Act with Responsibility

We are committed to conduct our activities in a financially, environmentally, and socially responsible way with transparent business practices and high ethical standards.

Responsibility

POLICIES

Gifts policy

Anti-corruption policy

Fair competition policy

IPR policy

Procurement policy

Trade compliance policy

Human rights policy

Modern slavery policy

Whistleblower policy

Privacy policy

Supplier Code of Conduct

Tax policy

TARGETS

2023

Alignment of the compliance structures with new acquisitions (PACCOR and MCP USA)

2025 Local compliance risk assessments carried out for each site

· Implement procedures to comply with EU’s Corporate Sustainability Reporting Directive and EU’s Corporate Sustainability Due Diligence

We are an international organisation committed to act as a proper and responsible group at all times, and we have imposed strict requirements on ourselves, including our employees, officers and directors, as well as our business partners, through internal and external policies and guidelines.

Training in fair competition, anti-corruption and GDPR

We actively support international and national anti-corruption and fair competition efforts, and we are dedicated to upholding the highest standards of integrity and business ethics among our employees and business partners.

We have a zero tolerance against corruption and anti-competitive behaviour.

By implementing and sending out guidelines, policies, e-learning courses and conducting onsite training for officers and employees, we actively fights inappropriate business conduct.

In 2022, 134 employees were trained on-site in anti-corruption and fair competition. A total of 398 employees have received on-site training, including the majority of our officers, directors, managers, sales and procurement personnel. To obtain a beneficial face-to-face dialogue, the on- site training of employees is often held in smaller groups of 5-15 employees.

In addition, a total of 666 employees have completed the e-learning training course in anti-corruption law, and 300 employees have completed the e-learning training programme in competition law. Our PACCOR colleagues did not have this training previously, which explains the relatively low number. The training will be rolled out in 2023 to all relevant employees. The training enables our employees to e.g., execute business negotiations, attend meetings and social events with knowledge and understanding of basic competition law and anti-corruption law in order to protect both themselves and Faerch against prosecution while contributing to upholding a fair and healthy market.

At Faerch, we also process personal data in different areas. To support our officers’ and employees’ understanding of personal data and how to deal with it, Group Legal has implemented a GDPR e-learning course. In 2022, 707 employees have completed the GDPR e-learning course.

Furthermore, Group Legal has prepared several GDPR procedures to ensure basic data subject rights, e.g., the right to access one’s own personal data, the right to rectify one’s personal data, the right to erase one’s personal data. Any such requests from data subjects will be handled and answered by Group Legal.

We have also prepared policies and established technical and organisational measures to ensure i) that personal data is not accidentally or illegally destroyed, lost or changed, ii) that unauthorised persons do not get access to personal data and iii) that personal data is not processed in breach of GDPR in any other way.

Overall, personal data is deleted when storage of such is no longer needed for the intended and legitimate purposes.

In 2023, Group Legal will continue to focus on overseeing and improving Faerch’s compliance programmes, including policies and internal guidelines on fair competition, anti-corruption and GDPR as well as sanctions, while also focusing on integrating the same principals to PACCOR and MCP USA.

Whistleblower scheme

Our governance programme is designed to identify and prevent serious offences and criminal acts. However, even the most effective compliance procedures cannot fully protect against every conceivable situation.

Consequently, we have implemented a whistleblower scheme in co-operation with a renowned Danish law firm enabling employees, business partners (such as customers and suppliers) and other third parties to report suspicions or knowledge of unethical and/or criminal conduct (on anonymous basis if so desired). The whistleblower scheme includes whistleblower units on entity level. It is ensured that investigators in whistleblower units are – and remain - impartial. If, during the law firm’s and the first whistleblower unit’s investigations and assessments, it is ascertained that a whistleblower filing should be further dealt with, such filing will be reported to impartial members of management for further assessment and action.

The whistleblower scheme was launched in December 2018 and was updated in 2021 pursuant to new EU whistleblower legislation that came into force on 17 December 2021. The whistleblower scheme can be found on our websites. Employees have been informed hereof during compliance training sessions, in internal announcements and in introduction programmes. In 2023, we will look into ways of improving the whistleblower scheme due to a relatively low number of cases being reported to make sure it functions properly.

Supplier Code of Conduct

Faerch conducts business in a conscious way and follows the ten principles of the UN Global Compact. To ensure that our suppliers adhere to the same standards and guidelines as we do, Faerch has developed a ‘Supplier Code of Conduct’.

The ‘Supplier Code of Conduct’ thus reflects the same ten principles as the UN Global Compact which covers human rights, labour rights, the environment and anti-corruption and was updated with improvements in 2022.

Each site director and/or relevant group function of Faerch Group is responsible for ensuring that new suppliers sign Faerch’s ‘Supplier Code of Conduct’, while also ensuring that all signed Code of Conducts are stored within Faerch.

Further, we recognize our responsibility to continuously improve the quality and effectiveness of our human rights, labor rights, environmental and anti-corruption due diligence across operations and business relationships.

In 2022, PACCOR implemented a Supplier Onboarding Process with the purpose of obtaining (additional) relevant information for the due diligence which will e.g. help to secure fundamental human rights and labor rights and thereby proctecting workers in the value chain. This will in 2023 be rolled out to the entire Group.

Data ethics

The responsible use of data is an enabler for Faerch’s business model. In line with our core values we strive to ethically manage and use data, with customers trusting that the company uses their data appropriately. To avoid abuse and privacy infringement issues, and to safeguard the company from legal, business and reputational risks, it is vital to manage and control the storage and use of customers’ and employees’ data ethically and proactively. No formal data ethics policy has been adopted yet due to the strong existing data governance, but in context of the recent acquisitions and as part of the sustainability priorities Faerch will establish a formal data ethics and security policy in 2023, with accompanying governance measures.

Reported cases about corruption

Reported cases about unfair competition

Reported cases about gifts over EUR 200

Reported cases in our whistleblower solution