At Ahlstrom compliance is the responsibility of every director, officer and representative regardless of the region, business area or function in which they operate. Compliance starts from the top down and is directly linked to all activities conducted for Ahlstrom.
Ahlstrom’ Board has Compliance Framework in 2014. The Compliance Framework is based on the following elements:
- Ahlstrom’s management’s commitment and leadership to compliance
- Ahlstrom Code of Conduct and other key compliance policies
- Compliance communication
- Compliance education and training
- Compliance monitoring and associated record keeping
- Whistleblowing service
- Disciplinary actions
In addition, Ahlstrom has implemented trade compliance procedures to ensure that it does business only with permitted customers and vendors in a manner that complies with legal and company standards. In 2016, the company also launched a data protection policy.
The main policies of the Compliance Framework are the Company’s Code of Conduct, Approval and Signing Policy, Competition and Antitrust Policy, the Anti-bribery Policy, the Trade Compliance Policy, the Donation Policy, the Risk Management Policy and Insider Rules.
The Board is responsible for overseeing how compliance is organized and managed at Ahlstrom. The Board is assisted by its Audit Committee.
The Chief Compliance Officer of Ahlstrom is responsible for supporting the Board and Ahlstrom’s senior management in implementing compliance at Ahlstrom. The Chief Compliance Officer reports directly to the President & CEO and the Audit Committee in compliance matters. Unless otherwise nominated by the Board, Ahlstrom’s EVP Legal, General Counsel shall act as the Chief Compliance Officer.
Ahlstrom has an externally maintained whistleblowing system, SpeakUp, for all employees to report anonymously unethical or unlawful behavior
In its insider administration, Ahlstrom follows the Guidelines for Insiders issued by Nasdaq Helsinki stock exchange complemented by the Company’s own Insider Rules approved by the Board.
Ahlstrom Board of Directors has updated insider rules on July 3, 2016. These Insider Rules apply to all personnel of the Company and its group companies, including employees, the President and CEO, the Board of Directors and other management.
As a result of Market Abuse Regulation (596/2014/EU, as amended, "MAR") that entered into force on July 3, 2016, Ahlstrom does no longer maintain public or permanent company specific insiders lists. The Company maintains a Project-specific Insider lists, which must always be created and maintained for a project which, when published, would be likely to have a significant effect on the price of the Company’s financial instruments.
The company has defined that the Company's managers to include the following persons (the"Managers")
- the members of the Board of Directors and their deputies, if any;
- the President and CEO and his/her deputies, if any;
- the members of the Company’s Executive Management Team; and any other senior executive of the Company who has regular access to inside information relating directly or indirectly to the Company and power to make managerial decisions affecting the future developments and business prospects of the Company (such executives to be identified by the General Counsel and re-evaluated on a continuous basis, and the President & CEO to define such executives based on the proposal made by the General Counsel).
The Company has informed the Managers in writing of his/her duties under the MAR.
According to Ahlstrom’s Insider Rules, persons listed as Managers shall not in any case trade in the Company’s securities 30 days (“Closed Window”) prior to the publication of an interim report or annual financial results. According to its Insider rules, the Closed Window shall also apply to persons who work with interim reports and annual results or who otherwise possess significant and unpublished information (for the sake of clarity, which does not, however, constitute inside information) of the Company or its financial instruments.
Updated: February 2017