GOVERNANCE & ETHICS
At ADAMA, we continually strive to be a socially responsible and trusted company that is driven by the highest ethical standards and legal compliance in all our business practices. We view compliance as an essential part of our long-term success.
We do not tolerate any violation of the law, our code of conduct, or internal regulations.
Our businesses are managed responsibly and in compliance with the statutory and regulatory requirements of each country. We have established an ethics committee to examine and review resolution of various ethical issues in a consistent manner, with two senior management members participating and reporting to the Executive Committee.
In 2009, we established the role of Ethics Officer to handle ethics-related issues in a professional and confidential manner. Michal Arlosoroff, Executive Vice President, General Legal Counsel, Company Secretary, and Chief Sustainability & Communication Officer, who has held this office since 2009, reports regularly to management on the Company’s ethical performance. Processes which have been established by the Ethics Officer make it straightforward for our People to seek advice or counseling regarding any ethical question, dilemma, or complaint in an anonymous and/or confidential manner, ensuring that all queries are handled properly.
SpeakUp – Reporting Concerns
ADAMA operates a global confidential reporting system available 24/7 to all employees and suppliers/service providers. It is operated by an independent service provider based in the Netherlands.
ADAMA recognizes that sometimes issues are too sensitive to report directly and therefore we encourage the confidential or anonymous reporting of concerns about ethical issues or breaches of applicable law relating to the Company and its activities.
The SpeakUp service is, a confidential toll-free call or e-mail reporting system. SpeakUp is available in countries where ADAMA operates and being web based is not dependent upon location. It is available in 27 languages - all our employees’ native languages. The system is also available for non-employees, such as service providers, who may wish to raise ethical concerns, here the access is promoted via our ADAMA website and Suppliers Code of Conduct.
The reports are recorded by an independent, external third party, translated if needed, and forwarded to two members of ADAMA’s Legal Team for confidential investigation. The person reporting (Messenger) receives a reference number confirming the receipt of the report so that they can call back or log in to receive feedback or provide further information
We encourage employees to speak-up! All HR representatives have been trained in the service and are required to bring the Speak Up to the attention of their employees and in particular to new joiners.
Promotional posters are located in office locations. Our intranet has a Compliance Corner where the Speak Up is also highly visible to all employees. Also, an annual report is published on the internal messenging service of the Company and in the Corporate Sustainability Report.
In 2021, there was an increase in the number of complaints - from 5 in 2020 to 23 in 2021 (46%). This is after several years of stability in the number of complaints. We conducted in-depth research about these increases and the findings arise from the nature of the complaints.
ADAMA’s Code of Conduct makes it clear that any reporting of issues must be treated confidentially, and the messengers wishes respected and properly dealt with without fear of recrimination or retaliation.
The complaints were on various topics. The majority of the complaints (45%) dealt with were based on discrimination or harassment.
20 inquiries were found to be justified and handled with varying degrees of severity including an employment termination case.
We will continue to encourage our employees to submit complaints in any concerns that may arise, small as may be, and we will continue to deepen the examination process and internal investigation of these complaints.
Other than SpeakUp, compliance incidents or queries are reported through managerial levels directly to General Counsel or senior managers.
Code of Conduct
Our Code of Conduct is the blueprint by which we ensure ethical practices and integrity. In the Code, we outline our commitment to our People and stakeholders and set out our expectations of them. It encompasses our corporate culture, community relations, and the components of appropriate behavior. In 2019, compliance with the Code of Conduct was discussed during the General Assembly and throughout the Company to raise awareness of the subject.
In 2019, the Code of Conduct, as well as a Q&A section giving day-to-day examples of situations of ethical dilemmas, was reissued in the Asia-Pacific region, translated into four new languages, and made available in a total of 21 languages.
In order to achieve full alignment, roll out and training on the Code of Conduct was conducted on a global scale throughout ADAMA. 6,191 employees participated in the programs, and 88% of users completed them.
Zero Tolerance for Bribery and Corruption
ADAMA has zero tolerance for, and is committed to preventing, bribery and corruption. It is committed to full compliance with all applicable laws, regulations, and contract requirements relating to the fight against bribery and corruption.
Our code of conduct strictly prohibits offering, giving, or receiving bribes, either directly or through a third party. Entering into business relationships with an individual or entity which has a history of engagement with bribery is forbidden. We share, implement, supervise, and enforce our anti-bribery and anti-corruption principles with all of our People.
Our policy is to require all relevant employees to complete online anti-bribery training on an annual basis. Where necessary, online training is provided in the local language.
In 2019, we planned various initiatives as part of our commitment to preventing bribery and corruption. These plans included the creation of an online library of compliance case studies, as well as continued training and adoption. In 2020, ADAMA internally developed the anti-bribery training. The online training was deployed on a global scale throughout ADAMA, and is accessible to all employees in their local languages.
Corporate Compliance training is an annual requirement for performance review and part of onboarding for new employees.
Since 2018, completion of all compliance training programs are a necessary condition for receiving a bonus.
Compliance Moments site
In 2020, we launched our Compliance Moments program, a user-friendly way to raise awareness for compliance. The Compliance Moments program consists of cases featuring real-life ethical and legal dilemmas from a wide range of topics, to be shared by our leadership members in the first five minutes of meetings they lead.
Our new Compliance Moments website is home to all Compliance Moments cases, currently available in four languages – English, Chinese, Portuguese, and Spanish. Each case, labeled with a catchy title, includes a multiple-choice question and suggested points for discussion, referring to our Code of Conduct.
Compliance Moments can be shared in the traditional way, i.e. using slides, or through our new interactive user-friendly app, allowing the interactive, dynamic, and real-time participation of all members.
No Political Donations
We do not use funds or corporate resources to support any political candidate or party. We recognize the rights of our employees to participate in the political process, provided they act independently of ADAMA and do not use ADAMA time, property, or equipment in the process.
Ethical Supply Chain
ADAMA recognizes that the quality of its products is influenced, among other factors, by the quality of its relations with its suppliers. The company conducts efficient, honest, and legal commercial relations with its suppliers, based on clear and organized procedures. We operate in accordance with environmental and social regulations, and expect our suppliers to do so as well.
Our Code of Conduct applies equally to all of our suppliers, and includes aspects concerning environmental protection and community commitment. The Company attaches importance to having business relations with suppliers who are strict about fulfilling legal provisions regarding rights of employees, health and safety, protecting the environment, etc. within their businesses.
Data Privacy
ADAMA’s Global Information Security Policy emphasizes the critical role our business plays in protecting the personal data of our People as well as our stakeholders, and putting in place preventative security measures to avoid data breaches. We control and supervise access to personal information, balancing the interests and privacy rights of individuals with those of our business interests and assets, in full compliance with GDPR regulations.
We have solidified our environment using cutting-edge cybersecurity tools and systems. All new systems that necessitate access to our data are required to undergo vetting by our cybersecurity compliance and intelligence team.
We annually audit and check our third party solutions for continued data privacy and cybersecurity compliance. We have deployed multi-factor authentication for all users (employees, contractors, etc.) who require access to our data.
We leverage our cybersecurity intelligence systems to better understand what vulnerabilities our environment and data are susceptible to, to enhance our enterprise’s defense.
We have deployed incident response procedures and escalation processes to be ready for any potential incident.
We also test our environment and the procedures we have created.
We are currently working on our ISO27001 certification to better display our ongoing efforts to secure our environment.
In 2021, ADAMA relaunched an online data privacy training module. The module, which is available in eight languages, covers the scope of data protection and data privacy laws, personal data processing, employee responsibilities, data breach management, data security, and more. All new employees are required to complete the training as part of their onboarding at ADAMA.