Compliance

We gain the trust of our stakeholder groups and protect our reputation by complying with global and national guidelines and legal regulations. This is the basis for building our partnerships, which are central to our commercial success. We also see it as our duty to act as a role model by behaving in an ethical and legally compliant manner, thus enabling us to exert a positive influence on the industry.

Shared responsibility

At Vetropack, the General Managers of the individual sites are responsible for ensuring that negotiations are conducted in a legally compliant and responsible manner. They are assisted in this by instructions on conduct from the Legal department. It is nevertheless crucially important that all our employees are aware of their individual duty to comply with applicable laws as well as internal and external policies and guidelines, and to report any breaches. We empower them to do so by raising their awareness of fair business practices in the corporate culture through regular, level-appropriate and topic-based training and familiarisation activities.

Code of Conduct

Vetropack’s corporate culture is based on the values of integrity, reliability and transparency. In addition to compliance with legal requirements and internal policies and guidelines, our Code of Conduct states the following principles:

• Safeguarding of human rights as set out in the Universal Declaration of Human Rights and the Fundamental Conventions ('core conventions') of the International Labour Organization (ILO)
• Prohibition of discrimination
• Guarantee of a safe workplace environment by adhering to relevant labour legislation
• Prevention and exclusion of child labour and forced labour
• Guarantee of freedom of association
• Ensuring fair competition and preventing bribery, corruption and fraud

Supplier Code of Conduct

We also require our suppliers to conform to our values and to behave in a legally compliant and ethical manner. Our Supplier Code of Conduct provides the basis for ensuring that legal compliance is also upheld in the supply chain. You can find additional information about this in the Supply chain management section.

Business Ethics Policy (BEP)

Instructions on legally compliant and ethical conduct are enshrined in our Business Ethics Policy. The most important principles are integrity, reliability and transparency. On this basis, the Business Ethics Policy promotes accountability and enables fair and legally compliant collaboration. The policy supports our culture with the following instructions on conduct:

• Compliance with applicable laws and regulations
• Fair competition and respect for antitrust law
• Prohibition of bribery and corruption
• Prohibition of undue advantage
• Avoidance of conflicts of interest
• Ensuring legal compliance and transparent reporting

This policy applies to all employees throughout the Group. Employees in key positions undergo specific training that focuses on combating corruption and bribery. Implementation and enforcement are verified by means of internal audits.

Provisions regarding fair competition and antitrust law

Vetropack firmly believes that the best business results are achieved on the basis of free and fair competition. Unfair competition may entail heavy financial penalties. The high degree of concentration in the European glass packaging market results in some significant challenges. In this context, Vetropack views itself as responsible for impeccable compliance with competition law.

The individual countries where Vetropack operates each have different competition and antitrust laws. The following actions, among others, are prohibited throughout the Group:

• Arrangements to influence prices or conditions
• Market/customer allocation agreements with competitors
• Arrangements with competitors regarding participation in invitations to tender
• Disclosure of sensitive information

All employees are obliged to comply with the applicable competition and antitrust laws.

Preventing and combating corruption and bribery

Corruption includes illegal practices such as bribery, fraud, organised business crime, and money laundering. In order to combat corruption, we adhere to local and international provisions based on the 1997 Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2021 OECD Anti-Bribery Recommendation.

Our Business Ethics Policy (BEP) and the Code of Conduct prohibit all employees from offering, soliciting or accepting facilitation payments (‘kickbacks’) or bribes. Both employees and suppliers are kept regularly informed about the anti-corruption policies. All employees receive additional guidelines on preventing corruption and bribery. In-depth training is provided for employees holding key positions in areas such as procurement and sales.

Our employees should take any indications of corruption seriously, and report them to their line manager or the Legal department. The situations in this list (which is not exhaustive) are indications of corruption, and they require particular caution:

• Business activities in a country that is known for its high level of corruption, e.g. according to Transparency International
• Suppliers or customers having close relationships with a government or a state-run enterprise
• Insufficiently transparent accounting
• Non-transparent decisions when accepting or placing contracts or orders
• Missing documentation or contracts

Our Internal Control System ensures that corruption and bribery are excluded. Any deviations are followed up.

Our Business Ethics Policy (BEP) also regulates the handling of gifts in order to prevent undue advantages and/or bribery. Bribery may have consequences under criminal law for individuals or for Vetropack as a company. Specific instructions on conduct are set out in the Group Policy for Gifts, Hospitality and Entertainment.

Conflicts of interest

Conflicts of interest arise when an employee's private interests clash with Vetropack’s interests. In our Business Ethics Policy (BEP), we provide our employees with instructions on conduct in the event of any conflicts of interest. Employees are required to report any conflicts of interest to the HR department, the local General Manager, or the Legal department. If conflicts of interest arise, the CEO and the responsible General Manager take decisions on how they should be dealt with and what consequences are involved in such cases. If conflicts of interest arise at Board of Directors level, the member concerned must recuse himself or herself from the relevant agenda item.

Whistleblowing to report breaches

We have a whistleblowing system in place that can be used to notify suspected cases of anti-competitive behaviour or other breaches of the law. Employees and third parties can access our SpeakUp Hotline via our website, and it is available in various languages. Implementation of the SpeakUp Policy also goes beyond the Hotline. On the basis of this policy, our employees undergo regular training to ensure that they are familiar with the mechanisms for whistleblowing.

The local Compliance Coordinator, the management, the Legal & Compliance department (compliance@vetropack.com) or the CEO of the Vetropack Group can also be contacted at any time in case of suspected or identified breaches or if there are any questions regarding the application of internal policies or the implementation of laws. If necessary, critical notifications are also submitted to the Board of Directors. We encourage all employees to notify suspected cases, while bearing proportionality in mind. Notifications are treated as confidential. The number of notifications in the reporting year can be found in the ‘Performance indicators’ section.

Data privacy and data security

In connection with data privacy and data security, we follow the principles of the European General Data Protection Regulation (EU GDPR) and the revised Swiss Federal Act on Data Protection (Data Protection Act, FADP), and we continuously implement the required updates to the legislation. We make use of a Data Privacy Policy to ensure that our employees are familiar with the relevant provisions. To prepare ourselves to cope with the growing number of cyber attacks worldwide, we invest continuously in technical measures to increase information security. For example: we have remodelled our network architecture and established new solutions for external connections and our external security rating. As you can also read in the Innovation section, we take the Group-wide Security Guideline as our basis for ensuring that the data of our employees and our business partners is protected.

Guidelines, policies, supervisory and control instruments

• Internal Control System (ICS)
• Business Ethics Policy (BEP)
• Code of Conduct
• Antitrust Policy
• Provisions on accepting and giving gifts and invitations
• Internal training courses to prevent anti-competitive conduct
• Antitrust risk assessments are undertaken
• Regular internal inspections (e.g. in the Accounting and Purchasing areas) to reduce the risks of corruption and bribery
• SpeakUp Hotline
• SpeakUp Policy
• GDPR guideline
• Group-wide Data Privacy Policy
• Supplier Code of Conduct
• Procurement Policy
• Supply Chain Policy
• Sedex Members Ethical Trade Audit (SMETA)

Progress and events in the reporting year

Performance indicators

GRI 2-16 Communication of critical concerns

One notification was received via our whistleblowing system in the reporting year.

GRI 2-27 Compliance with laws and regulations

There were no breaches of applicable laws that led to the imposition of significant fines or non-monetary sanctions on Vetropack as a company during the reporting year.

GRI 205-1 Operations assessed for risks related to corruption

With the exception of our plant in Ukraine which (for reasons related to the war) resumed production in the year under review, all our plants were assessed for corruption risks and audits were conducted in case of a general increase in risk.

We determine the country-specific corruption risks for our plants on the basis of the Transparency International Corruption Perceptions Index (CPI). Rank 1 indicates a low risk. Rank 180 indicates a very high risk. The ranks for our plants are as follows: Switzerland (7), Austria (22), Czech Republic (41), Croatia (57), Slovakia (49), Moldova (91), Italy (41), Ukraine (116).

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

Our entire management undergoes yearly training on Vetropack’s procedures for preventing and combating corruption, so they are informed about legally compliant conduct in these respects. In 2023, 100 percent of our employees (except for those on long-term sick leave) were made aware of our compliance policies (Code of Conduct, Business Ethics Policy, Anti-Trust Policy, Anti-Corruption Policies and Gift Policy) and/or took part in training activities.

GRI 205-3 Confirmed incidents of corruption and actions taken

There were no known incidents of corruption or cases of bribery during the year under review. No proceedings were initiated against Vetropack in these respects.

GRI 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

Vetropack is aware that risks of anti-competitive behaviour may arise. For this reason, all employees are required to adhere to the company’s Business Ethics Policy (BEP) and the Antitrust Policy.

An investigation in connection with antitrust law was launched into various glass packaging manufacturers in Italy during the year under review, and Vetropack Italy is included in this investigation.

GRI 418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data

In the year under review, no complaints were submitted to Vetropack regarding breaches of customers’ data privacy or losses of customer data.