Ethics and compliance

Preventing negative impacts of corruption

As a global corporation, we are committed to complying with all applicable local and international anti-corruption laws. At Huhtamaki, all forms of corruption and bribery are strictly prohibited, irrespective of the location of our operations.

The Huhtamaki Anti-Corruption Program ensures that we are taking needed steps to mitigate and manage corruption risks in our operations and across our value chain. Anchored by the Huhtamaki Anti-Corruption Policy, it includes related instructions and procedures that support our business and educate Huhtamaki employees so they can make informed decisions when interacting with business partners. This includes:

• Definitions of different forms of corruption
• Guidance and procedures for disclosing and managing actual and potential conflicts of interest
• Rules for offering and accepting gifts and hospitality
• Rules for contributions, charitable donations and sponsorships
• Rules on how to act in high-risk situations where due care is required such as when interacting with government officials, when dealing with third parties or when planning mergers and acquisitions
• Roles and responsibilities for management and accountability of anti-corruption matters at Huhtamaki
• Contact information for questions or concerns related to corruption

Focusing on sanctions risks

Due to the global nature of our business, we are committed to following all national and international sanctions and export control regulations applicable to us. 

The Huhtamaki Trade Sanctions Compliance Program is guided by our Huhtamaki Trade Sanctions Compliance Policy. The policy and related procedures support our business and educate Huhtamaki employees by setting out: 

• Huhtamaki’s trade sanctions compliance principles 
• Sanctions screening procedures to all Huhtamaki entities that engage in exports/imports that pose sanction risks 
• Roles and responsibilities for management and accountability of trade sanctions compliance matters at Huhtamaki 
• Contact information for questions or concerns related to trade sanctions or export controls 

Respecting privacy 

As part of our business, we collect, store, transfer, and otherwise process several types of personal data concerning different data subjects such as our employees or Huhtamaki business partner representatives. Any processing of such data is governed by data protection laws and regulations. At Huhtamaki, we comply with applicable data privacy laws to keep the personal data we process safe.  

Huhtamaki Data Privacy Program is guided by our Huhtamaki Data Privacy Policy. This Policy supports our business and educates Huhtamaki employees by:  

• Explaining data protection principles applicable to any processing of personal data 
• Providing rules to assess risks associated with different data processing activities
• Defining the rights of data subjects
• Providing a process for personal data breaches
• Giving contact information for questions or concerns related to data privacy 

Competing fairly in all our markets

Competition benefits businesses, customers and the economy, and therefore we compete fairly and honestly. At Huhtamaki, any activities that could distort free competition are prohibited. We strictly comply with antitrust laws and competition regulations. 

The Huhtamaki Competition Compliance Program is guided by our Huhtamaki Competition Compliance Policy. The policy supports our business and educates Huhtamaki employees by: 

• Explaining different forms of anti-competitive practices 
• Providing practical rules to ensure fair competition across Huhtamaki’s value chain 
• Offering best practices for risky situations, such as when participating in industry or trade association meetings or when interacting with competitors 
• Setting accountability and defining roles and responsibilities for management of competition compliance matters at Huhtamaki 
• Giving contact information for questions or concerns related to anti-trust and competition compliance 

Discussing matters before they become issues

In accordance with Huhtamaki’s values, we promote a culture of open discussion where we encourage everyone to voice their concerns, provide their feedback, ask questions, and make suggestions without fear of harm or retaliation. We aim to discuss matters – including difficult ones – before they become issues.

Huhtamaki maintains multiple channels for voicing concerns. In cases of suspected misconduct, unethical behavior or observed violations of the Huhtamaki Code of Conduct or other Huhtamaki policies, laws and regulations, employees can report to their manager, over manager, legal counsel, Human Resources representative, or the Global Ethics & Compliance team directly.

In cases where direct reporting is not possible or preferred, suspected violations can be reported through the Huhtamaki Speak Up Channel.

Our Speak Up channel is available to all Huhtamaki employees, suppliers, customers and other stakeholders. Additionally, in some countries, reports can be submitted via local reporting channels. Reporting can be made anonymously when permitted by the local legislation.

Retaliation or any negative actions against an individual reporting a suspected violation in good faith is explicitly prohibited and may result in disciplinary action.