Governance & ethics

We expect everyone working with us to act with integrity, always.

Integrity is one of our core values. Operating ethically and adopting fair business practices is fundamental to our responsible culture, essential to comply with applicable laws and regulations, and critical to protect our reputation and maintain stakeholder trust.

Our commitment

We are committed to acting professionally and with integrity in everything we do, abiding by the ethical principles set out in the SIG Code of Conduct which include:

• Ethical and legal behaviour
• Fair, courteous and respectful treatment of fellow employees and others with whom we interact
• Fair and appropriate consideration of the interests of other stakeholders (customers, business partners, government authorities and the public) as well as of the environment
• Professionalism and good business practice.

The SIG Code of Conduct, approved by the SIG Board of Directors and detailed by policies on specific topics, sets out our expectations on topics such as anti-bribery and anti-corruption, avoidance of conflicts of interest, anti-trust and fair business practices, privacy and data protection, human rights compliance, equal employment opportunity, anti-harassment and anti-discrimination, and political and charitable activities.

Our zero-tolerance approach to bribery or corruption in any form is included in the SIG Code of Conduct and our Anti-bribery and Anti-corruption Policy, and reinforced through training.

All employees are trained on the SIG Code of Conduct as part of their induction when they join the business and are expected to complete mandatory refresher training every year.

We encourage people to speak up if they have any questions or concerns, without fear of retaliation, via their line managers, Human Resources teams, global and regional Legal and Compliance officers, or our confidential Integrity & Compliance Hotline (anonymously where permitted by local legislation). We are committed to investigating all concerns and taking appropriate action, including, but not limited to, disciplinary measures.

Our target

Our progress

In 2022, we rolled out training on the SIG Code of Conduct to the employees we welcomed through acquisitions during the year. Mandatory annual compliance certification continued for all employees, as well as additional training for those in high-risk roles, and we raised awareness of our Integrity & Compliance Hotline to encourage people to speak up if they have any concerns. We also introduced several new and updated policies that offer further guidance on key compliance topics, as well as on remaining vigilant on information security.

Performance in 2022

Updating our policies

• As we integrated operations in new countries, we checked that the SIG Code of Conduct was available in relevant languages and translated it where needed. It is now available in 19 languages.
• We introduced policies offering detailed guidance on the topics of anti-trust and trade and sanctions compliance. We implemented a revised Anti-bribery and Anti-corruption Policy – which includes our policies on gifts and entertainment, as well as political and charitable donations – and we updated our directive on handling of personal data. We also began rolling out our new Supplier Code of Conduct to new and existing suppliers in place of the previous SIG Business Ethics Code for Suppliers (see Responsible culture: our supply chain).

Training our people

• 99%¹ of SIG Group employees (including virtually all of those joining us through integrations this year) completed their annual certification on the SIG Code of Conduct, which includes topics such as anti-bribery and anti-corruption.
• More than 6,300¹ employees completed additional training on the SIG Code of Conduct. This training was offered through video and in-person sessions for employees without regular access to computers at work. We also provided in-depth training for employees in high-risk roles on topics such as anti-bribery and anti-corruption, anti-trust, data privacy and anti-harassment.
• We continued to raise awareness on ethics and compliance topics through various channels, including internal newsletters, emails, local campaigns and posters advertising our Integrity & Compliance Hotline.

Investigating and acting on concerns

• Concerns reported via our Integrity & Compliance Hotline and other channels in 2022 mainly related to workplace and employment-related matters.
• We investigated all concerns and took disciplinary action, including reprimands and dismissals, where appropriate.
• No cases of corruption were substantiated in 2022.

Maintaining ethical standards

• All our aseptic carton production sites, our office site in Mexico and several of our legal entities in Germany and Switzerland completed SEDEX SMETA audits – which include business ethics as one of the four pillars – in 2021. The next scheduled two-yearly audits in 2023 will also include the production plants we acquired this year.

Focusing on security

• We achieved certification to the international ISO 27001 standard on information security management for SIG IT in Germany, China and Romania. We also launched a new security acceleration programme to further bolster our security posture.
• 99%² of employees completed security awareness training this year. We reinforced the training through our internal communications with reminders of how to guard against cyberattacks, such as vishing (voice phishing), which are on the rise.

1 Includes employees joining SIG from Scholle IPN and Evergreen Asia, both acquired in 2022.

2 Includes employees joining SIG from Scholle IPN, acquired in 2022.