ESG Systems

Preventitive

The aim of the Compliance Organization is to further establish and promote awareness and understanding of responsible and honest conduct among all ESG employees, suppliers and business partners.

In order to prevent compliance violations, the Compliance Organization has implemented various measures:

Code of Conduct

The ESG´s Code of Conduct applies to all ESG employees — the Executive Board, management, and all other employees. The Code of Conduct is at the heart of ESGs’ corporate culture and sets forth specific and binding guidelines for situations in which managers and employees should pay particular attention to acting responsibly. The Code of Conduct uses examples to describe how conflict situations can be addressed in everyday business.

Code of Conduct for Suppliers and Business Partners

ESG expects its suppliers and business partners and their employees to respect laws and behave responsibly and with integrity, everywhere and always. That is why ESG has a Code of Conduct for Suppliers and Business Partners, which communicates the ethical standards that ESG requires suppliers and business partners to uphold.

Communication

The Compliance Organization continuously communicates across all levels of the organization. Integrity and compliance topics are regularly featured in ESGs company media, such as newsletters, employee magazines, and the Intranet. In addition, the Compliance Organization informs and advises managers and other employees through trainings, the helpdesk service, and at internal conferences and meetings.

Compliance policies

ESG has group-wide compliance policies, which establish requirements related to anticorruption, antitrust law, the prevention of money laundering and terrorism financing, and Business Partner Integrity. These policies contain binding rules for all employees throughout the Group.

Compliance training program

ESG has a robust Integrity and Compliance training program which covers all operations and employees worldwide. Diverse training methodologies and formats are used, ranging from e-learning modules to classroom and videoconference trainings. Key content includes information about the Code of Conduct, the ESG Compliance Organization, compliance policies and guidelines, practical and realistic case studies and other relevant knowledge about anticorruption, antitrust law, and the prevention of money laundering and terrorism financing.

Exchange of experiences with experts

The Compliance Organization participates in regular exchanges on integrity and compliance topics with experts from industry and academia. Through memberships in external compliance-related initiatives, ESG supports and encourages Integrity & Compliance initiatives individually and in partnership with other companies.

Helpdesk

ESG offers a Compliance Helpdesk service to all employees, which they can use to address their integrity and compliance related questions directly to Compliance Officers via phone or e-mail. The queries made to the Compliance Helpdesk provide the Compliance Organization with an overview of the most common questions that arise in the business. The knowledge gained from these questions is used to identify new risks and trends and to identify preventative compliance measures.

Monitoring

To ensure the sustainability of the Integrity and Compliance Program, the Compliance Organization continuously reviews the Program’s effectiveness and efficiency, by tracking the implementation of measures and projects. The Compliance Organization also analyses potential weaknesses, in order to strengthen the Integrity and Compliance Program.

Tone from the Top

The Executive Board of ESG is aware of its responsibility for integrity and compliance and is committed to fulfilling this responsibility. ESGs’ Executive Board and management consider integrity and compliance to be an integral part of the corporate strategy.

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