Compliance

Ethical conduct and rejection of unlawful conduct form the basis for our daily work. We understand Compliance as meaning adherence to global and national laws and frameworks, together with integrity in business activities. Compliance benefits our corporate culture; it is essential for all our business relationships, and thus provides the basis for our commercial success. Breaches of the law would impair Vetropack’s reputation and negatively impact the trust demonstrated by our suppliers, business partners and customers. Such breaches could also lead to legal consequences, including financial penalties.

Concepts, policies and measures

Embedding ethical conduct

Our fundamental ethical values are reflected in our corporate culture, which is based on the values of integrity, reliability and transparency. Our Code of conduct sets out these values, and also stipulates compliance with legal regulations and guidelines applicable throughout the Group. On recruitment, our employees sign the Code of conduct to signal their commitment to these principles. They include (among others) the prohibition of discrimination, ensuring fair competition, and the avoidance of bribery, corruption and fraud. Further principles include (but are not limited to) respect for human rights in accordance with the Universal Declaration of Human Rights and the conventions of the International Labour Organization (ILO). This includes the strict rejection of child and forced labour, the guarantee of freedom of association, and the right to collective bargaining.

Our Business ethics policy contains instructions on conduct that are applicable throughout the Group regarding legally compliant and ethical business activities. This policy includes the prohibition of bribery and corruption, the avoidance of conflicts of interest, the guarantee of fair competition, and compliance with antitrust law.

At Vetropack, the General Managers of the individual sites are responsible for compliance. They are supported by instructions on conduct from the Legal department.

Ethical principles in the supply chain

We also expect our suppliers to take account of our values and to behave in a legally compliant and ethical manner. Our Supplier code of conduct and Supply chain policy lay the foundations for compliance in our supply chain. The Supply chain management section describes in detail how we implement ethical and legal standards in the supply chain.

Competition and antitrust law

The high concentration of the European glass packaging market gives rise to challenges in terms of competition and antitrust law. Our Anti-trust policy obliges all employees to comply with the applicable competition and antitrust laws. It prohibits price fixing and market/customer allocation agreements with competitors.

Every three years, we carry out antitrust risk assessments to evaluate the entire Vetropack Group as well as our market environment. We review relevant regulations and internal processes. Training courses on antitrust law are conducted annually.

Combating corruption

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.

We provide our employees and our suppliers with regular information on avoiding corruption. The relevant guidelines are established in our Code of conduct and Business ethics policy. They prohibit offering, demanding or accepting facilitation payments or bribes. In order to reduce corruption and bribery risks, we regularly implement internal inspections. Specific training is provided for employees holding key positions in areas such as procurement and sales. Our employees should report suspected cases to their line manager or the Legal department.

Corruption risks arise in connection with business activities in countries with high levels of corruption according to Transparency International. Our Legal department carries out corruption risk assessments every three years to determine the current situation. The Vetropack Group operates largely in countries with a moderate to very low Corruption Perceptions Index (CPI). There is a heightened risk in the Republic of Moldova and Ukraine.

Our Business ethics policy also defines the handling of gifts in order to prevent undue advantages and/or bribery. Bribery may lead to consequences under criminal law for individuals or for Vetropack as a company. The Group policy for gifts, hospitality and entertainment sets out specific instructions on conduct.

Handling conflicts of interest

In our Business ethics policy, we provide our employees with instructions on conduct in the event of any conflicts of interest. All employees are obliged to avoid conflicts of interest or to report them to the HR department, the local General Manager, or the Legal and Compliance department. In the event of conflicts of interest, the CEO and the responsible General Manager decide what approach should be taken. If conflicts of interest arise at Board of Directors level, the member concerned must recuse himself or herself from the relevant agenda item.

Whistleblowing system

We have set up a whistleblowing system for reporting identified or suspected breaches of the law. Our SpeakUp Hotline, which forms part of our SpeakUp policy, can be accessed by employees and externals via our website, and it is available in various languages. All notifications are treated as confidential. On the basis of the SpeakUp policy, our employees undergo regular training to ensure they are familiar with the mechanisms for whistleblowing.

In case of suspected unlawful conduct, and for questions about the application of internal guidelines and policies or about the implementation of laws, the following individuals or departments may also be contacted: the local Compliance Coordinator, the management, the Legal and Compliance department (compliance@vetropack.com) or the CEO of the Vetropack Group. If necessary, critical notifications are also forwarded to the Board of Directors.

Data privacy and data security

In respect of 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). To ensure protection of our employees’ and business partners’ data, we are guided by the Group-wide Security guideline, and we align our information security processes with the ISO 27001 standard. The Director of Information Security and the Information Security Board bear the main responsibility for preventing cyber attacks and for data privacy. To prepare ourselves for the growing number of cyber attacks worldwide, we invest continuously in technical measures to increase information security. In order to implement the Data privacy policy, our Data Protection Coordinators organises annual training courses on data privacy.

Compliance training

We provide regular training and implement sensitisation measures to raise our employees’ awareness about legally compliant business practices. For this purpose, the Legal and Compliance department conducts annual training courses on compliance at all our sites. As part of the onboarding process, new employees also participate in training programmes that cover the topics mentioned above. In addition, employees in key positions receive specific training that focuses on preventing corruption, excluding bribery, and antitrust law. We conduct internal audits to verify the implementation of these measures.

Our internal learning platform offers an online course about compliance which presents Vetropack’s values and principles in various areas of business. By taking this course, employees learn about the content and application of the following guidelines and policies: the Code of conduct, the Business ethics policy, the Antitrust policy, and the Group policy for gifts, hospitality and entertainment. Employees are required to read these instructions on conduct and to confirm that they have understood the content. For employees who have no computer workstation, we provide on-site training; participation is confirmed by signature.

Progress and events in the reporting year

Performance indicators

GRI 2-16 Communication of critical concerns

In the year under review, two notifications (2023: one) were submitted through our internal whistleblowing system. In both cases, the issues were not relevant to compliance. Additionally, several notifications were received from external stakeholders. These notifications also concerned topics unrelated to compliance and therefore did not require further investigations.

GRI 2-27 Compliance with laws and regulations

There were no breaches (2023: zero) 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

In the year under review, all our plants (2023: all plants with the exception of our plant in Ukraine) were assessed for corruption risks and audits were carried out in case of an increased risk. We determine the country-specific corruption risks for our plants on the basis of the Transparency International Corruption Perceptions Index (CPI).

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 2024, 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 policy and gift policy) and/or took part in training activities (2023: 100 percent). Furthermore, in 2024, all locations conducted trainings on antitrust-related topics

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 (2023: zero) 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 Anti-trust policy. In 2023, an investigation in connection with antitrust law was launched into various glass packaging manufacturers in Italy, and Vetropack Italy is included in this investigation. The authority has extended the investigation period until the end of 2025.

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 (2023: zero).