Case study: How TPI promotes compliance and business integrity
TPI is a leading wind-blade manufacturer, accounting for approximately 18% of all sold onshore wind blades on a MW-basis globally in 2019. To help ensure it follows all laws and regulations where it does business, TPI has developed and implements practices to promote a culture of compliance throughout the organisation.
This case study is based on the 2019 ESG Report by TPI 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.
Abstract
TPI is committed to global integrity Tweet This! , taking into account the fact that although everyone has a general understanding of integrity – do the right thing, even when no one is watching – applying this general concept to day-to-day operations at TPI can be complicated. In order to promote compliance and business integrity TPI took action to:
- implement a Code of Conduct
- encourage associates to raise ethical concerns
- promote third-party due diligence
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With this case study you will see:
- Which are the most important impacts (material issues) TPI has identified;
- How TPI proceeded with stakeholder engagement, and
- What actions were taken by TPI to promote compliance and business integrity
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What are the material issues the company has identified?
In its 2019 ESG Report TPI identified a range of material issues, such as economic performance, occupational health and safety, effluents and waste, materials and material efficiency. Among these, promoting compliance and business integrity stands out as a key material issue for TPI.
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:
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 TPI engages with:
| Stakeholder Group | Method of engagement |
| Associates | · Ongoing dialogue · Annual engagement survey · Focus groups · Town Halls |
| Customers
| · Ongoing dialogue · Contracts · Customer surveys · Interviews |
| Investors/Asset Managers
| · Ongoing dialogue · Financial reporting · Investor events · Interviews · Quarterly earnings calls |
| ESG Raters
| · Research · Rating process/feedback |
| Industry Associations | · Research |
| Regulators | · Research |
How stakeholder engagement was made to identify material issues
To identify and prioritise material topics TPI completed interviews and surveys with its key internal and external stakeholders.
What actions were taken by TPI to promote compliance and business integrity?
In its 2019 ESG Report TPI reports that it took the following actions for promoting compliance and business integrity:
- Implementing a Code of Conduct
- TPI’s Code of Business Conduct & Ethics (Code) sets a tone at the top for the entire company regarding ethical behaviour. The Code covers the topics of conflicts of interest, confidentiality, preventing workplace harassment, and anti-corruption, among others. TPI’s Board of Directors, in conjunction with its Audit Committee, is responsible for administering the Code, and has delegated day-today responsibility for administering and interpreting the Code to TPI’s General Counsel who serves as TPI’s Compliance Officer. The Code and TPI’s separate Anti-Corruption Policy educate associates on anti-corruption practices and expressly prohibit direct and indirect payments that violate applicable anti-corruption laws. TPI’s associates receive annual training on both the Code and the Anti-Corruption Policy, which are available in their local language.
- Encouraging associates to raise ethical concerns
- As part of the Code training, TPI’s associates are encouraged to raise any ethical concerns either directly or anonymously. They can report concerns anonymously through a hotline that is operated by a third-party provider. Any messages submitted to the hotline are only accessible by TPI’s Compliance Officer and Audit Committee Chairperson, who then decide if the concern will be investigated by the human resources department, the internal audit department, the internal legal department or an external law firm, depending on the nature of the concern. TPI does not retaliate against any associate who reports ethical concerns in good faith. Posters regarding the anonymous hotline are posted at all TPI’s manufacturing facilities in the local language.
- Promoting third-party due diligence
- TPI has implemented policies and procedures to help it evaluate the integrity of its third-party business partners. TPI has documented standards for suppliers and monitors performance throughout the supplier lifecycle. TPI does this by using an independent vendor assessment tool, conducts audits of its suppliers, and requires suppliers to complete an annual questionnaire that identifies compliance and policies from these companies for areas such as child labour, corruption and safety.
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: Peace, Justice and Strong Institutions
- Targets: 16.5
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References:
1) This case study is based on published information by TPI, 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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