2018 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 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 2,000 manager-level and above colleagues to complete policy training. We conduct annual SOX audits for all of our facilities that are material to our financial statements. Greif conducts risk-based audits at each of our facilities at least once every five years. We encourage our colleagues to anonymously report ethics and compliance violations by maintaining an Alert Line with the phone number posted at every Greif facility. In 2018, we investigated and resolved 94 percent of the complaints from our Alert Line. Quarterly, Greif’s Audit Committee receives internal audit reports and a report of all Alert Line calls during this period, prepared in conjunction with a third-party. The committee evaluates and prioritizes the risks that are most material to our business. For more information on Greif’s approach to risk management, please see Risk Management & Business Continuity.   

To validate our compliance to our established policies, we regularly conduct audits of our controls and processes. Across Greif, we have 170 auditable entities. In 2018, 40 of these entities were in-scope for SOX testing and we completed risk-based audits for 24 of them. We continue to strengthen our internal control environment as we leverage shared processes across locations.

In 2019, we will implement a clawback policy to further promote ethical behaviors. We will introduce web-based training for our Anti-bribery Policy in French and German. Greif will ensure our Whistleblower Policy and Alert Line procedures address new regulations in the European Union.

24

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 employees with access to computers
  • Provide training and information on the Greif Anti-bribery Policy to 100 percent of employees for whom training is relevant
  • Provide online training of the Fair Treatment of Others Policy to 100 percent of employees with access to computers, and provide accessible and traceable information to all employees

As part of our plans to reach our 2025 goals, we revised our Code of Business Ethics and Conduct in 2018 to improve its clarity and better reinforce the key behaviors we desire our colleagues to demonstrate. We implemented the new code in conjunction with our revised online training, which now reaches over 2,000 professional, administrative and clerical colleagues. In 2019, we will begin to translate the training into additional languages, helping us reach more colleagues for whom training is relevant in their primary language, and begin formally tracking completion metrics in order to report against our 2025 goals.

DEFINITION