Ethics & Compliance
Creating a culture, The Greif Way.
Highlights
- We strengthened our training initiatives by launching human rights and fair labor practices training for all colleagues on the Greif University platform.
- Our redesigned Human Rights Review process for facilities was launched in 2023, underscoring our commitment to achieving best-in-class standards.
- We remain focused on supporting seamless integration and ensuring our acquired businesses align with The Greif Way.
- In 2023, 94.8 percent of management and administrative colleagues completed Code of Conduct training.
Why Ethics & Compliance Matters
Our commitment to The Greif Way is fundamental to our business. It informs our conduct, and sets the foundation for Greif’s culture, which is deeply rooted ethical practices and integrity. Our policies and procedures govern our organization and help ensure we are carrying out our mission responsibly and in compliance with applicable regulations. Our colleagues drive our organizational culture, and we expect our colleagues to align with our ethical standards. By setting high ethical standards, we aim to prevent and address potential negative impacts on our colleagues and the communities where we operate.
Governance
Greif maintains a broad set of corporate policies that promote ethical behavior and support us in meeting our compliance obligations detailed on our Governance, Policies & Partnerships page.
A cross-functional team from Human Resources, Finance and the Legal Department collectively manages, reviews and implements each policy. To ensure our policies remain practical and current, we routinely update them by incorporating best practices and responding to evolving risks and regulations. Policies are reinforced through audits and training administered to all colleagues at the manager level and above.
As a global business, we are subject to regulations that vary across regions. Greif’s Global Regulatory Steering Committee proactively manages regulations, such as the EU’s Packaging and Packaging Waste Regulation (PPWR) and Carbon Border Adjustment Mechanism (CBAM), and Extended Producer Responsibility (EPR) regulations in the U.S., by tracking upcoming regulatory changes and potential risks. This strategic approach enhances our compliance posture and optimizes efficiency and resource allocation compared to reactive measures.
We aim to foster an environment of transparency. Colleagues and external stakeholders can confidentially report ethics concerns through our third-party, 24/7 Ethics Hotline. We communicate hotline information through our Code of Conduct, which we include in Greif University training and posters throughout our facilities. Internal and external stakeholders can submit complaints via the Ethics Hotline website, e-mail and phone globally, and we maintain a strict no retaliation policy. The Ethics Committee, led by Greif’s General Counsel, reviews all incidents and submits quarterly reports to the Audit Committee. After review, incidents are assigned to the appropriate department within or outside of Greif for appropriate resolution. In 2023, we investigated 100 percent of the 236 reports that were made through our Ethics Hotline, and resolved all issues that were raised.
We conduct Sarbanes-Oxley Act audits annually to ensure compliance with established policies across financially material facilities. This includes ensuring that facilities responsible for at least 75 percent of our revenue are included in our Sarbanes-Oxley scope. In 2023, Greif had 270 auditable entities. Each facility also undergoes risk-based audits at least once every five years; we completed 24 audits in 2023. Audit locations are selected using a comprehensive process involving Leadership Council surveys, discussions and approval by executive leadership and Ethics Hotline reports. As our business expands and we drive our One Greif approach, we remain committed to enhancing our internal control and audit capabilities.
As a global organization, we monitor global trends to align our ethics and compliance approach. In 2022, we established an EU Sanctions Steering Committee to oversee and enforce sanction compliance measures. Our Corporate Legal Department advises and monitors sanction laws continuously. Greif also developed procedures and training on compliance with sanction laws for colleagues across different business functions globally. Ongoing vigilance is maintained to monitor and comply with evolving sanctions.
Goals, Progress & Performance
2025 Goals:
- 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 FY25.
- Provide training and information on the Greif Anti-Bribery Policy to 100 percent of colleagues for whom training is relevant by the end of FY25.
- Provide online training on 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 FY25.
Greif is committed to continuously improving our policies and systems. In 2023, we strengthened our training initiatives by launching human rights and fair labor practices training for all colleagues on Greif University. Additionally, we updated our Child Labor Policy and Human Rights Policy to strengthen language and articulate our commitments more clearly to our stakeholders. We also launched our redesigned Human Rights Review process for facilities, underscoring our commitment to achieving best-in-class standards. We aim to complete this review for every Greif facility by the end of 2025. Please see the Human Rights & Fair Labor Practices section for more information on these initiatives.
We track colleagues’ ethics and compliance training to support an ethical and compliant workplace and ensure our colleagues understand our expectations. In FY23, 94.8 percent of management and administrative colleagues completed Code of Conduct training. Additionally, 97.6 percent of relevant colleagues completed training on our Anti-Bribery Policy in FY23. With the recent addition of LinkedIn Learning to our business, colleagues now have access to thousands of educational courses, many of which relate to business ethics issues.
At the end of 2023, over 94.2 percent of professional colleagues and 81.5 percent of production colleagues completed training on our human rights policies and procedures which includes training on the Fair Treatment of Others Policy, resulting in an overall completion rate of 83.3 percent for Greif as a whole.
Given the recent acquisition of several new businesses, we have focused our efforts on supporting seamless integration and ensuring alignment with Greif standards and The Greif Way. Through our formalized integration process, we emphasize the importance of establishing policies and completing necessary training for our new colleagues.
