CORPORATE RESPONSIBILITY
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 principles1, the
Universal Declaration of Human Rights2 and the OECD Guidelines for Multinational Enterprises3.
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.
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
Corporate Responsibility
Approved Sept 9 2014
Page 1
of 4
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 nondiscrimination, 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 anticorruption 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.
Corporate Responsibility
Approved Sept 9 2014
Page 2
of 4
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.
Corporate Responsibility
Approved Sept 9 2014
Page 3
of 4
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
Corporate Responsibility
Approved Sept 9 2014
Page 4
of 4
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
Corporate Responsibility
Approved Sept 9 2014
Page 5
of 4