A diverse team of representatives from human resources, finance, and the legal department manages, reviews and implements each policy. We regularly review our policies and revise them as necessary to strengthen language, address emerging risks and evolving regulations and communicate best practices. Greif leverages training and audits to actively implement our policies. We require each of Greif’s over 3,600 manager-level and above colleagues to complete policy training. We actively encourage our colleagues to anonymously report ethics and compliance violations through our Ethics Hotline. A third-party provider administers the Hotline to protect the anonymity of our colleagues and is available 24 hours a day, seven days a week. Information on the Hotline, and related policies, is included in the Code of Conduct – which colleagues receive training on through Greif University and via posters at each facility. Complaints can be reported via an online portal or e-mail as well as by phone globally. Greif’s Ethics Hotline policy assures that no retaliation can be made after a complaint is filed. All reported incidents are sent to our Ethics Committee, chaired by Greif’s General Counsel, for review. Incidents are reported to the Audit Committee of Greif’s Board of Directors quarterly. In 2021, we investigated 100 percent and resolved 98.5 percent of the complaints from our Ethics Hotline.

To validate our compliance to our established policies, we conduct annual Sarbanes-Oxley Act (SOX) audits for all facilities that are material to our financial statements. Each year we ensure that facilities accounting for at least 75 percent of our revenue are included in our Sarbanes-Oxley scope. In total, Greif had 278 auditable entities in 2021. In addition to required SOX audits, Greif conducts risk-based audits at each of our facilities at least once every five years. Facilities that are audited are identified through a multi-layered process that includes management surveys, discussions, approval by executive leadership and reports to the Ethics Hotline. In 2021, we completed 38 risk-based audits following this process. We continue to strengthen our internal control environment as we leverage shared processes across locations. This year we also introduced a GRC tool, Workiva, for SOX risks and audits. The implementation of this tool will allow us to capture more data more efficiently moving forward.

In 2020, we published an updated Code de conduite communicating our commitment to The Greif Way and defining globally applicable standards of conduct. The updated Code of Conduct presents this information in a more easily understood and digestible format, which reinforces more clearly the key behaviors we desire our colleagues to demonstrate. We accompanied the updated Code of Conduct with a new online training course that was launched in 2021 through Université de Greif. During 2021, we also published an updated Supplier Code of Conduct to better outline our business ethics expectations from our suppliers. In 2022, we will update our Insider Trading Policy and our Anti-Trust and Competition Compliance Policy to strengthen the language and ensure compliance with evolving regulations.

Tout au long de la pandémie de COVID-19, nos équipes mondiales et régionales se sont réunies au moins une fois par semaine pour élaborer des protocoles, des communications et un suivi visant à préserver la santé et la sécurité de nos collègues et à respecter les réglementations nationales et locales. Grâce à la collaboration avec des conseillers externes, nos équipes des ressources humaines, de la santé et de la sécurité et d'autres équipes de Greif ont pu se tenir au courant de l'évolution des réglementations et élaborer un ensemble de protocoles cohérents dans toutes nos usines.