2019 Sustainability Report

arrow blueCommitted to using financial, natural and human resources wisely without compromising the ability of future generations to meet their needs

ADDRESSING RISK
Ethics & Compliance

Creating a culture The Greif Way.

United Nations Sustainable Development GoalsReduced inequalities

Why Ethics & Compliance Matters

102-11
Precautionary Principle or approach

102-16
Values, principles, standards, and norms of behavior

103-1
Explanation of the material topic and its Boundary

103-2
Explain management approach components

102-3
Location of headquarters

205-1
Operations assessed for risks related to corruption

205-2
Communication and training about anti-corruption policies and procedures

412-2
Employee training on human rights policies or procedures

GRI 102-11; 102-16; 205: 103-1, 103-2,103-3; 205-1; 205-2; 206: 103-1, 103-2, 103-3; 412-2

The principles set forth in The Greif Way establish a company culture rooted in ethics and compliance. We believe that behavior influences culture and culture determines performance, which is why establishing positive behaviors is important to our business. Every day, our colleagues implement these principles which are formalized through the policies that govern our organization.

Governance

Greif maintains a broad set of ethics- and compliance-related policies:

Each policy is managed, reviewed and implemented by a diverse team comprised of representatives from human resources, finance and legal. We regularly review our policies and revise them as necessary to strengthen language, address emerging risks and communicate best practices. Greif leverages training and audits to actively implement our policies. We require each of Greif’s over 2,300 manager-level and above colleagues to complete policy training. We actively encourage our colleagues to anonymously report ethics and compliance violations through our Ethics Hotline. The Hotline is administered by a third-party provider to protect the anonymity of our colleagues and is available 24 hours a day, seven days a week. In 2019, we took steps to make the Hotline more accessible to our colleagues and improve our governance and oversight of potential ethical violations. Information on the Hotline, and related policies, is included in the Code of Conduct – which all colleagues receive training on – through our internal colleague portal and via posters at each facility. Complaints can also now be reported via an online portal or e-mail as well as by phone globally. All reported incidents are sent to our newly formed Ethics Committee, chaired by Greif’s General Counsel, for review. Incidents are reported to the Audit Committee of Greif’s Board of Directors quarterly. In 2019, we investigated and resolved 90 percent of the complaints from our Ethics Hotline.

To validate our compliance to our established policies, we conduct annual Sarbanes Oxley Act (SOX) audits for all of our facilities that are material to our financial statements. Prior to the Caraustar acquisition in 2019, Greif had 175 auditable entities. With Caraustar now integrated into Greif, we now have 265. In 2019, 39 of these entities were in-scope for SOX testing. In addition to required SOX audits, Greif conducts risk-based audits at each of our facilities at least once every five years. Each year we ensure that facilities accounting for at least 75 percent of our revenue receive risk-based audits. Facilities that are audited are identified through a multi-layered process that includes management surveys, in-person discussions, approval by executive leadership and reports to Ethics Hotline. Following this process, in 2019 we completed 24 risk-based audits. We continue to strengthen our internal control environment as we leverage shared processes across locations.

As part of the Caraustar integration, we performed a full review of their ethics and compliance policies and training to confirm their practices were well-aligned to Greif’s expectations. Based on this review, we provided Insider Trading Training to key Caraustar colleagues, but found no other significant gaps in their legacy ethics and compliance practices. As Caraustar fully integrates into Greif’s training and business systems, legacy Caraustar colleagues will be expected to complete ethics and compliance training in accordance with Greif’s policies. In 2019, we implemented a clawback policy, which allows for the possibility to recover colleague incentives in the case of a breach in compliance, to better protect our financial interests and further promote ethical behaviors.

In addition to continuing to work towards our 2025 goals, in 2020 we will continue to promote ethical behavior internally and throughout the supply chain. We will publish an updated Code of Conduct that more clearly reinforces the key behaviors we desire our colleagues to demonstrate and launch updated Code of Conduct training in support of our 2025 goal. We will release an updated Supplier Code of Conduct that better outlines our business ethics expectations.

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SOX Audits Completed

We work to ensure our internal policies are implemented and our operations are compliant with relevant regulations.

Goals & Progress

In 2017, we established our first ethics and compliance goals. By the end of fiscal year 2025 we will:

  • Provide online training of the Greif Code of Business Conduct and Ethics to 100 percent of colleagues with access to computers
  • Provide training and information on the Greif Anti-bribery Policy to 100 percent of colleagues for whom training is relevant
  • Provide online training of the Fair Treatment of Others Policy to 100 percent of colleagues with access to computers, and provide accessible and traceable information to all colleagues
In 2019, 78 percent of colleagues* with access to computers completed training on Greif’s Code of Business Conduct and Ethics. The training was fully transitioned to Greif’s learning management system, SkillPort, which allows for training to be more easily accessible and trackable. We developed and launched new Anti-bribery Training and began rolling it out to the organization. In 2019, 82 percent of eligible colleagues completed the training. In 2020, we will translate the training to four additional languages and transition the training to SkillPort. Together, these steps will allow us to provide the training in the primary language for more of our colleagues and improve the trackability of the training in support of our 2025 goal. In addition, 69 percent of colleagues for whom training is relevant received training on our Insider Trading Policy.
*Excludes legacy Caraustar colleagues
DEFINITION