Why Ethics & Compliance Matters
The principles set forth in The Greif Way guide our business and establish a company culture rooted in ethics and compliance. We believe that behavior influences culture and culture determines performance, which is why establishing positive behaviors is important to our business. Every day, our colleagues implement these principles, which are formalized through the policies that govern our organization.
SOX Risk-based Audits Completed
We work to ensure our internal policies are implemented and our operations are compliant with relevant regulations.
A diverse team of representatives from human resources, finance, and the legal department manages, reviews and implements each policy. We regularly review our policies and revise them as necessary to strengthen language, address emerging risks and evolving regulations and communicate best practices. Greif leverages training and audits to actively implement our policies. We require each of Greif’s over 3,600 manager-level and above colleagues to complete policy training. We actively encourage our colleagues to anonymously report ethics and compliance violations through our Ethics Hotline. A third-party provider administers the Hotline to protect the anonymity of our colleagues and is available 24 hours a day, seven days a week. Information on the Hotline, and related policies, is included in the Code of Conduct – which colleagues receive training on through Greif University and via posters at each facility. Complaints can be reported via an online portal or e-mail as well as by phone globally. Greif’s Ethics Hotline policy assures that no retaliation can be made after a complaint is filed. All reported incidents are sent to our Ethics Committee, chaired by Greif’s General Counsel, for review. Incidents are reported to the Audit Committee of Greif’s Board of Directors quarterly. In 2021, we investigated 100 percent and resolved 98.5 percent of the complaints from our Ethics Hotline.
To validate our compliance to our established policies, we conduct annual Sarbanes-Oxley Act (SOX) audits for all facilities that are material to our financial statements. Each year we ensure that facilities accounting for at least 75 percent of our revenue are included in our Sarbanes-Oxley scope. In total, Greif had 278 auditable entities in 2021. In addition to required SOX audits, Greif conducts risk-based audits at each of our facilities at least once every five years. Facilities that are audited are identified through a multi-layered process that includes management surveys, discussions, approval by executive leadership and reports to the Ethics Hotline. In 2021, we completed 38 risk-based audits following this process. We continue to strengthen our internal control environment as we leverage shared processes across locations. This year we also introduced a GRC tool, Workiva, for SOX risks and audits. The implementation of this tool will allow us to capture more data more efficiently moving forward.
In 2020, we published an updated Code of Conduct communicating our commitment to The Greif Way and defining globally applicable standards of conduct. The updated Code of Conduct presents this information in a more easily understood and digestible format, which reinforces more clearly the key behaviors we desire our colleagues to demonstrate. We accompanied the updated Code of Conduct with a new online training course that was launched in 2021 through Greif University. During 2021, we also published an updated Supplier Code of Conduct to better outline our business ethics expectations from our suppliers. In 2022, we will update our Insider Trading Policy and our Anti-Trust and Competition Compliance Policy to strengthen the language and ensure compliance with evolving regulations.
Throughout the COVID-19 pandemic, our global and regional task forces met at least weekly to develop protocols, communications and monitoring mechanisms to ensure the health and safety of our colleagues and maintain compliance with national and local regulations. Through collaboration with outside counsel, our Human Resources, Health and Safety and other Greif teams were able to stay abreast of changing regulations and develop a set of protocols that are consistent across all our plants.
Goals & Progress
In 2017, we established our first ethics and compliance goals. By the end of fiscal year 2025 we will:
- Provide online training of the Greif Code of Business Conduct and Ethics to 100 percent of colleagues with access to computers
- Provide training and information on the Greif Anti-bribery Policy to 100 percent of colleagues for whom training is relevant
- Provide online training of the Fair Treatment of Others Policy to 100 percent of colleagues with access to computers, and provide accessible and traceable information to all colleagues
In 2021, 99 percent of our management and administrative colleagues completed training on Greif’s Code of Conduct. The implementation of Greif University enabled us to further promote and distribute training to our colleagues. By the end of 2020, 83 percent of eligible colleagues completed anti-bribery training. In 2021, the anti-bribery training was part of our Code of Conduct training. The anti-bribery training will be repeated as a stand alone module in 2023. At the start of 2023, we will also launch our Fair Treatment of Others Policy training.
Colleagues With Computers Trained On Greif’s Code of Conduct
Enabled by Greif University to further promote and distribute training to our colleagues.
of Eligible Colleagues Received Anti-Bribery Training
We continue to make progress towards our 2025 target.