Archroma-Sustainability-Report-FY2018 - Page 34

In line with its third culture pillar: Customer & Market Focus, Archroma committed to the protection
of the information and data of its customers, and partners in general.
Whilst Archroma needs to have access to the information and data that is required to operate its business
and better serve the needs of its customers, the company is also extremely careful to comply with the laws
and regulations related to data privacy, fair competition or intellectual property, as well as with the
expectations of its customers and partners in this respect.
To do this, the Archroma Code of Conduct contains rules and guidelines aiming to the protection of
sensitive and confidential customer information. All our employees are trained to the Archroma Code of
Conduct to ensure that awareness is high on compliance issues, via an annual online training as well as
regular live or web-based meetings.
Archroma has a whistleblowing policy and a COMPLIANCE OFFICER in place to ensure that suspected
non-compliance incidents can be signaled, even anonymously, and properly inquired.
Archroma’s IT systems, including internet and intranet management systems, databases, Customer
Relations Management (CRM) tools and other operating systems, are strongly protected by solid firewalls
and password-protected accesses. The company has established an Information Security Officer during
the reported period.
For the most sensitive and confidential cases, projects are handled in secure online data rooms that can be
accessed only after the Archroma employees involved in the project have agreed to a non-disclosure and
confidentiality obligation.
In the reported period, Archroma recorded no incidents nor complaints related to the theft, loss, or leaks
of customer information, and no incidents of breaches of confidentiality.
As part of this core commitment of “Safe”, we believe that providing accessible and adequate information
to our stakeholders (our customers, partners, and their employees, as well as authorities, NGOs and
consumers) about the environmental and social impacts of our products is essential.
In particular, we produce information and documents aimed at allowing our stakeholders to make
informed purchasing choices or specifications, and then to handle, use and dispose of our products
in a safe, efficient and sustainable manner.
Some of this documentation is highly regulated such as:
•Material Safety Data Sheets (MSDS) - which are providing information regulated under the United Nations
Global Harmonized System (GHS) about potential health hazard, product classification, presence of
dangerous ingredients, and the instructions on Personal Protection Equipment (PPE) and safe handling.
Whereas standards such as GHS may not be applicable in all countries or may differ from one country
to another, Archroma follows the highest applicable standard wherever its products are manufactured
or delivered.
MSDS are therefore available in all countries where we operate, and available in the local language.
These are made available to concerned stakeholders via a dedicated web interface fed by a specific
Environmental Health and Safety (EHS) module within our SAP IT infrastructure: Archroma employees
and contracted warehouses, companies providing us with emergency assistance services, and key
distributors. MSDS are also proactively distributed to customers on initial orders, and subsequent annual
orders or whenever there are changes in product composition, or substance hazardous classification.
•Packaging labels - which provide GHS and transport handling information aligned on the product MSDS
in a more visual form such as danger and hazard pictograms. To ensure alignment between labels and
MSDS, Archroma is using the same specific SAP module that feeds directly to the label printers available
on all Archroma packaging sites.
Each country will either follow the GHS or have its own classification standard. In every eventuality
Archroma will comply both with the GHS and, in addition, with the standard applicable in the country
of production and destination, and in local language.
Archroma also creates documents that are not regulated but are requested from our customers by their
customers, as well as brands and retailers:
•Compliance certificates - which are established on request from customers and aim to certify compliance
of Archroma products to a number of industry standards that apply in their markets.
These standards can be edicted by
1. R
egulatory authorities, such as FDA food contact approval, the ISEGA certification by the German Federal
Institute for Risk Assessment (BfR), the Blue Angel, Nordic Swan or EU Eco-label.
2. Third-parties such as bluesign technologies or Cradle to Cradle Products Innovation Institute .
3. Brands and retailers with their own specific requirements such as restricted substance lists (RSL’s)
and/or manufacturing restricted substance lists (MRSLs).
In total, Archroma maintains a library of about 32 000 of the above mentioned documents. Annually we
receive about 10 000 requests for documents, and this is increasing as markets become more sensitive
regarding hazardous substance content and the inherent risk to the consumer and the environment.

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