Business Practice Policy definitions
Bribe or Bribery is an offer or receipt of any money, gift, loan, fee, reward or other advantage to or from any person as an inducement to act, or omit to act, in a way which is dishonest, illegal or a breach of trust.
Blacklists lists of Sanction Programs targets in Section 10.
Donation is a gift made on behalf of or in the name of Stora Enso for bona fide charitable purposes, i.e., contributions given to a charitable or not-for-profit organisation for which no benefit is received, or expected to be received, by Stora Enso.
Stora Enso Code is a summary of the essence of all Stora Enso’s policies, principles and guidelines relating to Stora Enso’s operations, available at Company intranet.
Commission has the meaning set out in Section 8.2.
Company means Stora Enso OYJ, its affiliates and subsidiaries.
Company Giveaways means nominal gifts bearing Stora Enso logos or other signs representing Stora Enso.
Competitively Sensitive Information has the meaning set out in Section 184.108.40.206.
Competitor means a company active on the same relevant market as Stora Enso or a company which, within a short period of time, is likely to enter the same relevant market as Stora Enso.
Corruption is the misuse of entrusted power for private gain.
Critical Country has the meaning set out in Section 10.
Critical Employees are a group of employees defined by their position who shall receive more in depth compliance trainings.
Critical Third Parties has the meaning set out in Section 6.2.
Customer means the legal entity named in the sales contract.
Customer Event is a type of GHE which includes travel, accommodation and Hospitality.
Discount is a deduction from the face amount of an invoice, made in advance of payment and agreed in the sales contract. It may sometimes be given on a separate credit note, in which case the instructions on payment of rebates are to be followed. A discount is included in the net sales value in financial accounts. The primary difference between a Discount and a Rebate is that a Rebate is given after payment and a Discount is deducted in advance of payment.
Expenses are travel or other related expenses paid for or by a prospective or existing client, customer of business partner, which are not included as part of a normal commercial agreement. Expenses can include costs related to travelling to view a manufacturing or reference facility or travelling to a customer event.
EU means the European Union.
Facilitation Payment is an informal, unofficial payment to a Public Official to encourage him or her to carry out services that you have a right to receive even without such payment, or to expedite a routine task. It is also known as a gratuity or a “grease” payment. It is a payment to expedite or secure performance of routine, non-discretionary tasks, such as obtaining permits, licences, or other official documents, processing governmental papers, such as visas and work orders, providing police protection, mail pick-up and delivery, providing phone services, power and water supply and loading and unloading cargo.
GHE means Gifts, Hospitalities and Expenses.
Gifts are typically items offered or given as a mark of friendship or appreciation, in order to promote a company’s brand, or in order to mark an occasion or festival. A Gift can consist of goods as well as services.
Group Controlling is the group function with the same name.
Group Taxes is the group function with the same name.
Guest has the meaning set out in Section 7.3.5.
Hospitality includes entertaining, meals, receptions, tickets to entertainment, social or sports events etc., and travel or other related expenses paid for or by a prospective or existing client, customer of business partner, which are not included as part of a normal commercial agreement. Occasion where the giver is not present at the entertainment or event is a Gift rather than Hospitality. For example, if a business counter party gives a Stora Enso employee two tickets to a concert, and no one from the business counter party’s company is attending, this is to be treated as a Gift (applying the appropriate thresholds and rules for Gifts) rather than Hospitality.
Insider means anyone who has unpublished information that is likely to affect the Stora Enso’s share price.
Inside Information is information relating to Stora Enso that has not been made public and which can affect the value of Stora Enso shares or any other publicly traded Stora Enso securities. The effect may be positive or negative.
Internal Audit is the group function with the same name.
Kickback is giving back a portion of a contract payment to a business partner’s employee, or utilising techniques such as subcontracts, purchase orders or consulting agreements to channel payments to government officials, to employees, their relatives or business associates.
Legal, is a Group Function in Stora Enso, whose task is to render the Group with intellectual property support, to facilitate the ethics and compliance of Stora Enso as well as to provide high quality legal service and advice to Group, divisions and functions.
Legal, Ethics and Compliance, is a sub function of Legal. Legal, Ethics and Compliance is responsible for our Codes and related policies, implementation, ethics training and legal compliance investigations.
Mill Visits are visits to mills and other production facilities.
Political Contributions are any contribution made in money or in kind, to support a Political Organisation or Individual. Contributions in kind can include gifts of property or services, advertising or promotional activities endorsing a political party, the purchase of tickets to fundraising events and contributions to research organisations with close associations with a political party.
Political Organisations or Individuals include political parties, election committees, party affiliated organisations, party aligned research bodies, and party aligned pressure or lobby groups, party officers and candidates.
- Any officer, employee or representative of, or any person otherwise acting in an official capacity for or on behalf of a government authority;
- Employees of government-owned or government-controlled entities;
- A legislative, administrative or judicial official, regardless of whether elected or appointed;
- An officer of, or individual who holds a position in, a political party;
- A candidate for political office; or
- An person who otherwise exercises a public function for or on behalf of any country.
In practice, this can include civil servants, inspectors, members of a political party, employees of a state university, judges, customs and imigrations officials, ambassadors and embassy staffs, and law enforcement personnel. This list is not exhaustive. If you have any questions or concerns, please ask Legal.
Rebate (sometimes referred to as a bonus) is a return of a portion of a purchase price by a seller to a buyer, after the invoice has been paid in full. A rebate can be conditional or unconditional. A rebate is usually given in the form of a credit note. The rebate may be performance-based (e.g. linked to sales volume), and may be agreed or promised in the original sales contract, in a separate letter or in a specific rebate contract. It is included in the net sales value in financial accounts. A rebate is distinguished from a Discount in that a Rebate is given after payment and a Discount is deducted in advance of payment.
Red Flag Issues are suspicious circumstances or incidents which indicate possible bribery or corruption.
Relationship Owner means the person assigned to manage the relationship with a Critical Third Party.
Sanction Programs trade sanction programs against violators of internationally recognized human rights and principles of law, see in Section 10.
Sponsorship is the supporting of an event, activity, person or organisations financially or with products or services and utilising the publicity of the sponsoring target. Both parties benefit from the cooperation.
Stora Enso means Stora Enso OYJ, its consolidated affiliates and subsidiaries.
Tax Haven Country has the meaning set out in Section 9.2.
Third Party has the meaning set out in Section 6.1.
This Policy means this Business Practice Policy.
Tier 1 Countries as at the date of this Section being last updated, Cuba, Iran, North Korea, Syria and the territory of Crimea, see in Section 10.
Tier 2 Countries As at the date of this Section being last updated, Afghanistan, Belarus, Bosnia and Herzegovina, Burundi, Central African Republic, Democratic Republic of the Congo, Egypt, Guinea, Guinea-Bissau, Iraq, Lebanon, Libya, Montenegro, Myanmar, Palestine, Russia, Serbia, Somalia, South Sudan, Sudan, Tunisia, Ukraine, Venezuela, Yemen, and Zimbabwe, see in Section 10.
Trade Association, also known as an industry trade group, business association or sector association, means an organization founded and funded by businesses that operate in a specific industry.
US means the United States of America.