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.
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.
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.
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
of worldwide commercial
representatives are vetted
and audited for corruption risk