Codes, Policies and Standards

Health and Safety

  • The Essentra Safety Commitment was reviewed and approved by the GEC in February 2023. It is published on the Company website, displayed at all Essentra locations and made freely available to all stakeholders. It will be reviewed annually.

    Please click here to view our Safety Commitment Report. 

Essentra Pension Plan Information

Essentra Tax Strategy

  • As a responsible corporate citizen, Essentra aims to always act in a socially responsible manner in accordance with Essentra’s Corporate Social Responsibility. Our tax strategy is an important part of delivering these values.

    General approach and commitment to compliance

    Essentra aims to achieve high standards of transparency and responsibility in dealing with its tax affairs, and to comply with tax laws and practice in all the territories in which we operate. Compliance for us means paying the right amount of tax in the right place at the right time, and making relevant disclosures to tax authorities to allow them to determine that the right amount of tax has been paid in the right place at the right time.

    Day-to-day tax matters are delegated by the Board to the Group Head of Tax and the Chief Financial Officer and overseen by the Audit and Risk Committee. Essentra’s approach to tax risk is set by the Board.

    Our approach to tax planning

    Essentra’s Code of Business Ethics requires that we adhere to the letter and spirit of all laws and regulations that govern our business. As such, Essentra does not undertake artificial tax planning which has no commercial purpose, or which has an outcome that is contrary to the intentions of the relevant government. Consideration of tax planning will also have due regard to the potential impacts on our reputation and relationships with key stakeholders.

    Essentra will consider and respond to legitimate tax incentives and reliefs in the countries in which we operate.

    In line with our responsibilities as a multinational group, intercompany transactions are set on an arm’s length basis and in line with OECD principles and reporting requirements.

    Attitude to tax risk

    Given the scale of Essentra’s business and the variety and complexity of the tax regimes in the jurisdictions in which we operate there is a level of inherent risk associated with tax, which we are committed to managing and minimising.

    In line with the Board endorsed controls culture we seek to proactively identify, evaluate, manage, and monitor such tax risk.

    Where appropriate, for example where there is significant uncertainty or complexity, we will work with specialist tax advisors to obtain independent advice and we may liaise with tax authorities to obtain greater certainty where this is possible.

    Taxation is vital in providing our societies with the funding needed to build for all of our futures. As such, we have a zero-tolerance approach to tax evasion and the facilitation of tax evasion by anyone associated with Essentra.

    Working with tax authorities

    As a UK headquartered group, we seek a particularly co-operative and transparent relationship with the UK tax authority (HMRC), with regular dialogue carried out through the proper channels. This allows us to provide business updates, seek clarification on UK tax laws, offer input into UK law consultations and address any open enquiries or general questions.

    In our interactions with HMRC we always seek to adhere to their published principles of ‘co-operative compliance’ which describe the framework within which HMRC seeks to work with large business. Co-operative compliance as a broader OECD concept also underpins the way we look to develop and maintain professional working relationships with all tax authorities.

    Where tax audits are opened, we aim to engage with tax authorities in a proactive and prompt manner to fairly resolve the matters under review. Where we disagree with a ruling or decision of a tax authority or court, we will first seek to resolve any disputed matters through proactive and transparent discussion and negotiation.

    Governance and monitoring

    The tax landscape, general business environment and business operations continuously evolve and so our approach to tax risk management and the tax strategy will be reviewed at regular intervals and amended if necessary. Any amendments to this tax strategy may be suggested by the Group Head of Tax, the Audit and Risk Committee or the Group Sustainability Committee but in any event any changes will need approval by the Board.

    The Essentra staff responsible for tax, which includes the Tax Department as well as other staff involved with tax as part of their day-to-day duties, are subject to internal and external audit reviews. Regular tax updates are given to the Chief Financial Officer and Audit and Risk Committee by the Group Head of Tax.

    UK tax legislation

    Publication of this tax strategy is regarded as complying with the duty under Paragraph 16(2), Schedule 19, Finance Act 2016 in respect of the period ended 31 December 2024.

Competition Compliance Policy

  • Competition law infringement is a serious risk for every business. A breach of competition law can lead to fines of up to 10% of Essentra’s worldwide turnover and individuals can be personally criminally liable.

    Compliance commitment

    Essentra plc is committed to ensuring that all of its international activities are conducted in accordance with all applicable competition law requirements.

    Essentra is committed to ensuring that its employees are aware of competition law requirements and that they are equipped as appropriate to comply with them during the course of their employment.

    Responsibility for compliance

    It is the responsibility of Essentra employees to ensure that none of Essentra's businesses engage in anti-competitive practices.

    Any Essentra employee engaging in anti-competitive practices may be subject to disciplinary action which may lead to dismissal and may face personal criminal liability.

    It is the responsibility of all Essentra employees to ensure that they report any infringement or suspected infringement of competition laws involving Essentra to their Line Manager or otherwise in accordance with the Essentra 'Right to Speak' Policy.

    Competition Compliance Policy PDF 0.01MB

Agency Compliance Policy

  • Essentra plc is committed to implementing a framework which facilitates the appointment and management of agents or other intermediaries authorised to act on behalf of any member of the Company on a basis which ensures compliance with the standards of business conduct required by Essentra plc's policies and by law.

    This policy sets out Essentra plc’s ethical and legal compliance policy for the entering into and ongoing monitoring of all agency or other similar intermediary arrangements by Essentra plc or any of its subsidiaries ("Essentra" or "the Company") and is part of the Company’s corporate governance and internal control arrangements.

    Appointing agents

    When considering the choice of agency or agent, including any other intermediary authorised to negotiate or finalise agreements on behalf of Essentra, ("Agent") the key issues to be considered are:

    • A reputation of corruption in the territory (a Corruption Perceptions Index is available at: www.transparency.org); 
    • Does the Agent have the necessary resources, knowledge and skill for the promotion and/or sale of the relevant product or business activities in the relevant market? 
    • Does the Agent conduct a legitimate business? Can the Agent be trusted to act with integrity and within the law?
    • Does the Agent have any conflicts of interest which are not in accordance with Essentra's standards of business conduct or which may otherwise affect the ethical performance of their duties?

    Appropriate due diligence into these issues must be conducted and appropriately documented before the decision to appoint any Agent is made. These due diligence issues must also be considered as part of the ongoing monitoring obligations detailed in this policy during the course of each Agency agreement.

    Compliance with policies

    Every Agent must be provided with a copy of Essentra's Agency Compliance policy, Code of Business Ethics, Policy on Bribery & Corruption, Policy on Gifts and Entertainment, Policy on Conflict of Interests and Competition Law policy and such other Essentra policies as may be specified from time to time by the Essentra plc Company Secretary. A written acknowledgement of their receipt and understanding of such policies must be obtained. All Agents must also be kept informed of any revisions to such policies and provide updated written acknowledgements

    Each Agent must be required, at six monthly intervals in conjunction with the Company’s annual and half year reporting cycle, to confirm in writing that the Agent has not engaged in any illegal, corrupt or unethical conduct in the performance of the Agent’s duties under the agency agreement and that the Agent remains in compliance with all applicable laws, regulations, rules and Essentra’s policies.

    Agency agreements

    An agency agreement in a form approved by the Essentra plc Company Secretary, which provides for Essentra’s ethical and legal compliance requirements, must be entered into before an Agent undertakes any work on Essentra’s behalf.

    Commission

    The rate of commission or other fees to be paid should be tailored to the role of the Agent to ensure they are appropriately incentivised to promote Essentra’s interests. Care should be taken to avoid levels of reward that could tempt an Agent into unethical behaviour such as sharing parts of their commission with persons able to secure the grant of business to Essentra.

    Bank account details provided by an Agent for the receipt of commission or other payments must be subject to appropriate due diligence and commission payments in cash or to third party accounts must be avoided. In the event that the Agent fails to submit a statement of compliance as required under this policy, all payments of commission to that Agent must be suspended.

    "Red flag" warnings

    All Essentra employees appointing, or working with Agents, should be aware of certain “red flags”, which may indicate that the Agent in question does not meet the standards of business conduct which Essentra requires. These include, without limitation:

    • Agent's previous behaviour is rumoured to be unethical or unlawful; 
    • Agent lacks experience in the market or country in question; 
    • Agent advises that cash is needed to secure any business;
    • Agent seeks unusually high commissions or requests payments for vague, urgent or unspecified purposes;
    • Agent requests payment of the commission, or a significant proportion thereof, before or immediately upon award of the contract by a customer;
    • Agent requests payments be made in cash, or to an unusual bank account (for example, offshore, numbered or Swiss) or to any third party;
    • Agent's ability to secure a contract appears based on improper or unethical relationships with key individuals;
    • Agent requests an arrangement (or some other special terms) on other than usual arm's length commercial terms.

    If any Essentra employee is aware of the existence or suspected existence of any issues regarding the failure of any Agent to comply with Essentra’s required standards of business conduct they should be reported forthwith to their Divisional Managing Director or President, who shall be responsible for informing the Essentra plc Company Secretary, or raised in accordance with the Essentra plc Right to Speak policy.

    Records

    Copies of all due diligence information gathered and all documents relating to the Agent’s activities, including emails, progress reports, notes of meetings and records of all payments made to the agent (including receiving bank account details) must be appropriately filed and retained. Copies of due diligence records must be retained for a minimum of six years after the termination of any agency arrangements.

    Reporting of new agency agreements

    Employees responsible for Essentra entering into new agency agreements are required to advise the Global Controls and Compliance Officer forthwith of such new agreements in accordance with Appendix A of this policy.

    Monitoring of agency agreements

    Employees responsible for the operational management of agency arrangements are required to ensure that Agents are provided with all applicable Essentra policies and that Agents provide such acknowledgements and statements of compliance as are required under this policy.

    Employees responsible for the operational management of agency arrangements are required to report to the Global Controls and Compliance Officer on the annual monitoring of agency agreements.

Anti Bribery and Corruption Policy

  • Essentra is committed to ensuring that all of its international activities are conducted in accordance with all applicable legal and regulatory requirements and the highest standards of ethical business conduct.

    It is the responsibility of all Essentra employees to ensure that none of Essentra’s businesses engage in practices which infringe legal or regulatory requirements or which fall below the highest standards of ethical business conduct.

    Any Essentra employee engaging in business practices which infringe legal or regulatory requirements or fall below the highest standards of ethical business conduct may be subject to disciplinary action which may lead to dismissal and may face personal criminal or civil liability.

    It is the responsibility of all Essentra employees to ensure that they report any infringement or suspected infringement of legal or regulatory requirements or the highest standards of ethical business conduct involving Essentra to their line manager or otherwise in accordance with the Essentra ‘Right to Speak’ Policy.

    Anti-Corruption & Bribery Policy PDF 0.03MB

Modern Slavery Policy

  • Essentra is committed to ensuring that all of its international activities are conducted in accordance with all applicable legal and regulatory requirements and the highest standards of ethical business conduct.

    Throughout its international activities Essentra supports human rights as set down by the United Nations Declaration and its applicable International Labour Organisation conventions and complies with relevant and applicable human rights legislation in the countries in which it conducts business.

    The Modern Slavery Statement applies to Essentra plc and its subsidiary undertakings as at 31 December 2024. The Board approved this Statement on 12 March 2025.

    Modern Slavery Statement PDF 0.20MB

    Modern Slavery Subsidiary Undertakings PDF 0.17 MB

Right to Speak Policy

  • Essentra plc, together with its affiliates and subsidiaries (together or individually ‘Essentra’ or ‘the Company’), is committed to doing business the right way, to continually earn the trust of customers, other stakeholders and the wider marketplace. In accordance with the Essentra Ethics Code, the Board of Directors and Group Executive Committee expect all employees - and anyone carrying out work on behalf of the Company - to maintain the highest standards of business conduct and personal behaviour at all times, and to act safely, honestly, responsibly, lawfully and with integrity.

    In support of this commitment, and consistent with its core values, Essentra seeks to maintain a culture of openness and accountability, so that prompt action can be taken to address any illegal or unethical conduct involving Essentra or anyone working for or on behalf of the Company. Essentra does not tolerate attitudes or activities that amount to a breach of law or trust, or otherwise fall below the highest standards of business conduct and personal behaviour.

     

    Essentra Right to Speak Policy

    Essentra Right to Speak Disclosure Portal

Essentra Ethics Code

  • Essentra’s Ethics Code helps to ensure that everyone working for or on behalf of the Company understands our expectations and conducts Essentra business in a way that is consistent with these values and our procedures.

    Our Ethics Code is a framework to assist in making ethical decisions, and is supported by further policies and guidance notes.  None of these documents can address every issue that an Essentra employee may face in the performance of their duties.  However, together with common sense, logic and good faith behaviour, our Ethics Code provides a framework and structure to guide each of us in determining the correct course of action.

    Essentra Ethics Code

Supplier Code of Conduct

Quality

  • Essentra recognises that customers depend on suppliers providing a range of products and services that consistently and demonstrably meet their requirements. Essentra is committed to this objective through the application of quality systems and aims to exceed customer expectations through the everyday actions of employees.

    Quality goals are never static – required standards are constantly being raised in response to customer and consumer demands, driven by the competitive nature of the marketplace. Essentra strives to rise to this challenge by continually improving the effectiveness of quality management systems, reviewing quality objectives regularly and modifying the approach, where appropriate.

    Essentra's commitment to quality is underpinned by detailed manuals, procedures, measurements and training, and is communicated to all employees to ensure a depth of common understanding and consistency of application. In order to meet the shared objective of enhancing customer satisfaction, Essentra actively seeks input from customers and suppliers together with encouraging teamwork, enthusiasm and participation from everyone within the Group.

    Essentra ensures that the necessary resources are available to implement this policy and reviews it periodically for suitability.

Ethical Trading Policy & Supplier Code of Conduct

  • Essentra regards suppliers as partners and works with them to help achieve policy aspirations in the delivery of products and services. Specifically, Essentra is committed to working with its suppliers of products and services to ensure that the welfare of workers and labour conditions within the supply chain meet or exceed recognised standards.

    Each business is responsible for ensuring that all those affected by the supply chain are producing goods and services which adequately meet internationally recognised minimum requirements for worker welfare and conditions of employment. The minimum requirements are defined by the International Fair Labour Organisation (IFLO) or based on the Ethical Trading Initiative dependent on the business jurisdiction.

    Our business has implemented appropriate processes to assess supplier’s compliance with the laid down standards and monitor performance and improvements against the standards. Suppliers who are unable to meet all the requirements after an initial assessment/audit will be given the opportunity to fully comply within a period which is deemed appropriate for the circumstances. An action plan should be documented and the supplier expected to commit to addressing all the areas where discrepancies have been identified. The process of improvement via this method is principally down to the commitment of the supplier’s management team/owner/agent to ensure that all areas are addressed. If Essentra has reason to believe that the supplier is not making sufficient or committed progress, then this could lead to a closure in the relationship until such time that Essentra were confident that all areas had been satisfactorily addressed.

    Essentra companies reserve the right to cease a relationship with a supplier if it is subsequently found that unacceptable practices are being employed within any manufacturing sites used for Essentra products. These include use of child labour, forced or bonded labour as well as physical abuse or discipline and extreme forms of intimidation.

    The policy applies to every business in Essentra and is in line with our Supplier Code of Conduct.

    Responsibilities

    Essentra-wide ethical trading issues are the responsibility of the Chief Executive supported by the Group Executive Committee who are responsible for implementing and monitoring ethical trading policies within the respective businesses.