Description

Risk arises from a potential failure to comply with:

  • The Solvay Code of Conduct
  • Supporting policies and procedures
  • Laws and regulations in the jurisdictions in which Solvay operates.

Examples:

  • Failure to implement good governance in a joint venture
  • Direct or indirect involvement in human rights violations
  • Intentional misstatement of financial reporting, corruption and by-passing of internal controls.

Prevention and mitigation

The Code of Conduct, policies and procedures adopted to enhance good governance apply to all employees wherever they are located. In addition:

  • Third parties are expected to act within the framework of the Code of Conduct.
  • All critical suppliers must confirm that they adhere to the principles set out in the Solvay Supplier code.
  • Majority-owned joint ventures are held to the Solvay Code of Conduct or to a separate code adopted based on similar principles.

Compliance organization:

  • This organization operates under the leadership of the Group General Counsel to enhance a Group-wide culture based on ethics and compliance. It also monitors compliance with applicable laws, the Code of Conduct, and supporting policies and procedures.
  • Regional Compliance Officers serve in all four zones where the Group operates to ensure communication of the Code and the principles on which it is based.
  • Every global business unit and function within Solvay appoints Compliance Liaisons to enhance adherence to compliance objectives and to instill a commitment to compliance throughout Solvay.

Training:

  • Courses are developed internally and presented by the Legal & Compliance function to ensure understanding and adoption and to address behavioral risks in certain areas such as anti-trust, anti-bribery and corruption, human rights, and other aspects of Corporate Social Responsibility. Multi-lingual online training is also being developed.
  • Special campaigns to maintain and/or enhance the level of awareness within the Group are identified and adopted annually.
  • New employee training is organized as part of the orientation process.

Reporting violations:

  • Is encouraged as a condition of employment through various internal avenues, including management, Human Resources, Legal & Compliance, and Internal Audit.
  • An external third-party helpline active 24 hours a day, 365 days a year allows employees to ask questions, raise concerns or file reports. The Solvay Ethics Helpline is available on the web or by phone, operationally via the internet in 46 specific regions in more than 40 languages, and via the phone in more than 20 languages.
  • This Group-wide Speak Up program is overseen by the Audit Committee of the Board of Directors.