Working to Avoid Conflicts of Interest
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 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 and Social Responsibility Committee of our Board of Directors. In the most significant cases, the committee is tasked with determining whether a conflict exists.
Our Whistleblower Hotline
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. In 2018, we made toll-free hotlines available in every country in which we do business, to make it easier to report potential violations. Potential violations can also be reported at averydennison.com /guidelinereport. Our GuideLine is operated by an independent third party, and it accepts reports in any language to accommodate our global workforce and customer/ supplier base. 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.
How we Handle Potential Ethics Violations
We take all reports of ethical violations seriously. We have a new global investigations system that enables us to investigate potential violations effectively and efficiently. Through this process we investigate at least 150 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. We also publish general investigation metrics on our internal website.
Helping Customers Navigate an Increasingly Regulatory World
The first step to corporate sustainability is compliance with regulations governing health, safety, and environmental impact. But ever-increasing government regulation of products and raw materials has become a strategic issue for many businesses. For many of our customers, meeting regulations is a necessary aspect of doing business with which they need assistance to manage.
Driven by our commitment to both sustainability and customer service, our LGM business created its Complete Compliance program. This industry-leading service offers our customers unparalleled speed and support in navigating the regulatory maze. The program helps customers ensure compliance and 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 showing that our products and materials comply with applicable regulations, enabling them to get their statements in a fraction of the turnaround time typical in our industry. The system has generated over 10,000 statements for over 800 customers in North America and Europe, helping them demonstrate compliance—and get to market faster.
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. EcoVadis audits a company’s environmental practices, fair business practices, working conditions, supply chain, and regulatory compliance. Supplier audit scores and corrective actions are made available in EcoVadis’ online system for any competitor or customer who requests the information.
atma.io Transforms Supply Chains and Advances the Circular Economy
atma.io is designed to be open, easily integrated and highly flexible allowing global organizations to connect all item-level events and product data in one end-to-end platform. Brands can communicate how a product is made and can launch new business models like recommerce, peer-to-peer commerce, and direct-to-consumer. Brands are also leveraging the technology to scale buy-back programs and provide consumers with recycling information and support their circular economy objectives.
The Ocean Cleanup
With plastic pollution reigning as a prime threat to our global environment, The Avery Dennison Foundation made a $200,000 grant to The Ocean Cleanup — a nonprofit using innovative technologies to remove plastic pollution from the world’s oceans. Our support of The Ocean Cleanup reflects our belief that innovation and sustainability go hand-in-hand.
Label and Packaging Materials
Increasing our Solar Capacity
Our commitment to reducing emissions requires looking beyond energy efficiency to strategies such as generating energy from renewable sources like solar. In Kunshan, India, we installed solar panels covering about 10,000 square meters on the roof of our Label and Packaging Materials facility. The panels generate about 800,000 kilowatt-hours annually per our power purchase agreement, reducing coal consumption by 288 tons each year and avoiding 711 tons of resulting carbon dioxide emissions.