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 approved a renewed 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
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 Ahlstrom 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.
In April 2015, Ahlstrom launched an externally maintained system known as SpeakUp for all employees to anonymously report unethical or unlawful behavior
In its insider administration, Ahlstrom follows the Guidelines for Insiders issued by Helsinki exchange complemented by the Company’s own Insider Rules approved by the Board. The Company maintains its public and company-specific insider registers in the SIRE system of Euroclear Finland Ltd.
In accordance with the law, Ahlstrom’s public insiders include the members of the Board, the CEO and his Deputy, auditors, the members of the EMT as well as the General Counsel. Ahlstrom’s register of company-specific permanent insiders includes individuals who are defined by the Company and who regularly possess insider information due to their position in the Company.
According to Ahlstrom’s Insider Rules, persons listed as permanent insiders shall not in any case trade in the Company’s securities after the end of each calendar quarter until the day after the publication of the (quarterly) interim report or annual result (“Closed Window”). The Closed Window shall, however, always include at least the three weeks immediately preceding the publication of the (quarterly) interim report or annual result and the date of publication of such report.
The Company’s legal function also maintains a project-specific insider register when required by law or regulations. Project specific insiders are prohibited from trading in the Company’s securities until the termination of the project.