Maintaining ethical behaviour and compliance
Why it's material
Our reputation as an ethical company – largely determined by the ethical behaviour of our employees and representatives – underpins our ability to unlock further growth opportunities. Accordingly, we view ethics are the foundation of our business. Values and ethics are not only critical to maintain a licence to operate but also for developing stakeholder trust and for driving performance. We place a high premium on adherence to ethical behaviour as encapsulated in our Code of Ethics. The latter creates clear boundaries and a consistent framework across cultures and geographies as to what constitutes ethical behaviour.
UNGC Principle 10:
Businesses should work against corruption in all its forms, including extortion and bribery.
How this issue links to other aspects of our business
Our global priority SDGs
Our top ten risks
- 6 Uncertain and evolving regulatory landscape
Our strategic fundamentals
- Grow our business
- Sustain our financial health
- Drive operational excellence
- Build trust
The global forces shaping our Thrive25 strategy
- Continued erosion of trust in business, coupled with increasing social activism
Maintaining a sound ethical culture forms the foundation of Sappi's long-term sustainability and creation of value for our stakeholders. We recognise that building an accountable organisation enhances trust and underpins our ongoing viability as a thriving business. Accordingly, the Social, Ethics, Transformation and Sustainability (SETS) Committee monitors our activities on matters such as social and economic development, including the United Nations Global Compact (UNGC) and the OECD Guidelines on Bribery and Corruption, with particular emphasis on section VII of the OECD guidelines for multinational enterprises dealing with combating bribery, bribe solicitation and extortion.
No issues have been raised for Sappi on compliance with the convention either externally or internally. We regularly review the Code of Ethics to ensure that it remains aligned to current governance and business trends.
Ethics management strengths include:
- The completion of mandatory online ethics management training for all employees
- Sappi hotlines, operated by independent service providers, are available to all stakeholders
- Retaliation against whistle-blowers is not tolerated
- An anti-fraud policy provides guidance to Sappi management in identifying and managing fraud
- Annual fraud and ethics risk assessments are conducted to identify potential weaknesses. These assessments are integrated into Sappi's control framework that covers 100% of our operations
- All our operating sites are covered by Sappi internal audit scheme
- For forensic incidents, independent investigations are done that include due consideration for ethics management and forensic lessons learned
- Employee Engagement Surveys, held every second year, provide insight into the application of ethics by employees and leadership
- Senior management sign annual confirmations that all frauds and ethics incidents and related control breakdowns have been communicated for investigation and review
- As part of the Group Legal Compliance Programme, designated employees confirm compliance with Sappi's governance, regulatory, and ethics standards on a bi-annual basis
Conducting forensic investigations
The internal audit (IA) department is responsible for performing or assisting with forensic investigations. During forensic investigations, particular attention is paid to the circumstances contributing to the incident and management's tone in responding to these incidents. IA pays also reviews the ethics management arrangements and ethics controls for particular units and processes during certain audits. Audit steps include confirming the status of our Code of Ethics and hotline communication, completion of ethics training by employees and reviewing processes for employees to disclose potential conflicts of interest.
All forensic investigations are undertaken with oversight from the legal department, human resources (HR) and executive management. Detailed formal reports are prepared for each incident and distributed to line and HR management. The Audit and Risk Committee and supporting committees receive and review reporting on all forensic activity.
In addition to the detailed scrutiny of all ethics incidents, various KPIs are used to monitor forensic and ethics management for SSA. The most important analyses relate to the numbers, classification and outcome of incidents and the timely resolution of hotline calls.
Key developments in 2020
In line with our emphasis on ethical behaviour, we implemented a comprehensive training programme across all regions in 2020. Topics covered ranged from environmental law to antifraud and corruption. These training initiatives – incorporating relevant and practical examples – have been implemented to inculcate the correct ethical behaviour and responses to avoid a tickbox approach to ethics.