Sustainability Principles

Integrity, Ethics, and Compliance

Integrity is more than a priority at Schnitzer — it is one of our Core Values. Working with integrity compels us to do the right thing even when no one is watching, or when it would be more convenient or advantageous to take another approach.

Our Core Value of Integrity underscores our commitment to operating from an ethics-based approach, which is why our program goes beyond ensuring compliance with the law to establishing and maintaining the framework for how we treat one another and all our stakeholders.

Maintaining a positive workplace and conducting business according to our Core Values requires a common set of ethical rules, which we present in our Code of Conduct. We also have a Supplier Code of Conduct to guide our relationships with those in our supply chain. Our Codes drive our culture of compliance, ethical decision-making, and accountability.

Our focus on Integrity extends to respect for human rights. As a business that engages in commercial transactions throughout the world, we have a responsibility to respect human rights everywhere we operate. In 2019, we published our first Human Rights Policy, which reinforces our commitment to upholding the internationally recognized human rights as set forth in the United Nations’ Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

Independent Ethics and Compliance function

Schnitzer has an independent Ethics and Compliance function, led by our Chief Ethics and Compliance Officer, who reports to the CEO and also to the Board of Directors through its Audit Committee. This structure allows for both the independence necessary to be a trusted resource for employees and the integration within the Company to ensure effective communication and coordination with the business.

Ethics program

Schnitzer’s Corporate Ethics and Compliance Program functions to promote the Code of Conduct, communicating and educating employees on the importance of making ethical decisions, and fostering an environment where employees feel free to report concerns.

100%

of employees trained
on Code of Conduct

Schnitzer employees participate in annual training on our Company’s Core Values, which includes instruction on our Code of Conduct and ethical behavior. For the first time, in Fiscal Year 2019, 100 percent of employees, both union and non-union, participated in this training. The training for managers also includes deep dives on important topics such as reporting misconduct, our prohibition against retaliation, diversity and inclusion, and unconscious bias.

Schnitzer’s employee community is rich in diversity, full of talented people with varied backgrounds and experiences, many of whom speak multiple languages. An ongoing emphasis of our Ethics and Compliance Program is ensuring that communications are inclusive and accessible to all. To this end, we make training content available in both English and Spanish, offer it in both written and audio formats, and produce communications such as posters and flyers to convey bilingual messages clearly.

100%

of misconduct
reports investigated

We empower employees to raise issues and concerns regarding compliance with our Code of Conduct and the law by offering multiple reporting channels, including a third-party, confidential, multilingual hotline. No matter how employees choose to report concerns, we ensure all reports are investigated, tracked, and finalized.

Anticorruption program

An essential part of operating ethically is ensuring that we follow anticorruption and antibribery laws and regulations. We scrutinize all business units for corruption risks and constantly evolve our program to address those risks. In addition to our Code of Conduct, we have a comprehensive Anticorruption Policy available to all employees that details prohibitions against bribery, money laundering, and engaging with terrorists or other sanctioned entities. The policy prohibits facilitation payments and also requires Schnitzer to maintain accurate books and records.

Our Anticorruption Manual, Anticorruption Controls, and other reference guides help employees understand these prohibitions and requirements and, for those whose job functions are critical to our Anticorruption Program, specifies roles and responsibilities in order to create accountability. Our International Anticorruption Council, chaired by the Chief Ethics and Compliance Officer and comprised of senior leaders in operations, finance, legal, sales, procurement, and audit, monitors the execution of Schnitzer’s Anticorruption Program and promotes it within the organization.

Essential elements of the Schnitzer Anticorruption Program are:

  • Accurate and transparent books and records

  • Robust third-party monitoring, including due diligence and auditing

  • International contract administration

  • Anticorruption internal controls

  • Wire transfer controls and payment monitoring

  • Designated party screening

100%

of worldwide commercial
representatives are vetted
and audited for corruption risk

Tamara Lundgren,
CEO

More than a continued acknowledgment of Schnitzer’s ethical standards and responsible business practices, the 2019 World’s Most Ethical Companies distinction recognizes our employees’ commitment to acting ethically, safely, and sustainably every day.

Global recognition

2019 was the fifth consecutive year in which Schnitzer was named one of the World’s Most Ethical Companies by the Ethisphere Institute. This prestigious award is given to companies that foster a culture of ethics and transparency at every level of the company. Specifically, winners must demonstrate leadership in five key categories: ethics and compliance; corporate citizenship and responsibility; culture of ethics; governance; and leadership, innovation, and reputation.

Sustainability, and its integration into all aspects of business, is emerging as a baseline condition for receipt of this award. Schnitzer is proud to continually raise the bar in all aspects of our business to rank among the World’s Most Ethical Companies, and to remain a leader in the corporate ethics community.

Ethics in Action award

Behaving ethically requires courage and a commitment to doing what’s right. Schnitzer’s Ethics in Action award program recognizes employees who demonstrate ethics in their daily work. These actions need not be anything heroic; recent honorees include a Pick-n-Pull employee who makes sure that his colleagues wear their personal protective equipment correctly, and a Melt Shop Operations Foreman at Cascade Steel whose respectful approach has earned him the loyalty of his team. Employees can nominate their colleagues year-round using an online portal. Those who win earn a celebration for their facility.

5 years in a row
World's Most Ethical Companies
Ethisphere Institute