66 Good governance High ethical commitments protect our reputation
High ethical commitments protect our reputation Our Principles of Conduct By acting in line with our Principles of Conduct we preserve Givaudan’s good name and reputation, which we have built with our partners over a long and rich history. The ethical commitments in our Principles of Conduct – the cornerstone of our Company culture – are developed around three pillars: Legal & Ethical Business Dealings, Responsible Corporate Citizenship and Protecting Givaudan’s Assets. There is an additional section, ‘How we live the Principles’, which reiterates our employees’ responsibility for ethics and integrity and explains ways of reporting any violation of the Principles, including a worldwide Compliance Helpline. The Principles of Conduct are supported and mirrored by Givaudan’s Responsible Sourcing Policy, a code of conduct for our suppliers, to ensure our partners abide by the same high standards we do. The Responsible Sourcing Policy includes a mechanism to report grievances.
Givaudan’s Principles of Conduct
Legal & ethical business dealings
Compliance with the law and Givaudan policies Bribery and corruption Gifts and entertainment Competition law Insider dealing Conflicts of interests Ethical conduct
Responsible corporate citizenship
Human rights Preserving the environment Diversity and fair treatment Fair employment standards and safe work environment Child labour
Protecting Givaudan’s assets
Fraud against Givaudan
The Principles of Conduct, as well as policies specifying any principle, are available in all major Company languages.
Organisation and process The Ethics and Compliance Programme is based on the compliance and fraud prevention concept of ‘prevent – detect – respond’. The Corporate Ethics & Compliance Officer oversees the administration of this programme and coordinates with other dedicated functions for effective compliance management. This is further enhanced by a global compliance team and network of local compliance officers and regional compliance coordinators. Regular compliance risk assessments are carried out by the Corporate Ethics & Compliance Officer with local compliance officers and corporate functions. In addition, a Group Data Protection Officer oversees the implementation of the Group Data Protection programme. The Company has a Group-wide Compliance Helpline system which allows employees to report suspected or actual misconduct or violations of the Company’s policies on a confidential basis and without fear of retaliation. We also have a mechanism as part of our Responsible Sourcing Policy to allow suppliers to bring grievances to our attention. We also have a compliance incident investigation procedure and process in place for investigations of compliance allegations received through any channel. Depending on the nature of the allegations, these cases are handled either locally or centrally. Where required, external specialist support is sought. Other compliance processes include the selection and engagement of third-party agents and distributors and the global supplier selection process of the Procurement organisation. The Corporate Ethics & Compliance Officer reports regularly to the Board of Directors, the Audit Committee of the Board, the Executive Committee and the CEO.
Open communication Protection of confidential information and trade secrets, intellectual property Conduct in research, development, application and creation
Givaudan – 2019 Integrated Annual Report
Dedicated corporate functions ensure the management of compliance with specific areas of operational compliance risk such as product safety/regulatory, procurement, trade affairs, environment, and occupational health and safety.
