Responsible culture:

Governance and ethics

Our commitments

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. These principles include, among others:

• Ethical and compliant behavior (for example regarding anti-bribery and anti-corruption).
• Fair, respectful, and courteous treatment of fellow employees and others with whom we interact.
• Fair and appropriate consideration of the interests of other stakeholders (customers, suppliers, and other business partners, government authorities and the public) as well as of the environment.
• Professionalism and good business practice.

Our approach

The SIG Code of Conduct is approved by our Board of Directors and complemented by policies and guidelines on specific topics. The SIG Code of Conduct is available in 19 languages. It sets out our expectations on topics such as anti-bribery and anti-corruption, avoidance of and dealing with 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 and corruption in any form is stipulated in the SIG Code of Conduct, detailed in 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 onboarding when they join the business, and they are required to complete refresher trainings every year. We provide additional in-depth training on specific topics for employees in high-risk roles. This includes further training for sales, procurement and finance teams on anti-bribery and anti-corruption.

We encourage people to speak up without fear of retaliation if they have any questions or concerns, including those related to bribery and corruption, via their line managers, our People & Culture teams, global and regional Legal and Compliance Officers, or via our Integrity & Compliance Hotline. The hotline is available to employees and external stakeholders, such as customers and suppliers, to report any concerns on ethical conduct, human rights or the environment relating to our own operations or our suppliers’ business activities. Reports can be made anonymously (where permitted by local legislation).

Details on the Integrity & Compliance Hotline and how to report a concern can be found on our website: Hotline.

We investigate all reports received and take appropriate action including, but not limited to, disciplinary measures. The effectiveness of the grievance mechanism is regularly assessed, including by statistical analysis of the reports and other controls.

Group Internal Audit regularly reviews expense reports as part of their audits to assess implementation of and compliance with our internal policies and procedures on anti-bribery and anti-corruption.

As part of the global community, SIG is committed to engaging responsibly and transparently with all relevant and affected stakeholders in developing, managing, and communicating governance topics and activities, including by developing channels to enable them to voice their complaints and grievances. We foster engagement with a wide range of stakeholders – see Stakeholder engagement.

Maintaining ethical and compliance standards

All our production plants completed SEDEX SMETA audits – which include business ethics – in the 2023 two-yearly cycle, with three new plants audited in 2024.

Focusing on data security and privacy

With cyberattacks on the rise globally, building employees’ awareness of IT security and safeguarding personal data is increasingly important.

• Our security acceleration program has been implemented. We have enhanced our security maturity to the next level, bolstered our cybersecurity to prevent and protect against cyber threats, and improved our cyber resilience to respond to and recover from security incidents.
• We maintained certification to the international ISO 27001 standard on information security management in China, Germany, and Romania scoping the provision of Information Communication Technology Infrastructure, related applications, data centers, and production operations.
• We continue to improve our security awareness culture by creating emotional involvement among employees (case examples, personal tips, sharing experiences), providing knowledge in a clear and easy way (do & don’t, phishing simulation), and ensuring active participation (annual cybersecurity survey and quiz).
• 99% of our employees completed our refreshed data security and privacy training. We carried out quarterly simulated phishing attacks to help employees spot common phishing tactics and provided guidance explaining how to report any suspicious emails they may encounter.

Measures taken in 2024

Approximately 99% of our employees completed an annual certification on the SIG Code of Conduct in 2024 and 99% completed additional in-person or virtual training on the SIG Code of Conduct.

Training our people and raising awareness

• We provided further training on specific compliance topics, such as anti-bribery, anti-corruption and anti-trust for employees in high-risk roles.
• We provided further training on data privacy for our People & Culture teams.
• We encouraged people to speak up by raising awareness of our Integrity & Compliance Hotline.
• We also reinforced a culture of cyber-security awareness to help employees remain vigilant.

Investigating and acting on reports received

• Reports received via our Integrity & Compliance Hotline and other channels in 2024 mainly related to workplace and employee matters.
• We investigated all reports received and took disciplinary action, including reprimands and dismissals, where appropriate.
• We have not identified cases of significant non-compliance with applicable laws and regulations during the reporting period; there were no cases in which monetary fines were incurred.¹
• During the reporting period there were no confirmed incidents where contracts with business partners were terminated or not renewed due to violations related to corruption, nor were there any confirmed public legal cases regarding corruption brought against the organization or our employees.
• If reports containing critical concerns are received, they are communicated to the Board of Directors, the Group’s highest governance body, at its quarterly meetings or on an ad-hoc basis, if required. During the reporting period there were no concerns considered as critical.

Assessing effectiveness

Regular updates and statistics on compliance matters, including relating to anti-bribery and anti-corruption topics, are provided to the Audit & Risk Committee. Internal audit reports are provided to the Audit & Risk Committee. Lessons learned are shared with the organization as appropriate.

Our targets and performance

Targets, progress and performance

1 We define significant instances by reference to a value exceeding €30 million, in line with the materiality threshold applied in connection with our consolidated financial statements 2024.