A year in review Economic / Governance Environment Social Appendix Governance & business conduct / ethics / transparency Ethics & Compliance Officer with local compliance officers Anti-bribery & anti-corruption Disclosure 205 – 2 and corporate functions. Anti-bribery and anti-corruption compliance are managed as Communication and training about focus compliance risk areas within our Compliance anti-corruption policies and procedures Other compliance processes include the selection and Management System. The approach is anchored in our Basic compliance training on the updated Principles of engagement of third-party agents and distributors and the Principles of Conduct, which state that Givaudan has zero Conduct, mandatory for all permanent employees once every global supplier selection process of the Procurement tolerance for bribery and corruption and does not make two years, includes sections on bribery and corruption and organisation. The Corporate Ethics & Compliance Officer reports facilitation payments. This principle is further detailed in two the ethical handling of issues linked to gifts, entertainment regularly to the Board of Directors, the Audit Committee of the policies: Givaudan’s Global Anti-Bribery, Gift, Entertainment and hospitality. Board, the Executive Committee and the CEO. and Hospitality policy, first enacted in 2011 and last amended in 2019, includes prohibitions on corruption, bribery, inappropriate We have also introduced specific anti-bribery training for We monitor for compliance via numerous measures. We ask all gifts as well as mechanisms for the approval and reporting of employees with significant contact to external stakeholders. Local Compliance Officers to certify the compliance of their gifts, entertainment and hospitality. Givaudan’s Global This group of senior managers includes all members of the country organisations with the laws and with Givaudan’s Charitable Giving and Community Support policy, also last Executive Committee and other employees whose work policies once annually. amended in 2019, provides mandatory guidelines on permitted involves regular and direct contact with external stakeholders. charitable causes, due diligence on recipients, and reporting. Givaudan senior managers have been invited to complete this Disclosure 102 – 17 The Principles of Conduct and the two policies are available to specific anti-bribery training since 2013. The latest training Mechanisms for advice and concerns employees in all major Company languages. was rolled out from Q4 2021 onwards. The completion rate about ethics for Givaudan employees, including Naturex employees, Givaudan’s various mechanisms for advice and concerns about The Corporate Ethics & Compliance Officer regularly reviews currently stands at 85%. ethics also contribute to monitoring activities. We have a corruption and bribery risks as part of compliance risk Group-wide Compliance Helpline system that allows assessment, which is done at both the local and corporate With further acquisitions over the past years, we have continued employees to report suspected or actual misconduct or levels. The results are presented to the Executive Committee, to roll out our ethics and compliance programme, which includes violations of the Company’s policies on a confidential basis and the Audit Committee and the Board of Directors. Given that training for employees in the acquired companies. Depending on without fear of retaliation. The helpline consists of a telephony they present a specific risk group, Givaudan has a process for the integration status of the acquired company, the training and a web intake. It is serviced by a third-party provider and is the selection and engagement of sales agents and distributors programme is available either online or offline in all relevant available at all sites worldwide 24/7 and in all major languages that includes a formal due diligence review and requirements languages. The basic training includes essentially the same spoken at the Company. We also have a dedicated grievance for agent contracts and payments. material on anti-bribery, corruption and corporate social email channel that allows third parties to report alleged non- responsibility as the basic training for Givaudan employees. compliance or other issues. This mechanism is mentioned in In the case of acquisitions, we conduct pre-signing due Additional compliance training may be introduced as a result of our Responsible Sourcing Policy. All reported cases are diligence and full integration of acquired companies into the pre-acquisition due diligence. reviewed and investigated as appropriate in accordance with Compliance and Ethics Management system upon closing. Givaudan’s Global Compliance Incident Investigation Procedure. Depending on the nature of the allegations, these cases are handled either locally or centrally. Where required, external specialist support is sought. 32 Givaudan — 2021 GRI Sustainability Report