Being a force for good begins with how we do business—with building a culture rooted in eight closely held values and setting high expectations for compliance and transparency throughout our operations. That’s why we work constantly to ensure that our employees and business partners know, understand, and live up to our values, Code of Conduct and high ethical standards.
Governance
The Audit and Finance Committee of our Board of Directors oversees adherence to the Avery Dennison Code of Ethics and ensures that our Chief Executive Officer, Chief Financial Officer, and Chief Accounting Office act professionally and ethically in fulfilling their responsibilities and set an example for every employee. Additionally, our Chief Compliance Officer is responsible for implementing our Code of Conduct throughout the enterprise, with oversight from the Governance Committee of our Board of Directors.
Code of Conduct
Our Code of Conduct applies to all our directors, officers and employees and reflects our values of integrity, courage, external focus, diversity, sustainability, innovation, teamwork and excellence. It includes messages from company leadership, detailed information on the ethical risks our employees are most likely to encounter, and case studies to provide guidance on complex ethical questions. Our Code of Conduct has been translated into over 30 languages and our leaders affirm their commitment to comply with it when they join our company and annually thereafter.
We train employees on the Code at least biannually. Annually, we conduct an online training program generally consisting of four courses covering specific risks addressed in the Code. Computer-based employees are required to complete the training each year. To ensure that the policies and principles encompassed in our Code of Conduct reach all our employees, we provide three “Talkabout” toolkits globally each year, also in more than 30 languages. The kits are based on topics from the Code of Conduct. Managers are required to use the kits to engage in meaningful discussion with their teams.
Annual Compliance Certification
Each year, we require all employees at the level of manager and above to complete a compliance certification in which they must disclose, among other things, whether they or any of their immediate family members have a job, contract, or other position with an entity that has commercial dealings with our company. Employees in individual contributor jobs at risk for potential conflicts are certified every other year. In all cases, disclosures are reviewed by our corporate compliance department in consultation with our law department and senior management to determine whether the disclosed activity significantly influences our business. Our Chief Compliance Officer provides a report on the disclosures to the Governance Committee of our Board of Directors. In the most significant cases, the committee is tasked with determining whether a conflict exists.
Business Conduct GuideLine
Our Business Conduct GuideLine is a whistleblower hotline available at all hours for employees or third parties to report potential violations of our Code of Conduct, anonymously if they so choose. We have toll-free hotlines available in every country in which we do business to make it easy to report potential violations. Potential violations can also be reported at averydennison.com/guidelinereport. Our GuideLine is operated by an independent third party and accepts reports in any language to accommodate our workforce, customers, and suppliers worldwide. All reports are investigated under the direction of our Chief Compliance Officer in consultation with the law department and senior management and with oversight from the Governance Committee. We prohibit retaliation for good-faith reporting.
Investigating Ethics Violations
We take all reports of ethical violations seriously. Our global investigations system enables us to investigate potential violations effectively and efficiently. Through this system, we investigate at least 200 reports annually. When violations occur, we take corrective action and discuss significant substantiated matters, trends, and geographic “hotspots” with our senior leadership and Board of Directors to promote transparency, good governance, and ongoing learning.
Helping Our Customers Comply With Regulations
Ever-increasing government regulation of products and raw materials has become a strategic issue for many of our customers. To help them navigate the regulatory maze, our LGM business created its Complete Compliance program. This industry-leading service offers our customers unparalleled speed and support in ensuring that the solutions we provide comply with all applicable regulations. The program helps customers stay up-to-date on regulatory developments through LinkedIn and Twitter feeds, “Hot Topics” columns in customer newsletters, self-service features on our website, and direct help from our compliance experts. The Complete Compliance Portal allows customers to download customized self-service compliance statements, enabling them to get their statements -- and get to market -- quickly.
Ensuring Supplier Compliance
As part of the Sustainability Procurement Program launched by our LGM and IHM businesses, we regularly assess key suppliers to ensure they’re complying with applicable regulations. With our partner, EcoVadis, LGM and IHM review suppliers representing over 80% of our direct spend on materials. When a supplier does not meet our expectations, we connect with the supplier to discuss opportunities for improvement and establish corrective action plans when needed. When corrective action is required, suppliers have two opportunities to improve their score before we begin evaluating alternative materials or sources. Supplier audit scores and corrective actions are made available in EcoVadis’ online system for any competitor or customer who requests the information.
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