GRI 205: Anti-corruption
Explanation of the material topic and its boundary
Ethical behaviour by our employees, agents and business partners is of critical importance to us. It is also a central element of our approach to responsible sourcing, which directs our compliance with high standards in health, safety, social, environmental and business integrity in the way we source.
We can be held responsible for our own actions as well as the actions of those associated with us and the penalties for violating bribery and corruption laws are severe. We also know that mere allegations of bribery or corruption can damage our reputation.
Our corporate governance systems ensure that our Company is managed in the interests of shareholders, including minority shareholders, and our management systems include checks and balances to control risk and oversee manageable accountability.
The basis for Givaudan’s ethical standards is laid out in the Company’s Principles of Conduct, last reviewed and updated in 2018. The Principles of Conduct consist of three pillars: Legal & Ethical Business Dealings, Responsible Corporate Citizenship and Protecting Givaudan’s Assets. These principles are supported and mirrored by Givaudan’s Responsible Sourcing Policy, a code of conduct for our suppliers to ensure that our partners abide by our high standards.
Anti-corruption compliance specifically is managed as part of the Givaudan compliance management system in the following ways: corruption is one of the risk areas regularly reviewed by the Corporate Compliance Officer as part of a compliance risk assessment; corruption and inappropriate gifts and entertainments are prohibited in Givaudan’s Principles of Conduct; Givaudan has included corruption and gifts/entertainment in its basic compliance training for all permanent employees and issues specific anti-bribery training to selected employees. Givaudan also discloses charitable contributions and sponsorship. In the case of acquisitions, we conduct pre-signing due diligence and full integration of acquired companies into the Compliance and Ethics Management system upon closing.
New mandatory compliance training on the updated Principles of Conduct was launched in 2017 to all Givaudan employees worldwide. For employees in the companies acquired over the past two years, we are in the process of rolling out classroom training on the same topics. The training material is available as online training in all major Company languages and includes material on anti-bribery, corruption and corporate social responsibility. The completion rate currently stands at 84%1.
As part of monitoring activities, the Compliance Helpline allows employees to report compliance issues in confidence. Givaudan has a procedure for the selection and engagement of agents and distributors. This includes a formal due diligence review and minimum requirements for agent contracts and payments.
1. The number reflects the completion rate of Givaudan entities only and the trainings are currently rolled out to recent acquisitions.
Communication and training about anti-corruption policies and procedures
Specific anti-bribery training also continued in Givaudan in 2019.
Since 2013, 5,847 Givaudan senior managers have been invited to complete this training. This group includes all members of the Executive Committee and other employees whose work involves regular and direct contact with external stakeholders. The completion rate currently stands at 97%.
For employees in the companies acquired over the past years, we are in the process of rolling out ethics & compliance training.