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Responsible sourcing policy

1.0 Objectives
Borregaard has no legal responsibility for the business standards of its suppliers. However, according to UN and OECD norms i we are expected to act with due diligence towards suppliers to avoid contributing to violating human and workers’ rights, environmental degradation or violating anti-corruption legislation within the supply chain.

Borregaard defines responsible sourcing as conducting purchases in a way which allows the company to identify the risk that violations of human and workers’ rights, environmental legislation or anti-corruption legislation may occur in the company’s supply chain and – where such violations are discovered – initiate actions towards the supplier to end the noncompliance.

This document describes the key principles for responsible sourcing in Borregaard.

We believe that by adhering to these principles, we will not only contribute to more sustainable supply chains, but also reduce commercial risk and strengthen our long-term competitiveness.

2.0 Scope
This procedure covers all purchasing activities within Borregaard.

3.0 Responsibility
The Senior Vice President for Strategic Sourcing is responsible for updating this procedure.
Every division/company or department within Borregaard is responsible for handling the procurement process according to this procedure.

4.0 Description

4.1 Principles for responsible sourcing in Borregaard
Responsible sourcing at Borregaard involves risk-based engagement with suppliers, meaning that efforts should be directed towards the product/product categories and suppliers which represent the most significant risk. Borregaard should work according to a continuous improvement philosophy, both with regard to setting internal targets and expecting suppliers to make progress.

4.2 Ethical supplier requirements
The Borregaard Supplier Code of Conduct (SCoC) describes Borregaard’s requirements for suppliers related to human rights, work standards, the environment and business practices. The SCoC should be communicated to all suppliers with a particular focus on risk-suppliers. Suppliers should be encouraged to present the same type of requirements to their own suppliers.

4.3 Risk assessment
Borregaard shall conduct a risk assessment of their portfolio of suppliers in order to identify suppliers who may represent a risk of non-compliance with the requirements presented in the SCoC. The suppliers should be categorized as low risk, medium risk or high risk based on the risk criteria described in Borregaard’s Supply Chain Risk Matrix. Suppliers who are assessed as medium or high risk suppliers should be subject to a more detailed risk assessment. Examples of commonly used risk assessment tools are self-assessment questionnaires and supplier audits.

4.4 Reactions to breaches
The purpose of responsible sourcing is to use our purchasing power to influence suppliers’ business standards for the better. Therefore, when breaches of the SCoC are detected, the contract with the supplier should not automatically be terminated, even when the contract gives us the right to do so. Rather, the company shall assess the severity of the breach. The normal response to non-compliance should be to follow up on the supplier through requirements, dialogue and guidance.

Suppliers which do not comply with our requirements shall demonstrate willingness to comply by documenting improvements within a specified time frame. In the case of severe breaches of the requirements, or lack of progress over time, the contract should be terminated. Risk issues related to complex supply chains, such as for commodities, should be dealt with on a case by case basis. Potential actions may include product certification, collaboration projects with other industry players or dialogue with governments.

5.0 References
Supplier Code of Conduct Declaration
Borregaard’s Supply Chain Risk Matrix