Management of the legal, ethics, and regulatory framework encompasses business ethics – human rights, anti-corruption, and non-discrimination – and anti-competitive behavior.

Commitments and policies

Solvay’s Code of Conduct

Solvay’s Code of Conduct and the 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.

Solvay’s Code of Conduct

Gifts, Entertainment and Anti-Bribery policy

Solvay’s Code of Conduct expressly states that the Group prohibits bribery in any form. Solvay and its employees do not use gifts or entertainment to gain competitive advantage. Facilitation payments are not permitted by Solvay. Disguising gifts or entertainment as charitable donations is equally a violation of the Code of Conduct. The Code is supported by a more detailed policy on gifts, entertainment and anti-bribery. Solvay is a member of Transparency International Belgium.

The Group employs an internal tracking system to record gifts and entertainment that exceed the acceptable reasonable value applicable in each region and requires manager approval for accepting or giving them. The use of the Gift and Entertainment Tracking System (“GETS”) is part of Solvay’s Internal Audit review process.

Human rights in business policy

Solvay’s Human Rights in Business Policy, published on Solvay’s website, sets forth Solvay’s commitment to respecting human rights and acting with due diligence to avoid any infringement of human rights or any adverse impact on or abuses of such rights. The policy emphasizes Solvay’s commitments to its stakeholders (its employees, its business partners, the communities and environment in which it operates, and children).

Solvay has a Global Human Rights Committee (GHRC) to oversee implementation of the policy, ensure compliance, and monitor the Group’s performance in meeting its commitments. Members of the Global Human Rights Committee include the heads of the following Solvay business service activities and / or their delegates: Legal and Compliance, Human Resources, Purchasing and Supply Chain Excellence, Industrial, Internal Audit and Risk Management, and Sustainable Development. The GHRC is chaired by the Group General Counsel, who is the head of Legal and Compliance. Members of Solvay’s Global Business Units and other business service activities contribute to the work of the GHRC on an ad hoc basis, as necessary.

The GHRC provides an annual written summary of its activities (including key performance indicator results) to the Executive Committee before the Group’s annual report is issued, and it also validates the human rights reporting made in conjunction with the issuance of that report. Upon request, the Chair of the GHRC may be called upon to provide an Annual Integrated Report to the Audit Committee.

Solvay is also a pilot participant in the Belgium Commission for Children’s Rights and Business Principles.

Solvay Human Rights in Business Policy

Competition Law policy

Solvay’s goal is to conduct business ethically and not to enter into any business arrangements that eliminate or distort competition. Solvay is committed to developing and maintaining a culture of compliance to keep Solvay and its people on the right side of the law. Solvay has a formal Competition Law policy that stresses the importance of strict adherence to all competition laws. This formal Competition Law policy was approved by Solvay’s Executive Committee and is published on the intranet, to which all Solvay’s employees have access. Any violation of this policy may result in disciplinary action, subject to and in conformity with applicable laws.

Resources and responsibilities

A Compliance organization under the leadership of the Group General Counsel enhances a Group-wide culture based on ethics and compliance.

Regional Compliance Officers serve in all four zones where the Group operates. Every Solvay Global Business Unit and Function appoints Compliance Liaisons to enhance adherence to compliance objectives and to instill a commitment to compliance throughout Solvay.

As for competition law, Solvay has dedicated resources within the Legal Function responsible for the implementation of the Competition Law Compliance Program. They are in charge of providing competition law advice and guidance, as well as deploying effective and regular communication and training on competition law-related subjects.

Implementation of the competition law policy

Solvay has put in place a Competition Compliance Program that propagates a zero tolerance approach towards competition law infringements. As part of its Competition Compliance Program, Solvay provides a competition law tool kit on its intranet that includes up-to-date guidelines on specific areas of competition law, including guidance on dealing with competitors, information exchange in Mergers and Acquisitions transactions, swaps, price announcements, vertical relationships, and so on.

To minimize cartel risks, Solvay has put in place a computer-based system that tracks all contacts that relevant employees have with competitors through a managerial approval procedure.

Grievance mechanisms

Employees are encouraged to report suspected violations or concerns through various internal avenues, including management, Human Resources, Legal & Compliance, and Internal Audit.

A Group-wide Speak Up program is in place and overseen by the Audit Committee of the Board of Directors. 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 following chart shows the types of claims from January, 2018 until February, 2019 through Solvay’s Speak Up program:

Solvay’s Speak Up program

Number of claims

 

2018

 

2017

Misconduct or Inappropriate Behavior

 

30

 

26

Discrimination including harassment and retaliation

 

20

 

15

Conflict of Interest

 

10

 

7

Computer, Email, Internet

 

3

 

1

Environmental, Health or Safety Law

 

2

 

6

Accounting or Auditing

 

1

 

2

Anti-Bribery

 

0

 

2

Confidentiality/Misappropriation

 

1

 

2

International Trade Compliance

 

0

 

0

Substance Abuse

 

1

 

1

Theft

 

4

 

3

Violence or Threat

 

5

 

2

Other

 

11

 

16

Total

 

88

 

83

Through the Speak Up program, any concern regarding a breach is investigated by the Ethics and Compliance Function. In keeping with its commitment to transparency, the Speak Up tool is used to report progress on the investigations and is used to communicate the results of investigations directly to the reporters upon conclusion. Posters and an online brochure are available to employees and advertise the web address and toll-free numbers to access this tool in their regions. The Board’s Audit Committee oversees the running of Speak Up.

88

Total claims made

81

Total claims closed*

34

Substantiated claims among resolved cases

37

Unsubstantiated claims among resolved cases

* Includes cases for which there was insufficient information or cases that were misdirected or referred.

Resolved Cases

 

No Action

 

Policy Review

 

Training

 

Discipline

 

Termination

 

Resignation

Substantiated

 

0%

 

21%

 

0%

 

44%

 

26%

 

9%

Unsubstantiated

 

92%

 

0%

 

5%

 

3%

 

0%

 

0%

Communication and training

Solvay’s Code of Conduct

Code of Conduct training (live training and web-based training) is organized to ensure understanding and to address behavioral risks such as anti-trust, anti-bribery and corruption, and human rights abuses. Specific anti-corruption training is tailored to management and other personnel in sensitive positions (sales, procurement, industrial development, etc.). Special campaigns to maintain and/or enhance the level of awareness within the Group are identified and adopted annually. 

Anti-trust

Solvay has a concrete Action Plan designed to mitigate the specific risks the Group has identified. It has been in force since 2003 and is updated yearly. In 2018, this action plan includes a new onboarding antitrust training session successfully completed by 369 recruits in relevant areas, as well as Contacts with Competitors Tracking System (CCTS) training for 822 individuals and additional tailored face-to-face training sessions for 134 high-risk individuals.

Annual Internal Audits check to make sure the Action Plan is being implemented effectively.

Anti-Corruption

A new web-based anti-bribery and anti-corruption training course was introduced in 2018 to supplement the live training program. With the help of this program, Anti-Bribery and anti-corruption training increased significantly in 2018: approximately 2,400 employees in sensitive business positions received the training, roughly double the number of employees previously trained on this topic. Additionally, anti-bribery and anti-corruption topics are still offered as part of the Code of Conduct training that is mandatory for all employees.

Human Rights

In 2018, the Group continued to develop its Human Rights in Business Policy plan. As part of this initiative, a new Human Rights video was introduced to the Leadership Council to provide an overview of Solvay’s actions and human rights strategy going forward. The video was also used to spur discussion on the topic at the 2018 Annual Sustainable Development Convention among approximately 75 leaders engaged in various aspects of sustainability within the Group. Throughout the year, the Group conducted human rights training for plant managers globally by connecting with them at their annual regional meetings, and Solvay will continue to increase its outreach and training in 2019.