We have training and monitoring programmes in place to ensure compliance with our ethical rules. Our mandatory training on our Principles of Conduct is available online and offline in all major Company languages and includes material on anti-bribery, corruption and corporate social responsibility. Despite challenges because of the COVID-19 pandemic, 83% of all employees, including production workers, completed the training. Anti-bribery and corruption management Adhering to high ethical standards means protecting our business for the risks of corruption and bribery. Givaudan has zero tolerance towards bribery and corruption, including facilitation payments, as stated in our Principles of Conduct. Most countries where we operate have strict anti-bribery laws. These include the US Foreign Corrupt Practices Act, the UK Bribery Act, the French Loi Sapin 2 and anti-bribery laws and regulations of other countries where Givaudan either plans to do or already does business. Anti-corruption compliance is managed as part of the Givaudan compliance management system: – Co rruption is one risk domain regularly reviewed by the Corporate Ethics & Compliance Officer as part of the compliance risk assessment. – Cor ruption and inappropriate gifts and entertainments are prohibited in our Principles of Conduct. They are addressed in more detail in our Global Anti-Bribery, Gifts, Entertainment and Hospitality policy, including the reporting of gifts and entertainment. Both documents are available to employees in all major Company languages. – Givaudan has included corruption and gifts/entertainment in its basic compliance training for all permanent employees and issues specific anti-bribery training to selected employees. – As p art of monitoring activities, the Compliance Helpline allows employees to report compliance issues in confidence. The helpline is open in all sites, and available in all major Company languages. – Gi vaudan has a procedure for the selection and engagement of agents and distributors, which includes a formal due diligence review and minimum requirements for agent contracts and payments. – We c onduct pre-signing due diligence on acquisition targets and integrate acquired companies into our Ethics and Compliance programme system post-closing. Since 2013, additional specific anti-bribery training has been given to 6,979 senior managers including all members of the Executive Committee and other employees whose work involves regular and direct contact with external stakeholders. In the last quarter of 2020, we started the roll-out of a new anti-bribery training to this group. Despite challenges caused by the COVID-19 pandemic, completion currently stands at 85%. With further acquisitions in recent years we have continued to roll out our Ethics and Compliance programme, which includes training for employees in the acquired companies. Depending on the integration status of the acquired company, the training programme is available either online or offline, but in both cases in all relevant languages. The basic training includes essentially the same material on anti-bribery, corruption and corporate social responsibility as the basic training for Givaudan employees. Additional compliance training may be introduced as a result of pre-acquisition due diligence. Charitable donations, lobbying and conflict of interest Alongside our anti-bribery and anti-corruption policy we have two further policies addressing adjacent areas. Firstly, our Global Charitable Donations, Philanthropy, Sponsorship, and Lobbying Policy focuses on charitable donations and sponsorship as well as lobbying. This policy prohibits donations to any political party. We also exclude as causes for charitable donations those organisations that advocate or support policies or practices that discriminate on the basis of race, religion, skin colour, age, gender, disability, national origin or sexual orientation or that are not otherwise aligned with our Principles of Conduct. We disclose all charitable contributions and sponsorship. Most of our charitable work is conducted through the Givaudan Foundation. As a rule, Givaudan does not engage in direct lobbying. We work with interest groups, NGOs and other groups to help our advocacy efforts and we are active participants in industry associations worldwide. Secondly, our Conflict of Interest Policy establishes guidelines for handling actual, potential or apparent conflicts of interest, including of a financial kind. Its aim is to clarify and establish appropriate guidelines to conducting business in a manner that ensures the business judgment and decision making is not influenced by undue personal interests. DOWNLOAD Our position statements can be found on www.givaudan.com ▸ Our Company ▸ About Givaudan ▸ Our position statements Givaudan – 2021 Integrated Annual Report 122 Value-based governance Ou r code of conduct for a positive impact on society