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Ethics and compliance

Ethics and compliance

​Ethical business conduct and legal compliance are not only cornerstones of our way of doing business, but also paramount for living up to Stora Enso's corporate Purpose 'Do Good for the People and the Planet' and our Value 'Do What's Right'. We believe that an ethical approach will lead to successful business, foster accountability and enhance our good reputation.

 

Stora Enso's Ethics and Compliance function is part of the Group's Legal Services. The Head of Ethics and Compliance, our General Counsel, is responsible for Stora Enso Ethics and Compliance and reports directly to the CEO. Our Ethics and Compliance Board, which is a management-level governance body appointed by the CEO, monitors and assesses the Group's legal compliance and ethical business conduct.

 

Our Ethics and Compliance function focuses especially on the main areas in our Ethics and Compliance Programme outlined below. All our actions aim to strengthen our organisational culture, which encourages our employees and stakeholders to take part in open and honest discussions on ethical issues related to Stora Enso.

 

Top level commitment

In the context of our efforts to make Stora Enso into a more value-driven organisation, with the prime focus on ethics rather than compliance (without downgrading the importance of strict compliance), the importance of continuing to set a clear and unfailing tone at the top cannot be overstated.

 

Since 2011 all Stora Enso employees in managerial positions, members of Business Area or mill management teams, employees with competitor contacts, and employees working with purchasing, marketing and sales have had to make a personal commitment to our Code of Conduct and Business Practice Policy, and undertake to train and inform employees within their respective organisations. During 2013 a total of 1 586 employees (1 039 in 2012) were required to make such pledges.

 

During 2013 we additionally ran an Ethics Workshop for 25 of our employees providing training and promoting discussions on ethical questions. We aim to organise more workshops of this kind during 2014.

Spreading the message

Clear communications and frequent training are fundamental ways to increase awareness and promote our values among our employees and business partners. In recent years we have rolled out a wide-ranging set of policies, guidelines and training on Ethics and Compliance.

These policies and guidelines are accessible to all of our employees on our internal website. Our Code of Conduct and Business Practice Policy are also publicly available at www.storaenso.com/sustainabilitypolicies.

 

 

Code of Conduct

Stora Enso has a single set of values that are applied wherever we operate. Our Code of Conduct defines common rules for all our employees, and provides guidance on Stora Enso's approach to ethical business practices, environmental values, and human and labour rights.

 

To ensure our employees understand and follow the rules set out in our Code of Conduct, they receive related training through our established e-learning tool or face-to-face training. We are also

working to ensure that all new employees are trained promptly.

 

In relation to the revision of our Code of Conduct during 2013 a new e-learning tool was rolled out. During 2013 a total of 10 418 of our employees underwent this e-learning, and our aim is to provide such training for all of our other employees who have access to computers during 2014. During 2013 we also devised a new training concept designed to reach more than 11 000 of our employees who do not have direct access to computers. This face-to-face training scheme will be launched during 2014.

 

 

Business Practice Policy

In 2011 Stora Enso launched a new Business Practice Policy to complement our Code of Conduct, aiming to further strengthen our stand on ethical business practices. The policy has given our employees more detailed guidance on topics such as antitrust, corruption, gifts and entertainment, conflicts of interest and money laundering.

 

 

New complementary guidelines

During 2013 we established a Gifts and Hospitality Guideline and a Third Party Due Diligence Guideline to complement our Business Practice Policy.

 

Our Gifts and Hospitality Guideline gives more detailed guidance than the rules set out in our Business Practice Policy. It emphasises Stora Enso's zero tolerance approach to corruption. We have defined our new Third Party Due Diligence Guideline in response to more stringent anti-corruption legislation, which requires companies to actively prevent corruption committed by their business partners. It aims to help ensure that Stora Enso has adequate procedures in place to prevent bribery committed by third parties.

 

Our divisions have worked extensively to make all our employees aware of the content of our guidelines on Gifts and Hospitality and Third Party Due Diligence. These activities have particularly

targeted divisional management teams, mill management teams, employees with competitor contacts, employees working with purchasing, marketing and sales, and employees in China, India and South America.

 

 

Competition Law Compliance Programme

In 2013 we updated our Competition Law Compliance Programme, which aims to explain the fundamentals of anti-trust legislation to our employees, and to establish reporting pathways for the approval of benchmarking, mill visits and competitor contacts.

Further efforts in risk areas

During the last decade we have expanded our business operations into geographical areas which offer excellent business opportunities, but which also entail increased exposure to risks related to compliance. In order to facilitate our expansion in different areas Stora Enso has also entered into joint venture agreements which might also expose the company to risks related to competition laws.

 

Our risk assessment procedures on compliance cover all our units. The most significant compliance risks in our global operations relate to corruption and anti-trust.

 

During 2013 we rolled out an extensive in depth e-learning programme developed by an external law firm to increase awareness of legal regulations and mitigate the related risks. The target group for this e-learning has encompassed our Group Leadership Team, divisional management teams, mill management teams, employees with competitor contacts, and employees working with purchasing, marketing and sales. During 2013 around 3 000 employees were trained in this programme.

 

Extensive face-to-face training on our Business Practice Policy was additionally organised for our management and employees in Brazil, India, Pakistan and China during 2013.

Speak Up - an effective grievance mechanism

All our employees are encouraged to report suspected misconduct or unethical behavior directly to their own supervisor, Human Resources or Stora Enso Legal Services. Our employees may also report their concerns in confidentiality to the Head of Internal Audit.

 

In 2012 Stora Enso launched an additional external service through which our employees can confidentially and anonymously report on non-compliance issues by phone, by mail, or using the internet. This service was launched in cooperation with an external service provider and covers all of our units. During 2014 this external hotline is due to be opened up to our suppliers and other third parties in Brazil, Uruguay, Russia, India and China.

 

A total of 34 of the grievances received through Stora Enso’s various grievance channels were identified as potential non-compliance cases. All such cases are recorded and reviewed by Stora Enso’s Head of Internal Audit and Ethics and Compliance, and reported to the Ethics and Compliance Board as well as Stora Enso’s Financial and Audit Committee.

 

All potential non-compliance cases were investigated. Proven misconduct was found in 12 cases which led to disciplinary and/ or legal actions. None of the reported cases were related to child labour, forced labour or discrimination.