- The Greif Way establishes our values and guides our business activities, creating a strong company culture and daily actions rooted in doing the right thing.
- We conduct annual Sarbanes-Oxley Act (SOX) audits of facilities material to our financial statements to validate compliance with established policies and regulations.
- In 2022, we updated our Insider Trading Policy and Anti-Trust and Competition Compliance Policy and launched a new online anti-trust training course.
Why Ethics & Compliance Matters
The Greif Way guides our business and establishes a company culture rooted in ethics and compliance. This culture is influenced by the ethics of the actions we take on a day-to-day basis. Our formalized policies and procedures govern our organization and empower colleagues to make decisions that align with our culture. Failure to uphold these principles invalidates the work we do. Thus, we strive to mitigate adverse impacts on our employees and the communities in which we operate.
Greif maintains a broad set of policies that promote ethical behavior and support us in meeting our compliance obligations:
Together for Sustainability
Since 2014, Greif has worked with Together for Sustainability (TfS) to help build an industry-wide sustainability standard for suppliers to chemical manufacturers. On behalf of its more than 20 chemical manufacturer members, TfS audits supply chain partners on more than 30 management, environment, health and safety, labor and human rights and governance criteria. TfS distributes results to their members to support purchasing decisions, replacing the need for company-specific audits and holding suppliers to a consistent standard for the industry. Greif facilities have been audited since 2014, achieving an average score of 94 percent, indicating no major concerns at our facilities. In 2021, TfS conducted an audit of our Mendig, Germany facility.
TfS Audit Performance:
- RIPS Naperville, Illinois: 100%
- RIPS Mendig, Germany: 98%
- RIPS Cologne, Germany: 98%
- RIPS Lockport, Illinois: 98%
- RIPS Europoort, Netherlands: 97%
- RIPS Usti, Czech Republic: 95%
- RIPS Campana, Argentina: 83%
- RIPS Shanghai, China: 80%
A diverse team of representatives from Human Resources, Finance and the Legal Department collectively manages, reviews and implements each policy. As part of our continuous improvement processes, we regularly review and revise our policies to strengthen language, address emerging risks and evolving regulations and conform with best practices. Greif’s Global Regulatory Steering Committee, assembled in 2022, is responsible for identifying and proactively addressing regulatory changes and risks. We also leverage training and audits to effectively implement our policies, requiring each of Greif’s over 3,300 manager-level and above colleagues to complete policy training. In 2023, we will look to better track training data and make content easier to digest. We 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 24/7. We include information on the Hotline and related policies in the Code of Conduct, on which all colleagues receive training through Greif University. Hotline information is also shared through posters at each facility. Complaints can be reported via an online portal or e-mail and 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 quarterly to the Audit Committee of Greif’s Board of Directors. In 2022, we investigated 207 reports (100 percent) and resolved 99.5 percent of the complaints from our Ethics Hotline.
We conduct annual Sarbanes-Oxley Act (SOX) audits to validate the compliance of our established policies. This encompasses 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 260 auditable entities in 2022. To supplement required SOX audits, we conduct risk-based audits at each facility at least once every five years. Facilities are identified for audits through a multi-layered process that includes management surveys, discussions, approval by executive leadership and reports to the Ethics Hotline. In 2022, we completed 17 risk-based audits following this process. As we standardize processes across global operations, we will continue strengthening our internal control capabilities related to facility audits.
Greif also considers global trends and events when viewing ethics and compliance. In 2022, the EU and European and other authorities imposed sanctions related to the Russia-Ukraine conflict. Greif established an EU Sanctions Steering Committee to discuss and implement sanction compliance measures. Our Corporate Legal Department advises and monitors sanction laws continuously. Greif also developed procedures and trained colleagues to comply with sanction laws. We will continue to monitor this risk and ensure compliance with these evolving sanctions. Additionally, as we have fully integrated our response to COVID-19, global and regional task forces meet on an as-needed basis to develop protocols, communications and monitoring mechanisms to ensure the health and safety of our colleagues and maintain compliance with national and local regulations. As the pandemic endures, we will continue to track cases and enforce safety precautions at our facilities.
Goals, Progress & Performance
- Provide online training of the Greif Code of Business Conduct and Ethics to 100 percent of colleagues with access to computers by the end of fiscal year 2025.
- Provide training and information on the Greif Anti-bribery Policy to 100 percent of colleagues for whom training is relevant by the end of fiscal year 2025.
- 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 by the end of fiscal year 2025.
In 2020, we published an updated Code of Conduct that communicates our commitment to The Greif Way and defined globally applicable standards of conduct. This update presents information in a more easily understandable and digestible format, reinforcing the key behaviors we desire our colleagues to demonstrate. We accompanied the updated Code of Conduct with a new online training course launched in 2021 through Greif University. During 2021, we also published a revised Supplier Code of Conduct to better outline our business ethics expectations from our suppliers. In 2022, we updated our Insider Trading and Anti-Trust and Competition Compliance policies to strengthen language and ensure evolving regulation compliance. Included in this update was a new online anti-trust training course required for all professional and administrative colleagues. Since the launch of this training in March 2022, we have seen a completion rate of 91.5 percent. In 2023, we will roll out training for our Human Rights and Fair Treatment of Others Policy to further our ethics and compliance efforts.
To analyze our performance regarding ethics and compliance, we monitor our colleagues’ completion of applicable training. In 2022, 96.9% of management and administrative colleagues received and completed training related to our Code of Conduct.