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Compliance at Siegwerk

Company

Ensuring legally and ethically correct behavior

We at Siegwerk are committed to operating with integrity in compliance with applicable laws, regulations and policies and therefore expect the highest standards on ethical business conduct from all our employees in performance of their work regardless of which position one holds.

In principle, all employees are expected to

  • be honest, ethical, and truthful
  • obey the law
  • follow the company’s policies and procedures

when conducting business for Siegwerk.

We have established a compliance organization and a compliance program to demonstrate the importance we place on compliance with laws, regulations, and social responsibility. The compliance program pursues to maintain compliance with laws, regulations, and policies and to promote ethical behavior consistent with the principles laid out in Siegwerk’s Code of Ethical Business Conduct.

The Code of Ethical Business Conduct applies to every employee of Siegwerk and is the guideline for lawful and ethical behavior within the company as well as to our business partners and the public.

Siegwerk’s principles

We are committed to make proper business use of workplace information technology and help to protect systems and equipment against internal and external threats – no inappropriate use of and risk for information technology.

  • We are committed to fair competition – no antitrust violations.
  • We are committed to integrity in business dealings – no corruption.
  • We are committed to transparent financial reporting – no deceit, no fraud.
  • We are committed to fair and respectful working conditions – no unfair working conditions, no discrimination.
  • We are committed to the principles of sustainability – no inappropriate risks for human health and the environment.
  • We are committed to protection of confidential information and property rights – no infringement of our own or others’ property rights.
  • We are committed to keeping corporate and personal interests separate – no conflict of interest.

Whistleblowing & Contact

Whistleblower System "Integrity Line"

Siegwerk has implemented the Whistleblower System “Integrity Line”, which is intended to enable employees and third parties to submit reports to Siegwerk Compliance Organization: The Integrity Line is capable to record (anonymous) reports of misconduct in a comprehensible, secure process that ensures the best possible protection of the legitimate interests of those involved.

What should be reported?

Whistleblowing is only intended for specific categories of violations of law and other regulations. For Siegwerk these are specifically the following (not conclusive):

  • Violations of laws, such as fraud, corruption, antitrust, money laundering, discrimination, harassment, environmental law
  • Breaches of data protection and information security
  • Significant violations of Siegwerk’s Code of Ethical Business Conduct or Siegwerk’s policies
  • Misconduct (Violation of human rights or environmental standards) in Siegwerk’s Supply Chain (separate reporting channel)

What should not be reported?

Whistleblowing is not intended to address other issues that do not meet the criteria above, such as (not conclusive):

  • Labor law conflicts
  • Misconduct by colleagues or superiors not related to Siegwerk’s business activities
  • Disagreements among colleagues, organizational topics
  • Minor violations of internal guidelines (e. g. one-time violation of documentation requirements)

How are you protected from retaliation?

Siegwerk will not tolerate any kind of retaliation against anyone who, reports a concern or participates in an investigation, even if the allegation ultimately is not substantiated. Any such retaliation is strictly prohibited at Siegwerk and would be treated as serious misconduct. Nevertheless, please consider that reporting should only happen in good faith, meaning that we do not accept knowingly submitted false reports, e. g. to deliberately harm other persons or companies.

How does the process work?

In the “Whistle Blowing User Guide” you can find more detailed information on how the whistleblowing process at Siegwerk works, including a respective Q&A section.

How to access SIEGWERK’s Whistleblower System “Integrity Line”?

You can access the Whistleblower System “Integrity Line” via the following link (external provider):

SIEGWERK Integrity Line Start Page

Contact

SIEGWERK employees and third parties may contact us in case of questions or for the reporting of actual or alleged compliance incidents:

General Compliance

If you want to address a report of misconduct directly to the Group Compliance Officer in Siegburg, Germany, please contact: Compliance(at)Siegwerk.com

If you are a Siegwerk employee: Besides using Integrity Line or e-mail, you also have the option to discuss any misconduct personally with your direct supervisor, your (local/regional) Human Resources contacts or with your (local/regional) Compliance Representatives. More information can be found on the company’s intranet compliance webpage.

Supply Chain related Compliance

If you want to report a supply chain related misconduct directly to the Human Rights Officer in Siegburg, Germany, please contact: Humanrights(at)Siegwerk.com