32 Policy and regulations
Policy and regulations We adhere to the highest ethical standards in the way we interact with all our stakeholders in all communities in which we operate. High ethical standards are essential to how we interact with all our stakeholders, everywhere – customers, suppliers, shareholders, employees, competitors, government agencies and the communities in which we operate. Being open, transparent and honest in our dealings with these stakeholders, presented in more detail in the following chapter, allows us to grow responsibly and share our success. Ethical behaviour by our employees, agents and business partners is of utmost importance: we can be held responsible for our own actions as well as for the actions of our agents, consultants and other business partners. Our corporate governance systems ensure that our Company is managed in the interests of shareholders and other stakeholders. Our management systems include checks and balances to control risk and oversee management accountability. The penalties for violating bribery and corruption laws are severe, including prison sentences and significant fines. We also know that mere allegations of bribery or corruption can damage our reputation. Our Principles of Conduct apply to all the employees of any Givaudan company across the world. Our expectations of business integrity also extend to our suppliers, who are expected to maintain the highest degree of business integrity as described in our Responsible Sourcing Policy. They must abide by local laws and international standards and conventions on bribery, gifts, entertainment and hospitality, money laundering, fraud, fair competition, confidential information and reporting. The implementation of such a comprehensive policy across a global network of suppliers is an enormous task, but we view the implementation of the policy as an opportunity to transform the supply chain. Our approach is to work hand-in-hand with the suppliers to help them achieve compliance with the requirements. Givaudan’s Responsible Sourcing Programme aims to implement the policy while encouraging supplier leadership and fostering supply chain innovation.
Givaudan – Our Sustainability Approach
Finally, in terms of product and service labelling, our Regulatory and Product Safety teams provide the critical information that enables customers around the world to use our products in the knowledge they are safe and compliant for the intended use.
Anti-corruption
Keeping our business free from corruption issues is a key concern to Givaudan. It reflects the high ethical standards that are the basis of our DNA. Most countries where we operate also have anti-bribery laws. Some of them apply even extraterritorially, such as the UK Bribery Act, the US Foreign Corrupt Practices Act or the French Loi Sapin II. Noncompliance with these and other anti-corruption laws may expose us to fines and reputational damage, which may lead to loss of customers. Anti-corruption compliance is managed as one of the compliance risk areas within our Compliance Management System as follows: Policies Our Principles of Conduct, last updated in 2018, state that Givaudan has zero tolerance of bribery and corruption and do not make facilitation payments. This principle is further detailed in two policies: 1. Givaudan’s Global Anti-Bribery, Gifts, Entertainment and Hospitality policy, first enacted in 2011 and last amended in 2018 to take into account recent changes in French anticorruption law (Loi Sapin II) includes prohibitions on corruption, bribery, inappropriate gifts as well as mechanisms for approval and reporting of gifts, entertainment and hospitality. 2. Global Charitable Giving and Community Support policy, also last amended in 2018 to reflect the French Loi Sapin II, provides mandatory guidelines of permitted charitable causes, due diligence on recipients and reporting. The Principles of Conduct, as well as the two policies are available to employees in all major Company languages. Compliance Risk Assessment Corruption and bribery risks are regularly reviewed by the Corporate Compliance Officer as part of a compliance risk assessment, which is done at local and corporate level. The results are presented to the Executive Committee, the Audit Committee and the Board of Directors.
