Compliance & Ethics

Our Commitment

Doing business according to high ethical standards

Maintaining the highest standard of integrity is essential for securing the trust of customers, business associates and the general public, and in turn brings security for the company and its employees. Borealis' commitment to ethical business conduct is firmly rooted in the company's core values: Responsible, Respect, Exceed and Nimblicity™. Each Borealis employee is expected to:

  • Be responsible for their own actions and for upholding the highest standards of ethical behaviour at all times.
  • Respect the importance of upholding ethical principles, human rights and diversity within Borealis, among its business partners, and in all the communities in which it operates.
  • Exceed what is stipulated by law and regulations, to achieve even higher standards of business conduct.
  • Embrace the spirit of Nimblicity™, to seize every opportunity to achieve excellence in business behaviour.

Borealis' commitment to ethics extends beyond its employees. Agents, suppliers, contractors and distributors are also obliged to uphold ethical principles. Borealis contracts include an ethics clause.

Borealis Ethics Policy

The Borealis Ethics Policy is the foundation for the company's approach to ethical business. It applies to Borealis employees and all others working on behalf of the company, including suppliers and contractors. The policy is easily accessible on the Borealis website in 16 different languages, and offers clear guiding principles as well as practical tools and advice on how to make the right decision, when confronted with questions of ethics and business conduct.

The policy covers a wide range of topics, including the application of human rights, how to deal with conflicts of interest, Borealis' guidelines on political involvement, avoiding bribery, how the company competes and many more.

Ethics Ambassadors

Borealis applies ethical guidelines in practice through a comprehensive network of around 80 Ethics ambassadors, drawn from various functions and locations. Within the framework of Borealis' Compliance Management System and in alignment with the Group Compliance and Ethics Officer, Ethics Ambassadors hold general ethics training courses for employees. The Group Compliance and Ethics Officer and the Ethics Ambassadors also provide tailored workshops for high-risk functions or particular countries, as well as on topics such as competition and bribery. Employees with internet access must complete the company's "CodeOne" e-learning programme within the first weeks of employment and classroom training is mandatory for all employees during their first full year of employment. Depending on the role of the individual employee, additional classroom and online training courses are mandatory throughout the term of employment.

Complaint and grievances mechanism

The Borealis Questionline has been established as a channel for those inside and outside Borealis to blow the whistle by reporting unethical behaviour or to raise concerns with full confidentiality. All notifications are registered, evaluated, documented and, if necessary, investigated, and appropriate action is taken. On average, the QuestionLine is contacted 150 times each year with requests for information or advice, as well as with reports of unethical behaviour. Such reports have led to disciplinary measures, including dismissal. Every valid report of unethical behaviour is investigated and findings are reported to the Executive Vice President of the business area concerned.

Our Focus Areas

Competition and Anti-trust Laws

Borealis is committed to vigorous, lawful, straightforward and ethical competition. It is our policy to ensure that our business practices are in full compliance with competition and anti-trust laws wherever we do business.

Our Customers

  • We treat all customers in a straightforward manner and in a way that respects their independence.
  • We strive to ensure that customers obtain the best product and service levels commensurate with their needs.
  • We do not attempt to prevent customers from seeking to source Borealis products anywhere in the EU.
  • We do not interfere with our distributors' freedom to set their resale prices.

Our Products

  • We compete based on the merits of our products and services.
  • We ensure that our sales materials, advertisements and other communications accurately and fairly describe our products and services.

Our Competitors

  • We do not engage in any contact with competitors where price, markets or customers are discussed.
  • We ensure that any meetings with competitors are held for lawful purposes, for example trade association meetings, or benchmarking exercises that have been structured in accordance with legal advice.
  • We gather market intelligence through lawful means and independently determine our commercial strategy in light of that intelligence. We may participate in an exchange of aggregated industry data that does not disclose company-specific information where such data is compiled by an independent third party in order to maintain confidentiality. We do not obtain market information from competitors.

Anti-Corruption

  • Borealis does not tolerate corrupt activities in any form.
  • Borealis carries out its business dealings in an independent and impartial manner and is not unduly influenced by others. Borealis business activities are carried out professionally, fairly, and with integrity. Borealis will not be influenced, nor seek to influence, our business partners by payments of money or any other thing of value, including corporate hospitality and gifts.
  • Borealis requires compliance with all applicable anti-bribery and corruption laws in the conduct of our business. Compliance is required of Borealis employees as well as any party acting on our behalf, such as agents, distributors, contractors, consultants, or any other third party.

Business Ethics

Borealis trains all its employees on how to behave ethically with respect to:

  • Conflicts of Interest
  • Use of Company Assets
  • Safeguarding Important Information
  • Political Involvement and Contributions
  • Human Rights
  • Environmental Responsibilities

Issuer Compliance

  • Borealis has corporate bonds listed on the Vienna Stock Exchange and as a consequence must comply with Austrian securities trading laws.
  • Through our Issuer Compliance Instruction we wish to guarantee all bondholders equal treatment and seek to prevent people within our organisation from taking advantage of information which is not available to the general public.
  • Confidentiality requirements in all group companies and for all projects in which insider information or other sensitive information may arise aim to ensure that such information is kept confidential and not misused.
  • All relevant members of the Borealis organisation receive training to ensure that legal and internal Borealis regulations concerning insider information and insider trading are discussed and followed.
  • Compliance is monitored and the scope of possible penalties for violation is communicated.

Export Controls and Trade Restrictions

The export of certain technologies, goods, services and information from certain countries to other countries is subject to legal restrictions. Borealis will comply with all applicable export control and import laws, regulations and procedures wherever we operate.

Our Ethics Policy

Developed on the basis of international agreements, the Borealis Ethics Policy sets out the minimum standards of conduct expected from employees, suppliers and distributors. The policy covers a wide range of topics including human rights standards, how to deal with conflicts of interest, how to avoid bribery, as well as general principles on how the company competes. The guidelines are available in various languages and downloadable.

Our Responsible Sourcing Policy

Whenever doing business Borealis is committed to follow its values Responsible, Respect, Exceed and Nimblicity™. As a result of these business principles Borealis has developed a Responsible Sourcing Policy which defines the way to source goods and services from the market. Borealis therefore is committed only to do business with suppliers who follow business practices which are aligned with our values and our Ethics Policy.

In addition to the legal standards mentioned in this Code, suppliers will comply with all other applicable laws in the provision of products or services to Borealis. Borealis applies a „Zero Tolerance Policy" regarding unethical business behaviour, bribery, corruption and forced labour.

The Borealis Code of Business Conduct for Suppliers

This Code of Business Conduct for Suppliers sets forth basic principles for supplier conduct when working with Borealis. Borealis is committed to these principles and expects its suppliers to be as well.

Human Rights and Labour Practices

Respect for People is a core Borealis Value. Suppliers must respect the Human Rights of their employees and treat them fairly and with respect, in accordance with applicable laws.

  • No Forced and Compulsory Labour: Suppliers will not use forced or involuntary labour, including indentured labour, bonded labour or slave labour.
  • No Harassment and Abuse of Labour: Suppliers will ensure that their employees are not subjected to psychological, verbal, sexual or physical harassment or any other form of abuse, and will comply with all applicable laws on harassment and abuse of employees.
  • No Child Labour: Suppliers shall not employ full time employed workers under the age of 15 or, in those countries subject to the developing country exception of the ILO Convention 138, shall not employ full time employed workers under the age of 14."
  • No Discrimination: Suppliers must promote equal opportunities, not discriminate in any condition of employment on the basis of race, colour, national origin, sex, religion, age, disability or any other personal characteristic unrelated to job performance, and will comply with all applicable employment discrimination laws
  • Appropriate Work Hours and Wages: Suppliers will comply with applicable laws on work hours and overtime, as well as applicable laws on wages and benefits. Where no sufficient legal protection exists, suppliers must ensure at least 1 uninterrupted day off per week and compensate work at a minimum so that employees can meet their basic needs.

Environment, Health and Safety

Borealis´ commitment to sustainability includes efficient use of resources in the light of the Circular Economy, as well as the commitment to protect the environment and to provide healthy and safe workplaces. Borealis is committed to Responsible Care®, avoids using conflict resources and expects its suppliers to make similar commitments to continuously improve their environmental, health and safety performance.

  • Respect the Environment: Suppliers will comply with applicable environmental laws and shall have systems in place to ensure safe management of waste, air emission and wastewater discharges. Suppliers must seek to continuously minimize environmental impact and make continuous improvements to resource efficiency, for instance by using recycled materials
  • Protect Health and Safety: Suppliers will provide a safe and healthy workplace for their employees, including appropriate controls, training, work procedures and personal protective equipment. Suppliers will comply with all health and safety laws that are applicable to the workplace.

Ethics and Legal Requirements

Borealis expects its suppliers to conduct their business ethically and in compliance with the law.

  • Avoid Conflicts of Interest: Suppliers will avoid any interaction with a Borealis employee that may conflict, or appear to conflict, with the employee's ability to act in the best interests of Borealis.
  • No Bribery: Borealis does not tolerate corruption in any form. Suppliers shall not influence nor seek to influence Borealis employees by payments of money or any other thing of value, including corporate hospitality and gifts. Borealis requires compliance with all applicable anti-bribery and corruption laws in the conduct of business. Compliance is required of any third party acting for or on our behalf, such as agents, distributors, contractors, consultants, etc.

    Bribery is corruption. It is the giving to or receiving by any person of anything of value, either directly or indirectly, as an inducement to gain an undue commercial, contractual, regulatory or personal advantage or to influence contrary to the principles of honesty and integrity. Bribery can occur, and is unlawful, in both the private (between commercial companies) and the public sector (bribing a public official).
  • Fair Competition: Suppliers will be committed to vigorous, lawful, straightforward and ethical competition and must ensure that their business practices fully comply with the competition laws wherever they do business.
  • Accurate Accounting and Business Records: Suppliers will keep – and provide to Borealis upon request – accurate records of all matters related to the supplier's business with Borealis
  • Protect Information: Suppliers will protect Borealis confidential information and act to prevent its misuse, theft, fraud or improper disclosure. Suppliers must take all due care in handling, discussing or transmitting sensitive or confidential information that could affect Borealis, its employees, its customers, the business community or the general public.
  • Sanctioned Parties: Shipper may not use any supplier of services or equipment which (a) is located in any country subject to United Nations, U.S. or EU economic sanctions (or acting on behalf of persons or entities located in such countries) or (b) appears on lists of restricted or prohibited persons maintained by the United Nations, U.S., EU or the country of manufacture, origin/destination of the cargo. Shipper shall screen all vessels, containers and other equipment and their owners to ensure compliance with this requirement.

Expectations in Respect to the Code of Business Conduct for Suppliers

Borealis expects suppliers to implement systems and controls to promote compliance with applicable laws and the principles set forth in this Code, including policies, training, monitoring and auditing mechanisms. Suppliers should also apply these or similar principles to the subcontractors and suppliers they work with in providing goods and services to Borealis.

Borealis reserves the right to assess and monitor suppliers' compliance with this Code. Suppliers who are not in compliance with this Code are expected to implement corrective actions or face the prospect of not being considered by Borealis for future business.

Authorized Economic Operator (AEO)

The international security environment has changed over the years. Several initiatives to implement global terms and standards concerning risk management within the supply chain and customs processes have been created in response.

In 2005, the EU introduced the Authorized Economic Operator (AEO) concept as one of the main components of the so-called security amendment of the Community Custom Code.

AEO status has been granted to parent company Borealis AG and the majority of Borealis locations in the European community. Borealis is currently in the process of seeking AEO status for those Borealis locations which have not yet been certified.

Borealis is proud to have been acknowledged as a trustworthy organization fulfilling stringent criteria, including customs compliance, appropriate record keeping, financial solvency and, where required, appropriate safety and security measures .

Borealis remains fully committed to fulfilling its legal obligations concerning AEO and has taken appropriate measures to secure our business and the international end-to-end supply chain from a customs perspective.

For further information related to Borealis' AEO status, please send your inquiry to aeo@borealisgroup.com.