Ethics and compliance
We Care Dare Deliver – with integrity. We are committed to foster an atmosphere of openness and transparency and maintaining the highest ethical standards in everything we do. We see compliant and ethical business conduct as responsible leadership and something that is relevant for all our employees and in every business transaction we are involved.
Our commitment to Ethics and Compliance
The Huhtamaki Global Ethics and Compliance program focuses on Huhtamaki’s commitment to integrity and legal compliance across our global organization. The program serves as a toolkit supporting Huhtamaki in conducting its business in compliance with laws, regulations and our ethical standards and ensuring that we have adequate procedures in place to prevent Huhtamaki taking part in any unethical business activities.
The main purpose of our compliance work is to enable and inspire all our employees to make the right decisions and to foster an open and ethical company culture. We strongly believe that conducting business with integrity is the right thing to do, and it is also our license to operate.
Read more below about the different elements of our compliance work.
A dedicated Global Ethics and Compliance function, which sits within our Legal team, has the overall responsibility for ensuring that our Global Ethics and Compliance program is designed and developed to meet Huhtamaki’s needs, and that related support and training is provided to the whole organization. It is an advisory function that supports Huhtamaki in conducting its business in compliance with laws, regulations, and Huhtamaki’s values and ethical standards by advising in certain key areas, such as anti-corruption, supply chain transparency, trade compliance, conflict of interest situations, competition compliance and data privacy related matters.
In addition, the Global Ethics and Compliance function helps our business to create policies and processes to identify and mitigate compliance risks and organizes trainings on various ethics and compliance topics. Furthermore, Global Ethics and Compliance is responsible for our whistleblowing system, the Huhtamaki Speak Up channel. The implementation of the program is reported to and followed up by the Huhtamaki Global Executive Team and the Audit Committee of the Board of Directors.
The Huhtamaki Code of Conduct is the core element of our Global Ethics and Compliance program and the basis for everything we do. The Code is a set of ethical guidelines that outline the expected behavior of all employees and defines how we treat each other, do business, and engage with our stakeholders. It also explains how we conduct our business in an ethical and responsible manner in order to earn the trust of our customers and other stakeholders.
We strive to ensure that all of our employees understand what ethical business conduct means and know how they should respond to any ethical dilemmas that may arise. All Huhtamaki employees are required to complete the Code of Conduct online training annually.
The Code of Conduct for Huhtamaki Suppliers sets out the ethical business practice requirements we expect from our suppliers and other business partners. The Code for suppliers covers areas such as business ethics, social responsibility but also environmental commitments and expectations toward our suppliers.
We operate in 38 countries and 79 sites around the world, including high-risk markets that offer good business opportunities but may also entail exposure to serious compliance risks such as bribery and corruption. As a global corporate citizen, we are committed to the laws and regulations of the countries where we operate, but also applicable international laws and regulations. At Huhtamaki, we have zero tolerance for corruption, and bribes and corrupt practices are not allowed anywhere in our operations, regardless of location.
Anti-bribery and corruption provisions are an integral part of the Huhtamaki Code of Conduct with which all our employees globally are expected to comply with. In line with the Codes of Conduct, we do not award donations to political parties or political activities, religious organizations, authorities or local administrations. Our annual Code of Conduct training contains an anti-corruption section and provides practical guidance and examples for ethical decision making for all Huhtamaki employees. In addition, these provisions are included in the Code of Conduct for Huhtamaki Suppliers, which sets the minimum principles we expect also our suppliers and contractors to uphold. Ethics and business integrity requirements, including anti-corruption and zero tolerance for bribery and corrupt practices, are also an integral part of Huhtamaki Working Conditions Requirements.
Huhtamaki conducts business globally, including countries with higher compliance risks. Our Group Trade Compliance Policy highlights our commitment to compliance with all applicable national and international trade compliance laws and regulations, including international sanctions and export control regulations. The Policy sets out the trade compliance principles and expectations and requires all Huhtamaki entities that engage in exports directly or indirectly with a country identified as a risky country to follow sanctions screening procedures before entering into business transactions.
In accordance with Huhtamaki values, we promote a speak-up culture and encourage everyone to raise their concerns and to report any suspected or observed violations of the Huhtamaki Code of Conduct, any other Huhtamaki policies or laws and regulations. In effect this means that if the employee has concerns about potential misconduct by
colleagues, managers, suppliers, customers, other business partners, or about how we conduct business within Huhtamaki, the employee is expected to report the violation by contacting either his or her manager, a local Human Resources representative or Global Ethics and Compliance directly.
Alternatively, the employee can report any suspected violation through the Huhtamaki Speak Up channel, which is a global, webbased whistleblowing system operated by an external provider and managed by Huhtamaki Global Ethics and Compliance. Our Speak Up channel is available for Huhtamaki employees, suppliers, customers and other stakeholders, and can be accessed by visiting the website: https://report.whistleb.com/Huhtamaki.
Additionally, in some countries, reports can also be submitted through local reporting channels. Retaliation or any negative actions against an employee reporting a suspected violation in good faith is explicitly prohibited and may result in disciplinary action.
All breaches and suspected breaches of the Huhtamaki Code of Conduct, any other Huhtamaki policies as well as laws and regulations brought to the attention of Global Compliance are investigated in accordance with the Group Investigations Policy providing a mechanism for investigating and addressing alleged violations in a structured and timely manner.