DISCLOSURE ON MANAGEMENT APPROACH
Goals and performance
Novozymes wants to be a responsible corporate neighbor in the communities in which we operate. We strive to integrate this objective in the way we work, through all our business processes and our products. We operate on the basis of high business integrity standards as defined by our Novozymes Touch values and commitments and our legal compliance program. We also have clear guidelines for donations and influencing public policy.
For Novozymes’ overall commitment to society aspects, please refer to Novozymes’ social responsibility policy, environment and bioethics policy, financial and legal policy, position on donations, and position on business integrity.
See also the description of Novozymes’ approach to local social responsibility strategies.
Operational responsibility rests with management representatives for social responsibility, whereas overall responsibility for local community aspects rests with site presidents and regional presidents. The regional presidents all report to the Executive Vice President, Stakeholder Relations.
There is an External Affairs function within each region reporting to the regional president. Through these functions, Novozymes participates in the political debate to promote the benefits of our technology and products and to serve the company's interests.
Novozymes has local approaches to donations to reflect local priorities and needs, but it is a general restriction that we do not give financial contributions to political parties, or to political campaign efforts.
A special Committee on Business Integrity is responsible for managing implementation and taking action based on business integrity concerns raised by employees. Findings and actions are not reported externally.
Training and awareness
Community aspects are addressed in the local strategies for social responsibility that Novozymes’ major sites develop and/or update annually in order to prioritize issues of relevance for local stakeholders. A communication plan forms part of local strategy development to make sure that employees are involved in relevant activities and have the necessary capacity to fulfill objectives.
Novozymes' integrity measures have not been devised to correct bad behavior, but to further stipulate and institutionalize our values of accountability, responsibility, openness and honesty. As a means of ensuring effective implementation, we have developed training material and continue to train selected employee groups. Furthermore, all employees have access to guidance and a mechanism for raisng concerns about possible breaches of our integrity principles anonymously.
Monitoring and follow-up
All Novozymes' business units are regularly visited by a facilitator corps. These facilitators assess compliance with Novozymes' values by means of interviews with employees at all levels. Novozymes also has a special ombudsman, who provides an opportunity for all employees to have cases heard that they believe to be in conflict with Novozymes' values, policies, and management standards. This is not reported externally.
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Nature, scope, and effectiveness of any programs and practices that assess and manage the impacts of operations on communities, including entering, operating, and exiting
Percentage and total number of business units analyzed for risks related to corruption
Percentage of employees trained in organization’s anti-corruption policies and procedures
The percentage of employees trained in anti-corruption policies and procedures is immaterial seen in relation to Novozymes' general efforts on anti-bribery and anti-corruption. Accordingly, Novozymes reports partially on this aspect.
Actions taken in response to incidents of corruption
Data on specific actions taken on incidents of corruption is currently not available. An expedient set-up for reporting and administrating such incidents is however currently under development and Novozymes will be able to report the data externally when the appropriate set-up is finalized during 2011.
Public policy positions and participation in public policy development and lobbying
Please find the relevant public positions below. Due to organizational change, a complete set of data on Novozmes' participation in public policy development and lobbying is currently not available. It is, however, the intention to publish an overview hereof by the end of 2010.
Total value of financial and in-kind contributions to political parties, politicians, and related institutions by country
Total number of legal actions for anti-competitive behavior, anti-trust, and monopoly practices and their outcomes
Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with laws and regulations