Case study: How Stoelzle promotes legal compliance

What are the material issues the company has identified?

In its 2019 Sustainability Report Stoelzle identified a range of material issues, such as employee health and safety, emissions, consumer awareness, avoidance of problematic substances, employee communication & participation. Among these, promoting legal compliance stands out as a key material issue for Stoelzle.

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 Stoelzle engages with:

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Stoelzle carried out an anonymous and independent survey among 80 key stakeholders who included customers, suppliers, and employees.

What actions were taken by Stoelzle to promote legal compliance?

In its 2019 Sustainability Report Stoelzle reports that it took the following actions for promoting legal compliance:

• Implementing a Code of Conduct
• The Stoelzle Code of Conduct is the basis of Stoelzle’s Compliance Management. With this code, Stoelzle commits itself to compliance in general, and underlines the commitment of all employees to responsible behaviour and compliance with applicable law. In 2020, Stoelzle will conduct a Group-wide communication and training campaign on the topics of integrity and responsible conduct, aimed at all employees. Compliance Management will be applied to all compliance issues, in particular to prevent corruption and anti-competitive behaviour, as well as to ensure that human rights are respected at all Stoelzle’s The key elements of the system include internal compliance regulations, legal monitoring, complaint management, employee training and communication. Moreover, in 2019, the existing Code of Conduct was completely revised. In a Group-wide and interdisciplinary team, a value-based framework for legal conduct valid for all employees was created, in several joint workshops. The new Code of Conduct encompasses the following principles:
  • Compliance with regulations
  • Respect for human rights
  • General business practices & integrity
  • Internal collaboration
  • Social responsibility
• In addition, IT-supported applications for legal databases in the area of quality, environmental law and working conditions were further expanded. In 2018, for example, a programme was launched to audit all locations. The aim of the audit is to make sure that all local environmental and occupational health and safety legislation, as well as company operating requirements, are being complied with. Independent local experts who are well acquainted with national and local law are consulted for the audit. Furthermore, Stoelzle keeps itself continuously up-to-date and proactively informed about new requirements with the help of nominated representatives and external consultants.

• Applying a software-based legal database
• Stoelzle increased legal compliance through the implementation of a software-based legal database in the field of environmental and working conditions: in Austria, France and the Czech Republic legal audits were carried out in the field of environmental and working conditions by independent third parties, without any significant deviations in findings. The legal obligations are checked every six months to ensure their up-to-datedness and compliance. Additionally, a Group-wide legal database is to be implemented by the end of 2020.

• Promoting business ethics and anti-corruption
• Stoelzle’s employees have the opportunity to ask questions about compliance issues to their managers or to the Stoelzle Group Compliance Contact. External stakeholders can revert to a whistleblower system, which has been integrated into the Stoelzle website. Within the company, eventual infringements can be reported anonymously via the Stoelzle Compliance Line. The Stoelzle Group Compliance Office deals with eventual infringements and sets necessary corrective actions. Despite the manifold scope of its activities, Stoelzle can report that no cases of anticompetitive behaviour, corruption, discrimination, unfair competition or related issues emerged in the reporting period.

• Complying with the legal requirements of product liability
• The Stoelzle Management System aims to avoid product liability cases. Due to the properties of glass, and despite extensive processes for assuring product safety, it is possible that glass breakage may put human health at risk during the use of said glass products. In such cases, Stoelzle works in close cooperation with the customer and provides support with its complete system of traceability. Glass containers for pharmaceutical use must also comply with the specifications established in pharmacopoeia monographs for pharmaceutical glass containers. The Stoelzle sites in Austria and the Czech Republic, where processes and product ranges are specifically geared towards pharmaceutical products, are equipped with special facilities and equipment. This allows Stoelzle to guarantee the pharmaceutical quality of the products. The labelling of the glass products, if applicable to the container, is carried out in accordance with the Finished Pack regulations in accordance with ISO norms (e.g. ISO 8362-4 for injection vials made from moulded glass), and especially in accordance with customer requirements. These requirements are defined in the internal documents, which guarantees the correct labelling. In the reporting year, there were no instances of non-compliance with product labelling. In the period under review, Stoelzle received no fines or sanctions with respect to non-compliance with the legal requirements of product liability.

• Implementing a Supplier Code of Conduct
• Stoelzle works together with its suppliers and partners throughout the entire value chain in order to initiate positive changes. This cooperation is based on the Supplier Code of Conduct, written in 2019. With this guideline, Stoelzle is actively committed to improving sustainable performance along the value chain and thus in the final product in order to create positive effects and additional benefits for people and the environment. The implementation of this guideline will be part of the contractual agreement between Stoelzle and its partners and will be checked in the supplier audits. The rollout of Stoelzle’s global Supplier Code of Conduct will start in 2020.

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

The GRI Standards addressed in this case are:

1) Disclosure 205-3 Confirmed incidents of corruption and actions taken

2) Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

3) Disclosure 307-1 Non-compliance with environmental laws and regulations

4) Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area

Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.5

Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.3

Disclosure 307-1 Non-compliance with environmental laws and regulations corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.3

Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.3

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References:

1) This case study is based on published information by Stoelzle, 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:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

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