STATUS ON MEASSURES
IDENTIFIED COMPLIANCE RISK IN 2021
RISK MITIGATION – TO BE IMPLEMENTED IN 2023
RISK MITIGATION – ALREADY IMPLEMENTED
RISK DESCRIPTION
RISK & COMPLIANCE
Whistleblowing mechanism is a local complaint system available in every factory. Code of Conduct & Ethics presented to production partners and suppliers, containing LTP Group policies on human rights. Social third-party audits through certifications: see full list in the appendix of this report Separate risk assessment based on the inherent risk identified with support of Corruption Perception index *. Whistleblowing mechanism. Ethical policy for all entities in LTP Group established and signed by all managers. General anticorruption and bribery policy incorporated in factory standard. Code of Conduct & Ethics presented to production partners and suppliers
Risk assessment with focus on social and environmental topics and according to OECD guidelines on supply chain due diligence Establishment of a Sustainability supply chain due diligence policy Establishment of a specific anti-corruption and fraud policy Training modules provided by LTP Group legal manager to all directors and critical functions: e.g. finance, purchasing
Not Done (Target: 2023)
Lack of control mechanism to prevent, identify and address breach of human rights among our business partners upstream and/ or downstream in the supply chain
Breach of human rights and working conditions in the global supply chain
In 2022, LTP Group conducted a business risk assessment which included compliance risks. Those risks are presented in the table. For each risk we present the mitigation measures implemented across LTP Group during 2022 and the mitigation measures to be implemented in 2023. While LTP Group has production sites in Lithuania, Belarus, Romania, Vietnam, Ukraine and Mexico we are inherent in risk with regards to human rights, corruption, and bribery, as our business involves engagement with many local suppliers and subcontractors, in countries considered to be high-risk, from a compliance, labor- & human rights perspective. We address this risk by training own employees in our Code of Conduct, by having suppliers and production partners signing our Code of Conduct & Ethics for Suppliers & Production partners, meanwhile we conduct due diligence towards suppliers and production partners. LTP Group’s Code of Conduct & Ethics for our employees, suppliers and production partner guides our behavior and sets the minimum standards for ethical behavior, including human & labor rights. LTP Group respects freedom of association and the right to collective bargaining, according to the laws or practices of the countries in which we operate. LTP Group promotes a healthy & safe working environment recognizing it as a fundamental right of employees. LTP Group recognizes the value and uniqueness of each human being as a fundamental element of its culture. LTP respects individuals' fundamental rights, ensuring physical and moral integrity, and equal opportunities for all. LTP Group disallow all forms of violence, forced labor or child labor, and discrimination, opposing all forms of harassment and behavior that is offensive to personal dignity in the workplace.
Lack of preventive measures and control mechanism to prevent, identify and address corruption bribery or fraud in the organisation
Risk of corruption, bribery and fraud
In Process (Target: 2023)
Tailor-made procedures based on a risk approach
Review of data in CRM On- boarding training/ information on employee's rights
Optimisation of solutions for documents and information storage
In Process (Target: 2023)
Breach of Data Privacy laws
Breach of data privacy and GDPR regulations
Risk of not leading innovative manufacturing solutions enabling circularity such as the ability to disassemble products or increasing use of materials which have recycled content, or which can be recycled
See commitment Embrace Durability & Circularity under the section “2022 TARGETS” of this report for all details on 2022 priority topics and targets
Meassures & achievemnents listed on p. 15, 22 and 23
Materiality assessment conducted which resulted in circularity identified as a material topic. As such, it has been added in LTP Group 2022-2025 sustainability strategy
Lack of focus on circularity
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* In 2022 CPI, Ukraine ranked 116 out of 180; Belarus ranked 91 out of 180; Mexico ranked 126 out of 180, Vietnam ranked 77 out of 180
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