Conducting business ethically and responsibly

Ethical business conduct and compliance with local, national and international legislation are fundamental to our way of doing business. We have a clear set of values that we expect all our employees to own and live by. These are to be caring, challenging, trusted, responsive and tenacious. Everything we do is aligned to these values. Code of Conduct

Our Code of Conduct describes expectations that apply to all our employees, providing guidance on our approach to ethical business practices, human and labour rights and the environment. It is made available to employees as part of their induction and has been translated into 27 languages. All employees are encouraged to report suspected misconduct, non-compliance or unethical behaviour.

Freedom of association

It is a fundamental right of employees to have the freedom of association and collective bargaining. In our Code of Conduct, we state that we recognise and respect the rights which employees have under local and transnational laws, including, where applicable, the right of employees to collective representation and bargaining. Employees will not be subjected to any detriment because of their involvement in legitimate trade union activities. In 2020/21, c. 85 per cent of our global workforce were covered under collective bargaining agreements. Our European Works Council (EWC) provides a forum for information sharing and consultation. Information about this can be found in DS Smith Annual Report 2021.

Human rights

Our most recent materiality assessment identified human rights as a foundation topic. We are therefore conducting a Human Rights Impact Assessment (HRIA) to identify, understand, assess and ultimately address potential adverse effects of business activities in our supply chain on human rights. In 2020/21, we planned and scoped our HRIA, selected a partner and identified key stakeholders to involve. In 2021/22 we will implement the high-level assessment, which will highlight the parts of our business with the greatest risk to human rights. Following this, clear actions to manage and mitigate these risks will be identified and addressed. In 2020/21, there were no known breaches of human rights, including incidents of violations of the rights of indigenous peoples.

Political donations

No political donations were made in 2020/21 (2019/20: nil). DS Smith has a policy of not making donations to political organisations or independent election candidates or incurring political expenditure anywhere in the world, as defined in the Political Parties, Elections and Referendums Act 2000. Speak Up!

Our Speak Up! policy is communicated to all employees via our employee handbook. It encourages employees to ask for advice or raise their concerns internally about unethical behaviour and explains the various internal grievance channels: reporting via line manager or local HR, internal email address direct to Company Secretary, Speak Up! telephone number or website, or reporting via local representatives of the European Works Council. Speak Up! is available not only to employees, but a range of other third parties. It is supported by an independent, 24/7 telephone number and website that is available in local languages. Confidentiality is maintained throughout the whole process and reasonable steps are taken to ensure that the reporter is not subjected to any retaliation from raising the report. In 2020/21, 25 (2019/20: 33) reports were received, investigated and resolved through our Speak Up! processes.

Tax strategy

We aim to manage our tax affairs in a proactive and responsible way. Our Group Tax Strategy outlines the approach we adopt to manage the tax obligations and activities of the Group.

More information and policies • Anti-Bribery and Anti-Corruption Policy • Code of Conduct • Modern Slavery Policy • Modern Slavery and Human Trafficking Statement • Speak Up! Policy • Tax Policy