture of ethical and responsible business conduct. It is designed to prevent, detect, and respond to breaches of laws, regulations, or internal policies, i.e., non-compliances and misconduct. The compliance program is proportionate and risk-based, and consists of the eight elements illustrated in the figure below.
Further details on prioritized compliance program elements
(2) Risk assessment
- Elopak has a risk-based approach to compliance. An annual compliance risk assessment is conducted where identified risks are evaluated and mitigated where appropriate. Types of risks taken into consideration are corruption, business partners, sanctions, competitive information, and human rights. During 2021 we conducted deep dives in four main risk areas and performed mitigating actions.
- The risk assessment is based on existing legislation and trends in legislation, input from the annual internal Ethics and Compliance Survey, types of reported concerns, and other internal and external input.
- There are multiple contributors to the compliance risk assessment. Legal and Compliance, the Executive Management Team, and stakeholders in the various staff- and business areas provide input on specific risks and mitigating actions. Going forward, the annual compliance risk assessment will be conducted through workshops with the Ethics & Compliance Council.
- The risk assessment is continuously monitored and updated when the risk situation changes.
(3) Governing documents
- Our Code of Conduct reflects our commitments and requirements for how we do business in Elopak. The Code of Conduct applies to all employees, the Board, and those who act on behalf of or represent Elopak. We expect our suppliers to uphold similar standards and act consistently with the requirements set out in our Code of Conduct. This is detailed in our Global Supplier Code of Conduct. To help us apply the Code of Conduct in our daily work, we have developed related policies and procedures, providing more detailed guidance on compliance requirements. The employees receive annual, mandatory ethics and compliance training through our PureEthics training. This is our Code of Conduct and Anti-Corruption Policy e-learning program, and we developed an in-depth dilemma training workshop concept for selected target employee groups. Elopak’s standard employment contract includes our Code of Conduct, which new employees must sign and confirm they comply with. The Code of Conduct document and training material are available in several languages to ensure we reach out to all our employees.
- Our Code of Conduct is explicit on our zero-tolerance of engaging in bribery and corruption. Elopak’s compliance program includes policies and procedures to comply with anti-corruption and anti-bribery legislation, uphold high ethical standards through preventive and detective measures, and mitigate risk through responsive actions. We have a global network of compliance champions (compliance network) who support the business in compliance issues. Annual mandatory anti-corruption training is provided.
- Elopak has developed clear policies and procedures against non-compliance with laws and regulations where we operate. In 2021, we strengthened our governing documents with new or updated policies and procedures, focusing specifically on our business partner procedure (due diligence), sanctions compliance policy, conflicts of interest procedure, gifts and hospitality procedure, speak up policy, and whistleblowing and internal investigation procedure. These governing documents will be rolled out in the organization in 2022.
(7) Speak up, issue reporting, whistleblowing, and investigation
- Employees and external stakeholders are expected to report suspected violations of Elopak’s Code of Conduct, internal policies and/or laws and regulations.
- Employees should contact their line manager when possible. Concerns can also be reported through the Elopak whistleblower helpline, which describes how one can report via phone, e-mail or online. Reported concerns can be sent anonymously through the latter channel which is currently available in eight languages.
- Our whistleblowing and internal investigation procedure establishes guidelines and responsibilities for reporting and investigating concerns. The procedure ensures a standardized and efficient process to handle investigations where confidentiality and protection of the individuals reporting are critical.
- Elopak does not tolerate retaliation against anyone who speaks up.
With a global footprint comes corresponding responsibilities. We are dedicated to responsible business conduct in our operations and throughout our value chain.
Hanne Langård, Compliance Manager
Performance
Targets
All Elopak employees to understand overall compliance risks and requirements for expected behavior
KPIs | KPI reference |
a) % completed COC training b) # reported concerns per category | GRI 205-2 GRI 205-3 GRI 406-1 |
Status 2021 | |
a) 68% total 88% line managers 89% level 2 management 100% top management b) 3 reported concerns |
In 2021, 68% of employees completed the Code of Conduct training, PureEthics. This is an increase of 21% from 2020. During 2021, we revised our Code of Conduct to strengthen important topics and clarify our commitments and expectations. The Code of Conduct was approved by the Board in December 2021 and will be rolled out to the organization in 2022.
PureEthics completion 2021
Employee group | Number | Percentage (%) |
Top management | 9 | 100 % |
Level 2 management | 45 | 88% |
Line managers | 196 | 88 % |
Employees | 1 178 | 65 % |
Grand total | 1 429 | 68 % |
Three concerns were reported through Elopak’s whistleblowing channels in 2021. According to external benchmarks, reported whistleblower issues tend to hover round 1% of the total employee population[1], indicating that the number of reported issues in Elopak is low.
[1] According to Navex Global’s Regional whistleblowing hotline benchmark report 2021
Moving forward
In 2022, the revised Code of Conduct will be rolled out in the organization and new training will be provided to all employees to reflect the changes in scope. The Ethics and Compliance Survey in 2021 provided feedback from the employees on the training and awareness for ethics and compliance. In addition, the survey retrieved input concerning Elopak’s speak-up culture and training in compliance focus areas. Based on this insight, Legal and Compliance will strengthen its efforts regarding awareness and accessibility of the whistleblower helpline, build faith in our reporting and internal investigation procedures, and strengthen our speak-up culture. Going forward, we will accommodate compliance training based on the feedback received from the organization.
