Code of Conduct

"Innovia Films is a market-led, customer-oriented company which operates in a global market place meeting customer needs through strong research and development, high quality products and responsive service.

We are focused not only on our own success but on the success we can bring to our customers' operations through our high performance, added value films.

Our mission is to be recognised by our customers as a leading value-added speciality film supplier and a supplier of choice through: 

In pursuing this mission, our success is underpinned by a set of values which are at the heart of how we do business.

These values are important to us not only because they impact our business performance but also because they impact our relationships with every individual and every business we come into contact with.

One of the six key values set out above is integrity and this touches many aspects of our business. This Code of Conduct provides greater detail on how this is applied within Innovia Films. In short, we intend to continue being a successful Group for the benefit of our shareholders, our employees, our suppliers, our customers and our communities. Where there is a right way and a wrong way to achieve this we will always choose the right way."


David Beeby
CEO
December 2010

 

This Code of Conduct applies to Innovia Films, its subsidiaries throughout the world, joint ventures over which Innovia Films has management control and to every employee, officer, director and agent of those companies. Each individual within the Group and each agent is informed of its contents upon appointment and thereafter on a periodic basis to ensure that they are aware of the provisions of this Code of Conduct.

Although we are not in a position to require that all the provisions within this Code of Conduct are respected by all third parties with whom or which the Group has business dealings, we would expect that the principles set out herein are recognised by the policies of those third parties. Business principles that were inconsistent with those set out herein could influence our future dealings with such third parties, depending upon the nature and extent of the inconsistency.
 

We believe that the ten principles of the United Nations Global Compact set the standard to which we must endeavour to adhere at all times and these impact to varying degrees on our Code of Conduct:
 

Principle 1  Businesses should support and respect the protection of internationally proclaimed
                     human rights; and
Principle 2  make sure that they are not complicit in human rights abuses.

 

Principle 3  Businesses should uphold the freedom of association and the effective recognition 
                     of  the right to collective bargaining;
Principle 4  the elimination of all forms of forced and compulsory labour;
Principle 5  the effective abolition of child labour; and
Principle 6  the elimination of discrimination in respect of employment and occupation.

 

Principle 7  Businesses are asked to support a precautionary approach to environmental
                     challenges;
Principle 8  undertake initiatives to promote greater environmental responsibility; and
Principle 9  encourage the development and diffusion of environmentally friendly technologies.

 

Principle 10 Businesses should work against corruption in all its forms, including extortion 
                      and bribery.

 

We respect the human rights and the dignity of all employees. We endeavour to treat our employees fairly and honestly. We strive to maintain a safe, secure and healthy workplace. We also strive to follow all applicable employment laws and regulations.

We are committed to equal opportunity in all aspects of employment for employees and applicants. We will provide a workplace free from any form of discrimination (other than on the basis of merit) or harassment, including sexual harassment.

We recognize the needs of individuals to achieve professional and personal balance in their lives. We also respect employee privacy and will acquire and retain only that employee personal information that is required for operation of the Group’s business or required by law. 
 
 

We are committed to providing safe and healthy work environments at our facilities for all our employees, visitors, contractors and vendors. It is our policy to provide employees with a workplace free from the use of illegal substances. In order to create an environment free from threats, violence and intimidation, we are committed to a policy of zero tolerance for violence.

We are dedicated to designing, constructing, maintaining and operating facilities that protect our people and physical resources. It is our policy to comply with all applicable health and safety laws and regulations, provide and require the use of adequate protective equipment and measures, and insist that all work be done in a safe and responsible manner. It is the responsibility of each employee to follow all Group policies and procedures related to workplace health and safety and to work in a manner that ensures their own safety and the safety of colleagues.

 

We are committed to strict compliance with the laws and regulations that apply to our business activities around the world. Failure to comply would undermine the integrity value standard of the Group and is simply not acceptable. Turning a blind eye to non-compliance is not an acceptable option either as it condones unacceptable behaviour or actions. 

 

We recognize the importance of laws which have been promulgated to prohibit unethical and unfair business practices. In all our dealings with customers and suppliers, we will:

 

The intent of business gifts and entertaining should be to build relationships or offer courtesy – reasonable, customary and occasional gifts and entertainment may be accepted and offered under those circumstances. However, gifts and entertainment should not influence, attempt to influence or be of such nature that they might appear to influence the recipient’s objectivity in making decisions. In the case of any dealings with government officials, gifts and entertainment may be subject to additional specific regulations or may be prohibited and no such gifts or entertainment should be provided unless the giver has checked that there are no legal impediments.

Where gifts or entertainment are beyond the limit of what is acceptable, Innovia Films would view such activities as bribery. In any event, gifts with a monetary value of more than €100 are prohibited unless approval is given in advance by a member of the Executive Team. Entertainment should not be excessive or out of the ordinary given typical practice with similar accounts without prior approval from a member of the Executive Team.

 

The Group has a zero tolerance for bribery and corruption. This policy extends to all the Group’s business dealings and transactions in all countries in which it or its subsidiaries or associates operate.

It is strictly prohibited to give or offer, directly or indirectly, anything of value to a third party to corruptly influence that person’s business decision or to gain an unfair advantage. It is also strictly prohibited to seek or receive, either directly or indirectly, anything of value with the intent of that influencing a business decision of the Group.

No employee will suffer demotion, penalty or other adverse consequences for refusing to pay bribes even if such refusal may result in the Group losing existing business or failing to secure new business. Furthermore, the Group will not tolerate any actions by any individual within the business to seek to threaten, harass or dissuade an employee who is intent on complying with this policy.

In certain spheres of the Group’s operations, there are activities where the decision making processes of third parties can impact upon the timeliness and efficiency of achieving progress with business objectives. From time to time, there may be perceived opportunities to expedite such decision making processes by making additional payments to secure a prompt or trouble free decision. However, where such payments would fall outside the scope of legally established fee structures they would constitute facilitation payments which are considered to be bribes and are prohibited by the Group.

If an individual has doubts about a payment or a payment request and considers that it might be a facilitation payment then the payment should only be made if the official or third party can provide a formal receipt or written confirmation of its legality. If a demand for payment is accompanied by threat of physical harm then safety should be put first, the payment should be made and reported immediately to senior management.

 

All actual or apparent conflicts of interest between personal and professional relationships must be handled honestly and ethically. Any potential conflict of interest should be disclosed as soon as it is recognised. Individuals should also seek to distance themselves from conflicted decisions as much as practical and with the full knowledge of the Company’s management. A conflict of interest is any personal interest which could influence a decision in relation to dealings with another party. Potential or actual conflicts of interest should be disclosed to your management for resolution. Non-disclosure of a clear conflict of interest, for whatever reason, demonstrates either naivety or a wilful breach of trust. A disclosure that knowingly fails to reveal fully all pertinent and specific details is dishonest and intentionally deceitful.

Examples of conflicts that must be disclosed and resolved include, but are in no way limited to:
 

 

Confidential or proprietary information includes all non-public information that, if disclosed, might be of use to competitors or might be harmful to Innovia Films, our suppliers or our customers. This would include product formulation, manufacturing processes, sales plans, pricing details, concepts, research and development, suppliers, customers, financial information, personnel and employment matters

Employees always have a duty to protect the confidential information of the Group and our business partners. Confidential information may not be disclosed to anyone outside the business unless there is a clear business need to do so and there is a belief that the disclosure will not harm or embarrass Innovia Films or its business partners. In the majority of cases, the party receiving the information should be asked to sign a confidentiality agreement committing to maintain the information’s confidentiality.

 

The Group believes in contributing to society and encourages employees to be involved in community activities in the areas in which they live and work. 
 
 

Innovia Films is committed to making continuous improvements in the management of our environmental impact. We will work with others to promote environmental care, increase understanding of environmental issues and disseminate good practice.
 

Compliance with this Code of Conduct is an essential part of our business success. The Innovia Films Board is responsible for ensuring these principles are applied across the entire Group. The Chief Executive Officer is responsible for implementing these principles and he is supported in this by the Executive Directors of the Group. The continuing appropriateness of the Code is reviewed at least annually to ensure that it continues to reflect the ethical standards established by the Group.

All employees are expected to display responsible and ethical behaviour, to follow consistently both the meaning and intent of this Code and to act with integrity on a daily basis. Managers are expected to ensure that our business processes and practices reinforce the Code, to serve as positive role models by establishing and adhering to high ethical standards, and to create an ethical culture by encouraging and rewarding actions that are consistent with the Code.

This Code cannot provide definitive answers to all questions. For that, we must rely on each person's judgment and integrity. Individuals are encouraged to seek guidance when a situation may not be clear. Your Human Resources manager or any Group Board Director will respond to questions and issues of interpretation about this Code.

All individuals subject to the scope of this Code of Conduct are expected to report any breaches of the Code of which they become aware. In normal circumstances, a breach should be reported to a Group Board Director. If there is a suspicion of a breach then this should also be reported. Deliberately false or malicious accusations will not be tolerated. However, anybody making an accusation or expressing concern in good faith will not be subject to any action in respect of the disclosure. Their identity will not be revealed unnecessarily and they will be protected by the Company against any form of victimisation.

In the event that an individual has concerns over revealing their identity when seeking to report a breach of this Code then they should contact the Chairman of the Audit Committee who is a non-executive director of the Group and is therefore independent of the senior management team.


By Order of the Board of Directors
David Beeby, Chief Executive
December 2010