How does your organization ensure robust business conduct through its policies? Please describe how you: • Identify, report, and investigate concerns about unlawful behavior or breaches of your code of conduct—including whether internal and external stakeholders can report such concerns; • Address anti-corruption and anti-bribery measures in line with the United Nations Convention against Corruption (or, if not, whether you plan to implement such policies and the timeline for implementation); • Protect whistleblowers by establishing internal reporting channels (including staff training and designation) and implementing measures against retaliation in accordance with applicable law (e.g., Directive (EU) 2019/1937), or, if no such policies exist, your plans to implement them and the timetable; • Promptly, independently, and objectively investigate business conduct incidents (including corruption and bribery); • (If applicable) Address animal welfare through dedicated policies; • Provide training on business conduct, specifying the target audience, frequency, and depth of coverage; and • Identify the organizational functions most at risk of corruption and bribery.
CSRD
This indicator requires you to disclose:
(a) Mechanisms for Identifying, Reporting, and Investigating Concerns:
Describe the mechanisms in place for identifying, reporting, and investigating concerns about:
Unlawful behavior.
Behavior contradicting the code of conduct or similar policies.
Specify whether these mechanisms allow reporting from:
Internal stakeholders (e.g., employees, management).
External stakeholders (e.g., suppliers, customers, civil society).
(b) Anti-Corruption and Anti-Bribery Policies:
State whether your organization has policies aligned with the United Nations Convention against Corruption.
If not, disclose:
Absence of such policies.
Plans for implementation, if applicable, including a timeline.
(c) Whistleblower Protection Measures:
Explain how your organization protects whistleblowers, including:
(i) Internal reporting channels, including:
Whether workers receive training and information on whistleblowing.
Whether designated staff handling reports receive specific training.
(ii) Protection against retaliation for workers who report misconduct, in compliance with Directive (EU) 2019/1937.
(d) Whistleblower Protection Policies:
If your organization does not have policies for whistleblower protection, disclose:
Absence of such policies.
Plans for implementation, if applicable, including a timeline.
(e) Investigation of Business Conduct Incidents:
Disclose whether your organization has procedures for investigating business conduct incidents, including:
Corruption and bribery cases.
Investigations conducted promptly, independently, and objectively.
(f) Animal Welfare Policies (if applicable):
State whether your organization has policies related to animal welfare and describe their scope.
(g) Business Conduct Training:
Describe your organization’s training programs on business conduct, including:
Target audience (e.g., employees, suppliers, senior management).
Frequency of training (e.g., annual, upon hiring).
Depth of coverage (e.g., general compliance training vs. specialized ethics programs).
(h) High-Risk Functions for Corruption and Bribery:
Identify the business functions most at risk for corruption and bribery, such as:
Procurement and supply chain management.
Sales and marketing.
Public relations and government affairs.
Financial and legal departments.
https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html#d1e39460-3-1