SCHREDER - Sustainability Report 2023

Company Information

3. Business Ethics

Code of Conduct, Policies and Procedures

In 2018, the Group Legal Department initiated Schréder’s Worldwide Integrity (WIN) programme, which sets out rigorous integrity standards for all employees worldwide. At Schréder, ethical business practices are non-negotiable. The WIN programme, exerts a significant influence on Schréder’s daily operations, core values, and organisational culture. Structured around four pillars identified through thorough legal risk management analysis, the WIN programme undergoes biennial cycles to ensure comprehensive coverage. In the latest cycle of 2023, the focus was on Governance and Anti-Bribery & Anti-Corruption

During 2023 cycle, Schréder introduced new policies aimed at reinforcing its commitment to human rights and enhancing governance practices. Specifically, the implementation of a Human Rights Policy and a Policy on policies. Moreover, to combat bribery and corruption effectively, Schréder updated its Anti-Bribery & Anti-Corruption Policy and supplemented it with e-learning modules to provide comprehensive training to employees.

In 2022, a new Code of Conduct was implemented, to promote our core values and to emphasise how we live these values in the workplace, in business and in the community. The Code of Conduct is available in 15 languages and has been adopted by the subsidiaries and acknowledged by Schréder employees. To support its internal governance, Schréder has also adopted policies and procedures that are part of the WIN programme. The Delegation of Authority and Signatory sheet constitute the authorisation framework within which our employees carry out their activities on behalf of the Group companies. The Code of Conduct and the Whistleblower Policy give all employees and anyone acting on behalf of Schréder the opportunity to internally report actual or suspected breaches of the Schréder Code of Conduct, policies and laws. Concerns can also be disclosed through the “WIN Line” which provides a telephone number and web-based portal to report matters in complete confidentiality. The “WIN Line” is available to all employees, contractors, suppliers or any third party with whom Schréder does business. In 2023, thanks to all our efforts, no major ethical incidents were reported through these channels.

Governance

Anti-Bribery & Anti-Corruption

Code of Conduct

Third Party Risk Management

Policies & Procedures (DOA & others)

Trade restrictions

Competition Law

Data Protection

In relation to suppliers and customers

GDPR

In relation to competitors

Cyber-security

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