EnerSys Communication on Progress
- Participant
- Published
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- 11-Oct-2022
- Time period
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- November 2021 – November 2022
- Format
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- Stand alone document – Basic COP Template
- Differentiation Level
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- This COP qualifies for the Global Compact Active level
- Self-assessment
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- Includes a CEO statement of continued support for the UN Global Compact and its ten principles
- Description of actions or relevant policies related to Human Rights
- Description of actions or relevant policies related to Labour
- Description of actions or relevant policies related to Environment
- Description of actions or relevant policies related to Anti-Corruption
- Includes a measurement of outcomes
- Statement of continued support by the Chief Executive Officer
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Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.
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To our stakeholders:
I am pleased to confirm that Enersys restates its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption, as well as the United Nations Sustainable Development Goals (SDGs).
In this annual Communication on Progress, we demonstrate our actions to continually improve the incorporation of the Global Compact and its principles into our business strategy, culture and daily operations as they are fully aligned with EnerSys core values. We aim to leverage the UNGC and the SDGs to further the transition to a low-carbon, clean energy future everywhere, for everyone. We also pledge to share this information with our stakeholders using our primary channels of communication.
Sincerely yours,David M. Shaffer
President & CEO
- Human Rights
- Assessment, policy and goals
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Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.
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Relevant reports, policies and statements: https://www.enersys.com/en/about-us/sustainability/policies_and_reports/
• 2021 Sustainability Report
• Corporate Social Responsibility and Human Rights Policy
• Code of Business Conduct and Ethics
• Conflict Minerals Report
• Anti-Slavery and Human Trafficking Statement
• Workforce Labor Rights Policy
• Conflict Minerals PolicyAssessment, policy and goals
As an approved member of the UNGC, EnerSys fully supports the ten UNGC principles and the seventeen United Nations Sustainable Development Goals (SDGs). Our Corporate Social Responsibility and Human Rights Policy are intended to communicate EnerSys’ position as well as the expectations for our business partners, particularly as it relates to SDG 10 where we identify some of our most significant impacts. EnerSys supports and respects the protection of human rights and recognizes that part of being a good corporate citizen includes respecting the human rights of those who interact with and/or act on behalf of the Company. We insist that all our partners, suppliers, vendors, and other stakeholders, apply and maintain the same comprehensive standards for human rights as outlined in our Corporate Social Responsibility and Human Rights Policy. This Policy is based on the United Nations Guiding Principles on Business and Human Rights, which includes an undertaking to respect the human rights reflected in the International Bill of Human Rights, the Universal Declaration of Human Rights and the Declaration on Fundamental Principles and Rights at Work. We are fully committed and aligned with the global consensus that respect for all minority rights, including indigenous peoples’ and women’s rights, is essential in observance of human rights. In 2021, we set goals to improve our female representation at the leadership level from 9% in 2021 to 20% in 2025, to improve our representation of multicultural talent in the U.S. at the leadership level from 16% in 2021 to 25% in 2025, and to become recognized by at least 3 global indexes as a leading employer by 2025.Our Corporate Social Responsibility and Human Rights Policy should be read in conjunction with our Workforce Labor Rights Policy which further details our efforts toward managing our workplace and workforce in an open, respectful, and dignified manner as it aligns with the UN Guiding Principles on Business and Human Rights. Additionally, EnerSys understands that we are part of a broader global community, wherever we do business. Engaging stakeholders, including indigenous peoples, as well as those from more at-risk populations, is a foundational component of our respect for human rights. Where practical, we are committed to dialogue and our goal is to listen, learn and consider the diverse views and local issues that affect the communities in which we operate. This includes a commitment to free, prior and informed consent (FPIC) with regard to indigenous peoples’ inherent and prior rights to their lands and resources, as defined and recognized by the United Nations Department of Economic and Social Affairs. Our Policy is available publicly and communicated internally and externally to our business partners and employees. Our commitment is reflected throughout the Company and can be identified in our Code of Business Conduct and Ethics, Conflict Minerals Report and Anti-Slavery and Human Trafficking Statement, all of which can be found on our website.
- Implementation
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Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.
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EnerSys strives to apply these principles, comply with applicable laws, and enforce our policies throughout our operations worldwide. A large part of that effort is ensuring that employees are informed of our policies through training and encouraging them to report any potential violations. EnerSys has developed training to ensure compliance with Company standards regarding our Policies and Statements. We will continue to develop and maintain training modules that support our commitment to human rights, including the prohibition of slavery and human trafficking, adherence to labor laws, adherence to truthful and trustworthy practices when dealing with employees, proper disclosure of information, and supply chain diligence, management and verification processes. Employees who have questions or have concerns about the location where he or she works, are encouraged to contact their supervisor, a member of the Human Resources department, or a member of the Legal Department. Employees may also anonymously report their concerns by calling or e-mailing the EnerSys Ethics hotline. Additionally, stakeholders may report violations of this Code on a confidential or anonymous basis by contacting the Business and Ethics Oversight Committee by fax, mail or e-mail, directly to an external and independent third-party administrator by web submission or by telephone to the Ethics and Compliance Hotline.
- Measurement of outcomes
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Description of how the company monitors and evaluates performance.
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In order to prevent slavery and human trafficking in our business and supply chain we have implemented internal accountability standards and procedures. Within our internal leadership, our Vice President, Global Strategic Sourcing leads the development and implementation of the Company’s efforts and works collaboratively with outside groups to promote responsible sourcing practices, including practices designed to prevent slavery and human trafficking. We also proactively communicate with external stakeholders and monitor trends and best practices in this area. EnerSys also engages in risk assessment where we undertake a periodic risk assessment of our supply chain to better understand the potential risks related to slavery and human trafficking. These assessments help us understand where human rights and labor issues may exist within our global supply chain so that we can prioritize and focus our responsible sourcing efforts. We also maintain whistleblowing procedures and anti-retaliation policies in order to empower and encourage employees to raise any concerns regarding compliance with this Statement, or any other concerns, without fear of retaliation. EnerSys provides access to an external and independent Ethics and Compliance Hotline. If the violation involves suppliers, appropriate action, up to and including termination of contracts will be undertaken. Additionally, we created an executive steering committee to oversee the integration of sustainability throughout our business and are leveraging this committee to ensure senior executive support, alignment and ongoing strategic direction. Suppliers must allow EnerSys, or an accredited third party, to conduct audits, including but not limited to environmental compliance, health and safety, product safety, conflict minerals, workplace labor rights, and corporate social responsibility. These audits may be in the form of questionnaires, site evaluations, discussions or the use of third-party databases. Failure to comply may result in discontinuance of current and/or the prevention of future business relationships between EnerSys and the supplier and its affiliates. These audits will be conducted periodically or as deemed necessary to address either the risk profile or past performance of any supplier. Policies are reviewed at least annually by the responsible subject matter experts and updated as needed.
As described in the Sustainability Oversight section of our sustainability report, we strengthened our internal governance and sustainability management team across our enterprise.
- Labour
- Assessment, policy and goals
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Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.
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Relevant reports, policies and statements: https://www.enersys.com/en/about-us/sustainability/policies_and_reports/
• 2021 Sustainability Report
• Workforce Labor Rights Policy
• Corporate Social Responsibility and Human Rights Policy
• Code of Business Conduct and Ethics
• Safety and Health Policy
• CEO Action for Diversity & Inclusion
Assessment, policy and goals
At EnerSys, our Workforce Labor Rights Policy demonstrates our efforts toward managing our workplace and workforce in an open, respectful, and dignified manner and it aligns with the UN Guiding Principles on Business and Human Rights, is inclusive of all rights outlined in the Universal Declaration of Human Rights to the extent those rights apply to business operations and respects the labor rights enshrined in the International Labor Organization (ILO) conventions, including CO87 and CO98. This Policy also includes additional information about our guiding principles and the actions we take to ensure an inclusive working environment, encompassing SDG 10 where we believe we have a notable impact. We are committed to providing equal employment opportunities to all applicants and employees without regard to sex, race, color, religion, national origin, age, disability, covered veteran status or any other characteristic protected by law. In 2021, we set goals to improve our female representation at the leadership level from 9% in 2021 to 20% in 2025, to improve our representation of multicultural talent in the U.S. at the leadership level from 16% in 2021 to 25% in 2025, and to become recognized by at least 3 global indexes as a leading employer by 2025. Our Workforce Labor Rights Policy should be read in conjunction with our Corporate Social Responsibility and Human Rights Policy which further outlines our commitments to our suppliers upholding human rights preventing modern slavery and child labor and maintaining discrimination-free workplaces in line with global principles. Our Code of Business Conduct and Ethics sets forth the legal and ethical standards of conduct for all of our employees, Board members, suppliers and business partners. EnerSys believes that to deliver innovation, high quality production, customer satisfaction and business success for our company, we must provide a work environment that enables our people to thrive. We are also committed to ensuring the safety of all employees by meeting or exceeding applicable safety and health requirements throughout the company. Within our Safety and Health Policy, we provide necessary resources to prevent injuries and illnesses through the cooperative efforts of all employees. These efforts include regular evaluations, implementation of improved methods and procedures, application of safeguards for processes and equipment and providing training for all employees to assist them in performing their jobs safely.
- Implementation
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Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.
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EnerSys strives to ensure that employees are aware of our policies through training and encourages them to report any potential violations. We also educate and train our employees to find and record potential hazards in our safety management system. There is a continued focus on improving the reporting and root cause analysis to prevent future recordable or lost time incidents. In addition to our health and safety training, we provide our employees with both formal and informal learning and development opportunities to advance their skills and careers. While training courses like anti-bribery and corruption, compliance, code of conduct, safety and general data protection regulation (GDPR) are compulsory, employees have access to additional educational opportunities within and outside of EnerSys to advance their development. We prioritize access to foundational and advanced training for all employees. Every EnerSys employee has access to our internal learning platform, housing over 2,500 courses on a variety of topics. It is management's responsibility to oversee implementation of all necessary safeguards to protect the safety and health of our employees. These safeguards include the development, promotion, implementation, coordination and monitoring of safety and health programs. Each location is responsible for ensuring these safeguards are in place and for working with employees to protect them from injury and illness. Our Corporate Environmental, Health and Safety (EHS) team is responsible for providing counsel and guidance to management in establishing their safety and health programs and in fulfilling their responsibilities under this policy. Employees who have questions or have concerns about the location where he or she works, should be encouraged to contact their supervisor, a member of the Human Resources department, or a member of the Legal Department. Employees may also anonymously report their concerns by calling or emailing the EnerSys Ethics hotline. Additionally, stakeholders may report violations of this Code on a confidential or anonymous basis by contacting the Business and Ethics Oversight Committee by fax, mail or e-mail, directly to an external and independent third-party administrator by web submission or by telephone to the Ethics and Compliance Hotline.
- Measurement of outcomes
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Description of how the company monitors and evaluates performance.
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Our management team oversees the implementation of all necessary safeguards to protect the safety and health of our employees. Each location is responsible for ensuring these safeguards are in place and for working with employees to protect them from injury and illness. Our Corporate Environmental, Health and Safety (EHS) team is responsible for providing counsel and guidance to management in establishing and auditing their safety and health programs. We also have EnerSys Safety Committees across our global footprint that meet regularly to boost our employee engagement in safety and support hazard identification and prevention. Policies are reviewed at least annually by the responsible subject matter experts and updated as needed. We certify our facilities and corresponding management systems to international standards where appropriate. There are seven EnerSys facilities certified to the ISO 45001 occupational health and safety standard. In our Shenzhen, China facility, we received the SA8000 Standard accreditation, recognizing our management system for social and labor standards. Additionally, our commitment to DEI extends to all layers of our organization, including our Board of Directors (Board) and leadership team. Our Board of Directors oversees EnerSys company performance at the highest level and is comprised of nine directors, including one woman and one man of color. All directors except for our President and CEO are deemed independent, and a non-executive serves as the Chairman of the Board. This year we also developed our DEI Steering Committee, which is comprised of our most senior business and functional leaders, as well as a mix of diverse, influential colleagues from around our business. In line with our four pillars around Commerce, Community, Culture and Talent, we formed subcommittees of strategic advisors from within the business. These committees will include employees from diverse backgrounds, as well as experts in the field. They will act as a sounding board for the DEI Steering Committee, keeping them informed of the needs, progress and impact of DEI initiatives within the business. EnerSys is also proud to be a part of the CEO Action for Diversity & Inclusion, a collaborative of nearly 2,000 CEOs from the world’s leading companies and organizations committed to advancing diversity and inclusion within the workforce. The organization was founded on the belief that diversity, equity and inclusion is a societal issue, not a competitive one, and that CEOs and the business community need to collaborate to drive change. We also recognize that employee engagement is critical to our success as a business. This year we completed our first-ever diversity engagement survey. While we included historical questions around EnerSys as a workplace, our main focus was to determine our employees’ sense of belonging as it related to inclusion for all.
- Environment
- Assessment, policy and goals
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Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.
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Relevant reports, policies and statements https://www.enersys.com/en/about-us/sustainability/policies_and_reports/
• 2021 Sustainability Report
• Environmental Policy
• Climate Change Policy
• Biodiversity and Critical Habitats Policy
• U.N. CEO Water Mandate
• Alliance to Save Energy
• The U.S. Department of Energy’s (DOE) Better Plants Program (BBP)
Assessment, policy and goals
Our Environmental Policy describes our commitment to meeting and exceeding environmental compliance, reducing our environmental footprint and developing products that minimize environmental impacts across their life cycle. With the assistance of our Corporate Environmental, Health and Safety (EHS) team, EnerSys management is responsible for ensuring compliance with this Policy and developing and executing environmental programs across the organization. This Policy is supported at the highest levels of our organization, reinforced with the signature of our President and CEO. Where possible, we seek to certify our facilities and corresponding management systems to the highest possible international standards. Sixteen of our facilities in the Americas, EMEA, and Asia are certified to ISO 14001 environmental management standard. We also realize that our operations and the energy they require have an impact on the environment and the climate. Additionally, EnerSys is committed to reducing our own energy intensity and greenhouse gas emissions in our global operations, operating in an environmentally responsible and sustainable manner, and working with our suppliers to limit environmental effects and greenhouse emissions in our supply chain as noted in our Climate Change Policy. In 2021, we began the necessary processes to accurately compile and transparently report our energy usage and Scope 1 and Scope 2 greenhouse gas emissions. We also began the preliminary steps to quantify our Scope 3 emissions. In 2021, we set material, measurable goals to advance our progress and reduce our environmental footprint which include goals to reduce energy intensity per kWh of storage produced by 25% by 2030 compared to 2020, reduce water intensity per kWh of storage produced by 25% by 2030 compared to 2020, and establish an ambitious and measurable waste goal aligned with key customer, investor and other stakeholder expectations. Additionally, as a global leader in manufacturing energy storage and energy systems, we have an obligation to responsibly manage and reduce the waste materials we produce. Nonhazardous and hazardous waste must be handled carefully across our products’ value chain to promote safe operations and protect human health and the environment. This focus on reducing and eliminating waste also allows us to identify opportunities for reusing products and reducing waste disposal costs. We also recognize how critical biodiversity, High Conservation Value (HCV) areas and critical habitats are to the health of local ecosystems. Through in-depth assessments, we have determined that our direct operations have minimal impact on critical habitats or other areas with high diversity value. While we don’t anticipate expanding our physical operations to areas where this would be a concern, we would evaluate the impact of our new construction and projects on biodiversity, adopt measures necessary to minimize impacts and consult with stakeholders. We are dedicated to protecting the land and biodiversity through our Biodiversity and Critical Habitats Policy. Our sustainability policies govern our commitment to excellence in managing ESG topics both in our own operations and our supply chain. Each employee and operating unit across the organization, as well as our vendors and suppliers, is held to these standards, and compliance is overseen by the Board of Directors and senior executive team. These policies guide our strategy and programs for continuously monitoring and improving our performance and play a role in the Company’s impact on the SDGs, particularly SDG 7, SDG 10, and SDG 13 where we believe we have the most impact.
- Implementation
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Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.
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Our Board of Directors (Board), including our CEO, oversees the administration of our Sustainability Program and considers sustainability issues quarterly. There are four committees on the EnerSys board – Audit, Compensation, Technology Advisory and Nominating & Corporate Governance (NCGC). The NCGC has specific responsibilities to assist the Board in fulfilling its oversight responsibilities relating to the Company’s policies and practices regarding sustainability matters that are significant to the Company. Our other Board committees also have oversight responsibility for sustainability topics under their purview. Additionally, the Audit Committee and the entire Board are directly engaged with Environmental, Social and Governance (ESG) risk areas through our comprehensive enterprise risk management program. The Board of Directors and our CEO administer our ESG Program by which EnerSys communicates and monitors our information regarding compliance with our various policies, including those for sustainability, conflict minerals, environmental responsibility and engagement, employee and supplier diversity, antislavery and human trafficking, battery recycling programs and environment and sustainability issues concerning the production and life cycle of our products. The Board of Directors and our CEO also administer our Sustainability (ESG) Program, which includes governance over our Climate Policy. This Policy is administered and governed by our Chief Executive Officer under the oversight of the Board Nominating and Corporate Governance Committee. Responsibility for its successful implementation belongs with every EnerSys employee.
At EnerSys, we are actively seeking to reduce our direct and indirect greenhouse gas emissions by increasing the efficiency of our operations and exploring renewable energy sources for our facilities. While heating and burning natural gas used in our operations is the most significant contributor to our Scope 1 emissions, our electricity usage, or Scope 2 emissions, represents the largest overall source of greenhouse gas emissions for EnerSys. When possible, we actively seek to electrify our operations through innovations such as replacing gas-fired melting pots with electricity. These efforts reduce our Scope 1 emissions, improve operational efficiency and safety and move us toward increasing electrification. We also look for opportunities to source electricity from renewable or low carbon sources which will reduce our Scope 2 emissions, and we are exploring ways to implement our own technologies across our facilities, in partnership with renewable power generation, to reduce our indirect greenhouse gas emissions. In 2021, as part of our growing sustainability commitment, EnerSys joined the following initiatives: U.N. CEO Water Mandate, Alliance to Save Energy, and The U.S. Department of Energy’s (DOE) Better Plants Program (BBP), focusing efforts on water and energy efficiency. Another key element to EnerSys’ sustainability strategy is our recycling initiatives which aim to recover every single battery we sell and return their materials to the battery supply chain, contributing to the circular economy. EnerSys is committed to providing the resources needed to operate a worldwide recycling collection program. Our program reduces the environmental impact of improper disposal and the need for new raw materials. We also aim to educate consumers on consumer battery recyclability. Our rechargeable batteries have a Call2Recycle certification label, showcasing how to safely recycle them at the end of their useful cycle.
- Measurement of outcomes
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Description of how the company monitors and evaluates environmental performance.
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In 2021, we made specific progress in the area of environmental protection. Our total Scope 1 and 2 GHG emissions increased by only 2% vs 2018, despite a nearly 9% increase in storage production; and our operations used 990.7 megaliters of water, which represents a more than 2% decrease per kWh of storage production compared to 2020. We prioritize using recycled water over fresh water wherever possible. In 2021, our percentage of water recycled increased to 12.6%. Our management team is charged with monitoring, developing, implementing, and improving the environmental programs and procedures at our facilities worldwide. As part of our Enterprise Risk Management process, we evaluate all risks that have the potential to impact our business, including climate change. The Quality and Sustainability Function is responsible for bringing these risks to the risk management process. The Executive Leadership Team is responsible for reviewing these risks and overseeing how they are managed. The Board oversees various risks affecting EnerSys through its committees. EnerSys has in place a risk management program, that, among other things, is designed to identify risks across the company with input from each business unit and function. Material risks are identified and prioritized by management and its risk committee that reports to the Audit Committee, and each prioritized risk is referred to the appropriate committee of the Board for oversight. We measure our improvement in these areas by setting meaningful goals, which evolve over time in coordination with our progress. We are committed, where feasible, in alignment with our business objectives, to better measure, improve, report, and assist others with increasing energy efficiency and reducing greenhouse gas emissions and overall environmental impacts.
- Anti-Corruption
- Assessment, policy and goals
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Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.
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Relevant reports, policies and statements https://www.enersys.com/en/about-us/sustainability/policies_and_reports/
• 2021 Sustainability Report
• Global Antitrust Compliance and Fair Competition Policy
• Code of Business Conduct and Ethics
Assessment, policy and goals
EnerSys is committed to preventing corruption in all its forms and do not tolerate it in our business or in those with whom we do business. We diligently conform with all anti-bribery and anti-corruption laws, including the Foreign Corrupt Practices Act of 1977 (FCPA) and the UK Bribery Act 2010 and our Global Antitrust Compliance and Fair Competition Policy ensures that EnerSys and all of its employees comply with all laws, rules and regulations relating to antitrust and fair competition. This Policy ensures that no one acting on EnerSys’ behalf may use bribes, kickbacks, or other unethical and improper conduct, or engage in illegal and corrupt practices. We uphold all laws, such as the FCPA, relevant to countering bribery and corruption and will actively cooperate with regulatory authorities in the investigation and punishment of any act of corruption or bribery by any person employed by or associated with EnerSys. Additionally, our Code of Business Conduct and Ethics prohibits a variety of unethical and corrupt practices, including but not limited to, commercial bribery, kickbacks, bribes, fraud, and misuse of funds or improper influence.
- Implementation
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Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.
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EnerSys strives to apply these principles, comply with applicable laws, and enforce our policies throughout our operations globally. A substantial part of that effort is ensuring that employees are aware of our policies through training and encouraging them to report any potential violations. Employees who have questions or have concerns about the location where he or she works, should be encouraged to contact their supervisor, a member of the Human Resources department, or a member of the Legal Department. Employees may also anonymously report their concerns by calling or e-mailing the EnerSys Ethics hotline. In addition to our health and safety training, we provide our employees with both formal and informal learning and development opportunities to advance their skills and careers. While training courses like anti-bribery and corruption, compliance, code of conduct, safety and general data protection regulation (GDPR) are compulsory and recur on an annual, biennial or triennial basis, employees have access to additional educational opportunities within and outside of EnerSys to advance their development. Training is also assigned based on position title category and/or level, as some courses are specific to different job functions, such as assignments targeted at managerial responsibilities. For non-compulsory training, completion rates have increased by 23% in the past two years. In 2019, the completion rate for self-assigned and/or manager-assigned training was 69.9%. In 2021, the completion rate was up to 85.6%. We understand that due to the nature of manufacturing work, our production employees may not have as much time for or access to our online, non-compulsory educational opportunities as our office employees. That is why, in 2021, we developed several courses to be facilitated on-site for production employee leaders, including line leads. This is just one step towards shifting the culture at our manufacturing facilities and creating opportunities for production employees to enjoy professional development opportunities with the support of their managers. Additionally, every stakeholder has the responsibility to ask questions, seek guidance, report suspected violations and express concerns regarding compliance with our Code of Business Conduct and Ethics. Any Stakeholder who knows or believes that any other Stakeholder has engaged or is engaging in Company-related conduct that violates applicable law, company policy, or this Code shall report such information to (i) the Ethics and Compliance Hotline (as described below), (ii) the Business Ethics Oversight Committee, or (iii) to an EnerSys Executive Officer. A Stakeholder may report such conduct openly or anonymously without fear of retaliation. The Company will not discipline, discriminate against or retaliate against any Stakeholder of the Company for reporting such conduct, unless it is determined that the report was made with knowledge that it was false, or, who cooperates in any investigation or inquiry regarding such conduct. Any manager of employees, consultants, agents, or other third-parties who receives a report of a violation of this Code must immediately report such information in the manner described above for Stakeholders.
- Measurement of outcomes
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Description of how the company monitors and evaluates anti-corruption performance.
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No one acting on EnerSys’ behalf may use bribes, kickbacks, or other unethical and improper conduct, or engage in illegal and corrupt practices. We uphold all laws, such as the FCPA, relevant to countering bribery and corruption and will actively cooperate with regulatory authorities in the investigation and punishment of any act of corruption or bribery by any person employed by or associated with EnerSys. We carefully document uses of funds and assets, in accordance with accounting policies and guidelines, to ensure that bribery and corrupt activity does not occur within our business or among our employees and stakeholders. Our Code of Business Conduct and Ethics prohibits a variety of unethical and corrupt practices, including but not limited to, commercial bribery, kickbacks, bribes, fraud, and misuse of funds or improper influence. Any Stakeholder with concerns regarding questionable accounting or auditing matters or complaints regarding accounting, internal accounting controls or auditing matters occurring within the Company should confidentially and anonymously if they wish, submit such concerns or complaints in writing to Internal Audit at the address or the telephone numbers listed below under “Reporting and Compliance Procedures.” All such concerns and complaints will be forwarded either directly to the Audit Committee or to the Senior Director of Internal Audit in compliance with the requirements of the Company’s Procedures for Handling Complaints Regarding Accounting and Auditing Matters. The Audit Committee will evaluate the merits of any concerns or complaints received by it and authorize such follow-up actions, if any, as it deems necessary or appropriate to address the substance of the concern or complaint.