Archroma-Sustainability-Report-FY2018 - Page 39



SAFE
COMPLIANCE
Archroma fully supports and complies with the 1948 United Nations Universal Declaration of Human
Rights. Archroma does not undertake any business with any country or regime with known human rights
abuses. Archroma fully supports and complies with United States Sanctions Laws and the European Union
Restrictive Measures and regulations.
For Archroma, there is no other way to do business than in a sustainable and responsible way. Archroma is
therefore committed to act with integrity and in strict compliance with the law.
Archroma has a Code of Conduct for employees, signed by the Chief Executive Officer and publicly available,
which sets out the binding rules and guidelines to the employees and officers of Archroma. This enables
employees to rely on the Code as a navigation guide, and one another’s good judgement, to uphold a high
standard of integrity for the individual and Archroma.
Each employee is required to give a personal commitment to meeting the Code of Conduct; and in the
reporting period, all employees were trained on the Archroma Code of Conduct, followed by a questionnaire
requiring 80% pass rate. Archroma conducts re-training on an annual basis.
Archroma takes responsibility for its employees, its customers, its suppliers, its other stakeholders and the
environment in order to achieve profitable long-term business development. Archroma commits maintaining
ethical and sustainable operation and business development in all activities according to its own Code of
Conduct and Responsible Care®.
The Archroma Code of Conduct links all Archroma employees around the world in a collective commitment
to integrity and excellence in all they do, by providing tools that will guide them in making consistent,
sustainable decisions.
Archroma also has a WHISTLEBLOWING POLICY in place that allows the anonymous reporting of any
suspicious situation of violations of our Code of Conduct or the law.
In addition, Archroma and its affiliated companies are committed to integrity and an open culture where
everybody feels secure in seeking advice or raising concerns, and has confidence that reports are handled
in a professional and transparent way. To help in its ability to provide advice and enable employees to
report concerns or misconduct, the Archroma Code of Conduct and Whistleblower Policy are essential
element of integrity is the commitment to an open culture where people feel secure in seeking advice and
in raising concerns. Archroma ensures a retaliation-free environment to anyone who comes forward in
good faith to ask questions or report violations.
It is a duty and responsibility of all employees and associated persons to take whatever reasonable steps
are necessary to ensure compliance with this policy. According to the company’s Code of Conduct and
Whistleblower Policy, employees shall immediately disclose to the company any knowledge or suspicion
of plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with
the business of the company.
Archroma has set up a Compliance Committee and a COMPLIANCE OFFICER holding regular meetings and
responsible for investigating any potential violations in a professional and consistent manner, while
safeguarding fundamental legal principles such as confidentiality, fairness and objectivity.
Any breach of the Code of Conduct is reported to the Compliance Committee, investigated and if necessary
prosecuted according to the company’s disciplinary procedure and/or criminal action, should the case
apply.
Regular internal audits are performed. The audit plan is based, in addition to other elements, on the
Corruption Perception Index, that is published annually by Transparency International.
Risk Management
Risk management is an ongoing area of attention at Archroma. The company has a Risk Management
Policy in place since 2015 and has been undergoing regular risk evaluation reviews.
Archroma identified early on the need to assess our risk management and led to a first risk assessment
workshop in November 2015. This initial review was performed following the most generally accepted
standards for risk mapping; being done every 3 years and leading to address defined action plans supported
by the Leadership Team and Board of Directors.
At the end of our FY2017, Archroma decided to strengthen its approach to risk management and assigned
the responsibility to a dedicated Head of Risk Management & Internal Audit, reporting to a member of the
Leadership Team, namely the Chief Finance Officer. Therefore risk management is under the responsibility
of the Head of Risk Management & Internal Audit who works with the support of external risk management
specialists which will be contracted at the beginning of FY2019.
With that nomination, Archroma has a risk assessment manager dedicated to operate as a catalyst to identify,
map and address risk areas in the company.
Archroma strictly prohibits all forms of corruption and any business conduct that could create the
appearance of improper influence. Archroma applies a zero tolerance policy regarding bribery in every
kind of commercial setting.
These principles are summarized in three rules:
1.No bribery under any circumstance;
2.Do not accept or offer kickbacks, even if moderate in value;
3.Third parties hired by Archroma are subject to these above principles.
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