1. INTRODUCTION

Borregaard defines corporate responsibility as achieving through its operations and development commercial profitability in a way that is consistent with fundamental ethical values and with respect for individuals, the environment and society. Through profitable, responsible operations our companies create positive economic, environmental and social ripple effects. The Borregaard companies shall respect human and labour rights, establish good environmental, health and safety (EHS) standards, facilitate good dialogue with all our stakeholders and generally operate in accordance with applicable regulatory frameworks and good business practice.

In line with Borregaard’s corporate structure, each company has an independent responsibility for operating in accordance with Borregaard’s principles, but is free to design its own activities and instruments to this end. Borregaard endorses the United Nations Global Compact’s ten principles [1], the Universal Declaration of Human Rights [2] and the OECD Guidelines for Multinational Enterprises [3]. Borregaard’s principles are established with these principles as a basis. This document is applicable for all companies in the Group, and for joint ventures where agreed to as part of the ownership contract.

 

2. MAIN PRINCIPLES

Borregaard has identified nine main corporate responsibility topics. The general principles underlying the Group’s approach to these topics are described below. There shall be an emphasis on continuous improvement, and priority shall be given to areas where the need for improvement and the potential for making an impact are greatest. Priorities shall be based on an assessment of the needs of both the business and its stakeholders, and be an integral part of day-to-day operations.

 

2.1. A STRONG CORPORATE CULTURE

Borregaard companies shall strive to promote an open corporate culture characterised by interaction based on the values in this document and in the Borregaard values and culture document “The Borregaard Way”. In promoting Borregaard’s principles for good business operations, we shall respect local values and norms, and achieve success by bridging the divide between different cultures and interests. Borregaard companies shall always comply with local regulatory requirements in the countries in which we operate.

Responsible operations require vigilance and the exercise of good judgement on the part of management and employees. The Group’s standards and expectations as regards employee attitudes and conduct are described in Borregaard’s Code of Conduct.

 

2.2 . RESPECT FOR HUMAN AND LABOUR RIGHTS

Borregaard companies shall promote corporate conduct that reflects respect and concern for others. We are committed to respecting fundamental human and labour rights, both in our own internal operations and in our relations with business partners, customers and others who are directly affected by the company’s activities. The companies shall work systematically with important issues such as non-discrimination, the right to privacy, the right to negotiate, employment contracts, protection against harassment and management-employee collaboration. Borregaard’s standards and expectations as regards company conduct in this area are described in further detail in the document Human Rights.

 

2.3. ENVIRONMENT, HEALTH AND SAFETY (EHS)

Borregaard companies shall strive to achieve a vision of inflicting no harm on people, the environment and society, and they shall work purposefully and systematically to prevent any negative effects of their operations. The companies’ products and services shall always be subject to strict requirements in terms of quality, product safety and impacts on health and the environment. Borregaard’s standards and expectations in this area are described in further detail in the document Environment, Health and Safety.

 

2.4. ANTI-CORRUPTION

Borregaard does not tolerate corruption, and expects local management to promote a strong anti-corruption culture in the individual companies. The companies shall make active efforts to prevent undesirable conduct, and ensure that their employees are capable of dealing with difficult situations. Borregaard’s standards and expectations as regards company and employee conduct in this area are described in further detail in the document Anti-Corruption Manual.

 

2.5. RESPONSIBLE MARKETING PRACTICES

Borregaard attaches great importance to product safety, good customer service and responsible marketing. The sale and marketing of Borregaard products and services shall be carried out with respect for local regulatory requirements, and in accordance with the principle of free and fair competition. The companies shall observe good business practice, and respect the established rights of competitors. When selling in new markets, an assessment of political and legal risk should be carried out, and necessary steps shall be taken to ensure sound and responsible practices. Borregaard does not tolerate any agreements on price fixing, market sharing or other activities that limit free competition. Borregaard’s standards and expectations in this area are described in further detail in the document Competition Law Manual.  

 

2.6. RESPONSIBLE SOURCING

Borregaard companies shall actively promote good work and environmental standards in their supply chains. This means setting ethical standards for their suppliers, assessing the risk of potential violations of these standards, and engaging in dialogue with suppliers concerning necessary improvements. Efforts to influence suppliers should be based on an ambition of continuous improvement, and should focus on the suppliers and markets where the risk is greatest. Borregaard’s standards and expectations in this area are described in further detail in the document Responsible Sourcing.

 

2.7. RESPONSIBLE INVESTMENTS

In connection with the acquisition of other companies, the risk that a company does not meet Borregaard’s corporate responsibility requirements shall be assessed. An introduction to corporate responsibility and ethics shall be included in the integration programme for companies incorporated into the Group.

 

2.8. COMMUNITY ENGAGEMENT

In order to achieve long-term profitable operations, we are dependent on public trust. We seek to be responsive to society’s needs, and engage in active dialogue with important stakeholder groups. All the companies in the Group shall identify relevant issues in the relationship between their business and society, and facilitate good, effective ways of dealing with complaints and other inquiries from external stakeholders. In areas that present special challenges, the company shall consider the need to initiate improvement projects. Some Borregaard companies are important for their local communities, and should consider how they can best support these communities.

Borregaard is dependent on good collaboration with public authorities irrespective of party affiliation, and will not provide financial support for political parties nor participate in parties’ election campaigns. This principle shall not in any way prevent our employees or board members from engaging in political activities.

 

2.9. WHISTLE BLOWING

The Group has established a whistle blower service through which employees can report concerns related to possible breaches of law or of Borregaard rules. Companies shall ensure that employees in the various businesses are well informed about this system. The whistle blower service is further described in Borregaard’s Code of Conduct.

 

3. REQUIREMENTS FOR IMPLEMENTATION AND ONGOING MONITORING

Borregaard companies shall provide for sound and effective implementation of the principles described above. Activities shall be adapted to the size of the company and an assessment of the most relevant issues, but shall always include:

  • Internal training on Borregaard’s corporate responsibility standards.
  • Annual assessment of risks related to the company’s corporate responsibility.
  • Procedures for receiving and processing complaints and other inquiries from customers and other external stakeholders.
  • Procedures for internal handling of concerns from employees (whistle blowing).
  • Procedures for distribution and communication of the Borregaard Code of Conduct

More detailed requirements for implementation and ongoing monitoring are set out in related documents mentioned at the end of this document. Borregaard will monitor the companies’ work through the business area boards, internal reporting and internal audits.

 

4. ROLES AND RESPONSIBILITIES

The Senior Vice President of Organisation and Public Affairs is responsible for this document.

The CEOs of the Borregaard companies are responsible for the implementation of these guidelines. Each company shall appoint one or more contact person(s) to report on issues relating to corporate responsibility and EHS. Borregaard will support the companies’ implementation by providing guidance and appropriate tools.

Borregaard strives to foster open dialogue on difficult dilemmas. As a general rule, this should take place in the form of discussions and assessments within individual companies, but guidance can also be obtained from Borregaard’s CR function and other relevant functions in the Group.

Borregaard and the companies in the Group are jointly responsible for promoting the Group’s corporate responsibility principles in respect of companies in which the Group has an ownership interest, as well as other business contacts.

Borregaard’s Guidelines for Corporate Responsibility do not give customers, suppliers, competitors, shareholders or other persons or entities any legal rights beyond those that follow from applicable legal regulatory frameworks.

References

  • Corporate Responsibility
  • Code of Conduct
  • Competition Law Manual
  • Anti-Corruption Manual
  • Responsible Sourcing
  • Human Rights
  • Whistle Blowing
  • Environment, Health and Safety
  • Corporate Responsibility
  • Approved 9 September 2014

[1] UN Global Compact, http://www.unglobalcompact.org     

[2] Universal Declaration of Human Rights, http://www.un.org                             

[3] OECD Guidelines for Multinational Enterprises, http://www.oecd.org