Society
Trelleborg’s policy in this area is principally regulated by the Group’s Code of Conduct (Compliance with laws, bribes), the Anticorruption policy, Communications policy, Sponsorship recommendations (contributions/lobbying) and the Competition Act policy (restrictive trade).
The overriding responsibility for issues within the framework of category is borne by the managers of Group Human Resources (Code of Conduct), Group Legal (anticorruption, competition act), Corporate Communications (communications policy, sponsorship recommendations), while compliance in the daily work is the responsibility of the line managers. It is also the responsibility of the managers to ensure that training related to the Group’s Code of Conduct is included in the employees’ training program. The Group conducts training activities and communication to support this, in addition to training within the area of competition legislation. The main tool used for following up the Group’s Code of Conduct is self-assessment in accordance with the model, supported by randomly conducted third-party audits.
Bribery and corruption are unacceptable behaviors, as is affirmed by the Group’s Code of Conduct. In 2007, Trelleborg will conduct comprehensive training within the Group with the goal of making all employees aware of the Code of Conduct and its contents. One of the Code’s main messages clearly addresses the issue of bribes/corruption.
Political contributions
Trelleborg’s recommendations with regard to all types of association and experiencebased marketing, such as sponsorship, event marketing, social and humanitarian activities, state that the company does not sponsor political or religious organizations.
Trelleborg is a member of national industry associations in a number of countries and these also include cooperation in environment and work-environment issues. At a European level, Trelleborg is affiliated with ETRMA, the European Tyre and Rubber Manufacturers Association, and participates in work groups addressing such issues as the environment and work environment, and chemicals. In Sweden, Trelleborg is a member of the Swedish Plastics and Chemicals Federation.
Trelleborg has a clear policy of observation of applicable competition rules. In 2006, extensive training of approximately 350 employees throughout the world was undertaken to ensure that rules regarding applicable competition legislation and the Group’s policies in fair-trade issues are known and followed.
As regards restrictive trade practices, the US Justice Department has been conducting an investigation since August 2005 into competitive conditions in the US from 2000 to 2005 for certain types of marine fender systems. The investigation relates to certain market conditions in the US and comprises several companies in the US, manufacturers, distributors and agents, including one of Trelleborg’s subsidiaries. The business that is the subject of the investigation represents a very small portion of the Group’s US operations. Discussions are under way with the appropriate authorities and a settlement of the matter is deemed likely, possibly in the first six months of 2007. The anticipated final costs cannot be expected to have more than a limited impact on the Group in its entirety. No provisions have been made to date to cover these costs.
Trelleborg prioritizes sponsorship commitments that benefit the community and the environment in which the company operates, that supports our values, and reinforces our relations with customers and other partners. A multi-year cooperation with Save the Children Sweden, initiated in 2006, involves annual contributions and is part of Trelleborg’s ambition to assume a greater global social responsibility by contributing to the development and education of children.
Trelleborg participates in several different social activities. These are often local and involve cooperation with neighbors, stakeholder organizations, authorities and sports clubs. With regard to the latter-mentioned, there are many examples of how the company supports work with young people. Within the area of education, Trelleborg has cooperation with a number of universities and schools entailing regular contact with researchers and students. Institutes with which Trelleborg cooperates include Université de Nantes, France, Fachhochschule Koblenz, Germany, LUISS in Rome, Italy, Western Michigan University, in the US, Malta University, Malta, University of Derby and Trent Technical College, the UK, and Chalmers University of Technology, Sweden.
Over the years, many degree projects and much research work has been conducted at Trelleborg’s facilities with emphasis on such areas as the environment. In addition, Trelleborg has a learning partnership with the Lund University School of Economics and Management, Sweden, which involves the financing of two postgraduate appointments.
(excerpt from the company’s communications policy)
• Trelleborg’s communication shall conform to applicable legislation, regulations and standards.
• It shall be characterized by a close relationship with the company’s stakeholders and be founded on regular contact, clarity and good ethics.
• It shall be transparent and truthful.
• It shall be planned and systematic.
One of the central communication goals is to contribute to Trelleborg acting as a good and responsible corporate citizen and, in line with this, mediate a relevant image of operations in this regard.