The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How ST promotes business integrity

ST (STMicroelectronics) is a global semiconductor leader delivering intelligent and energy-efficient products and solutions, with 11 manufacturing sites and over 80 sales & marketing offi­ces worldwide. Conducting its business with the highest standards of integrity is the foundation of ST’s culture  Tweet This!, and ST believes it is essential for its long-term success.

This case study is based on the 2018 Sustainability Report by ST published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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At ST compliance and ethics are everyone’s job and responsibility, so as to foster a business ethics culture that is consistent across regions, functions, and organisations. In order to promote business integrity ST took action to:

  • implement a Code of Conduct
  • raise compliance awareness
  • combat bribery and corruption
  • encourage misconduct reporting

What are the material issues the company has identified?

In its 2018 Sustainability Report ST identified a range of material issues, such as health and safety, labour and human rights, innovation, risk management, sustainable profit, energy and climate change. Among these, promoting business integrity stands out as a key material issue for ST.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups ST engages with:

Stakeholder Group                Method of engagement


·      Seminars, conferences, forums

·      VP communication meetings

·      Recognition, awards, contests

·      Intranet, internet, news, emails, videos

·      Training, workshops

·      Employee surveys

·      Application week, EHS week




·      Trade shows

·      Conventions, technical seminars

·      Audits and sites visits

·      Joint seminars, conferences, technodays, workshops

·      Meetings

Investors & analysts



·      Investors and analysts day

·      Annual reports

·      Extra-financial questionnaires




·      Meetings

·      Audits

·      Suppliers’ trainings

·      Surveys

·      EHS week

·      Technical roadshows



·      Conferences, conventions, meetings

·      Press releases

Industry associations



·      Memberships in public-private partnerships, International and European associations

·      Participation in consortiums, in working groups of electronic industry associations

·      Meeting, conferences, seminars

Academic & laboratories


·      Internships, scholarships, PhDs

·      Joint R&D projects, joint labs

·      Conferences, technical seminars

·      Site visits

National & local authorities


·      Partnerships with municipalities

·      Meetings, conferences, seminars

·      Annual reports

·      Site visits

Local partners


·      Partnerships

·      Conferences, conventions, meetings

·      Site visits

·      Donations, trainings, volunteering, local initiatives

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics ST carried out an online survey among 694 internal and external stakeholders, who were asked to rate the importance of each topic for them.

What actions were taken by ST to promote business integrity?

In its 2018 Sustainability Report ST reports that it took the following actions for promoting business integrity:

  • Implementing a Code of Conduct
  • The values and principles contained in ST’s Code of Conduct are the top-level reference for guiding ST’s behaviour, decision making and activities:
    • Integrity: ST conducts its business with the highest ethical standards, honour its commitments, delivers on its promises, is loyal and fair, and stands up for what is right.
    • People: ST behaves with openness, trust and simplicity, ready to share its knowledge, encourage everyone’s contribution, develop its people through empowerment, teamwork and training, with each one committed and personally involved in the continuous improvement process.
    • Excellence: ST strives for quality and customer satisfaction and creates value for all its partners; ST is flexible, encourages innovation, develops its competences, seeks responsibility and is accountable for its actions, acting with discipline and basing its decisions on facts, focusing on the priorities.
  • Raising compliance awareness
  • In 2017 ST continued its Compliance & Ethics awareness and communication campaign (branded ‘Building trust together’), focusing on the importance of integrity and ethical conduct. This initiative establishes clear expectations and invites all employees to speak up, without fear of retaliation. Over a period of 18 months (2016- 2017), ST’s Chief Compliance Officer held 27 town-hall meetings, gathering more than 1,700 employees on 23 sites, and carried out one-to-one interviews with more than 100 employees and managers in 14 different countries. In addition to face-to-face meetings, a variety of tools have been used by ST’s Compliance & Ethics team to engage with employees, managers and third parties. These tools include e-learning modules, dedicated intranet, articles, posters, targeted emails, and short videos available in 10 languages. In Q4 2017, the first ST Integrity Application (available on the Apple Store and Google Play) was launched, to provide employees with easy access to important and useful information, push notifications, fun quizzes, and training materials, as well as a link to ST’s misconduct reporting hotline and other useful contact information.
  • Combatting bribery and corruption
  • ST has a zero-tolerance approach to bribery and corruption, regardless of the identity or position of the originator or recipient of any bribe. It is also strictly forbidden for anybody in ST to use Company funds or assets to make a political contribution. ST’s Code of Conduct and Anti-Bribery and Corruption policy, which are available in the corporate governance section of ST’s website, provide clear definitions regarding instances of bribery and corruption, and include detailed descriptions of ST’s rules for engaging with third-parties. They also explain how to report actual or suspected violations and outline the potential disciplinary actions and legal consequences of non-compliance. In 2017, ST deployed a new tool to perform third-party due diligence, to enhance its ability to manage the inherent risks of doing business with external parties, including corruption, bribery, and reputation-related risks. 
  • Encouraging misconduct reporting
  • ST encourages everyone, including external business partners, to express, in good faith, any concerns they might have regarding possible violations of ST’s Code of Conduct, the Company’s policies, or the law. Managers are accountable for maintaining a working atmosphere where employees are comfortable about speaking up and expressing their concerns freely. ST’s misconduct reporting process is communicated to all employees through the Code of Conduct and a dedicated intranet web page. In addition to internal local and corporate reporting channels, ST has an independent multilingual misconduct reporting hotline and in 2017 deployed a new online reporting tool, operated by an independent third-party provider, which can be reached 24 hours a day/7 days a week, either online or by phone.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standard addressed in this case is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

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1) This case study is based on published information by ST, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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