We do what's right

We comply with the law

“Do what’s right” – these words should guide all Stora Enso employees in their everyday work. This means that we always comply with all applicable local, national, and international laws, regulations, and voluntary commitments wherever we do business. It is of the utmost importance that you are aware of and adhere to all laws and regulations that apply to your work – including our company policies. Where local laws or regulations differ from the Stora Enso Code, we must make sure that we meet both standards. But playing by the rules is not enough – we go beyond compliance whenever possible and always strive to be better.

We also require all agents, consultants, and business partners who work on Stora Enso’s behalf to comply with these same laws and practices, including Stora Enso’s Supplier Code of Conduct.

We have zero tolerance for corruption

Our success as the renewable materials company is founded on the products and services we provide, not on unethical or illegal behaviour such as corruption. Corruption – the abuse of power for personal gain – comes in various forms such as bribery, excessive business entertainment, and conflicts of interest.

We never pay bribes or facilitation payments

We have a zero tolerance for bribery or facilitation payments. We strive to ensure that external business partners acting on our behalf are aware of and share our commitment to doing business ethically.

We avoid excessive business entertainment

We compete and do business based only on quality and competence. We do not offer or accept gifts, hospitality, or expenses payments that are of unreasonably high value, or that could inappropriately affect business decisions – or even create this impression. We ensure that rebates, commissions, donations, and sponsorships are made transparently.

We avoid conflicts of interest

For Stora Enso to remain a successful renewable materials company, all business transactions must be conducted with the best interests of Stora Enso in mind. This means that we avoid all conflicts of interest.

A conflict of interest is when you are involved in something in your personal life that could influence your work at Stora Enso and make it difficult for you to make decisions in the best interest of Stora Enso. These types of personal considerations or relationships should never impact your work at Stora Enso. Also avoid situations where it might appear to an outsider that you have a conflict of interest.

Examples of potential conflicts of interest:

Taking on an outside job that could conflict with your work at Stora Enso.
Signing a contract with a business that is managed or owned by a member of your family.
Acting as a corporate director, board member, or consultant in another company without the permission of your manager. You do not need permission to be involved in non-profit or charitable organisations.
Having a financial interest such as owning shares in companies that are Stora Enso’s suppliers, customers, or competitors. However, you may own insignificant shares in any company or fund where you as an owner have no possibility to influence the operations of the company.

Do not offer, promise, or accept bribery, facilitation payments, illegal rebates, or any other unethical payments – even if such payments are common in the local culture.
Gifts or hospitality should never be offered in ways that make recipients feel that the giver expects something in return. They should not be extravagant, excessive in value, or offered too often.
You should never give or accept cash or cash equivalents.
Stora Enso always pays the travel and accommodation expenses of the company’s own personnel, but normal business courtesies such as paying for a meal or sharing a taxi may be considered as reasonable hospitality.
Consult your manager if you think you may have a conflict of interest.
If you suspect your personal life or relationships may impact your decision-making, make sure a colleague with no ties to your situation makes the decision (when hiring someone, for example).
Always ensure you have your manager’s approval and record who made the final decision.

Q: A very important customer’s key contact person called me and demanded we pay an agreed rebate to a new account. This account’s owner is not the customer but a name that I do not recognise. Can I make the payment?

A: No. The account may belong to the customer but it may also be the contact person’s private account, in which case making the rebate payment would not only be a clear bribe but also a criminal offence in most countries. Make sure you understand the connection between the customer and the account before making any payments, and follow the rules in our Business Practice Policy.

We know our business partners

As a global company, Stora Enso works with tens of thousands of suppliers, customers, agents, consultants, and other business partners all over the world. When we know who our business partners are, we can reduce the risk of becoming involved in unethical, illegal, or criminal activities. Always conduct careful due diligence before selecting a business partner. As a company, we are not only responsible for the actions of our employees, but also for the actions of anyone who represents us.

We are committed to fully comply with applicable trade sanction programs and anti-money laundering and terrorist financing laws throughout the world. We do not engage in transactions with parties that are subject to trade sanctions or participate in money laundering or criminal tax evasion. All financial activities should be carried out transparently and recorded accurately.

Before engaging with external parties that act on our behalf, follow our anti-bribery due diligence procedures. Avoid partners that have a known history of bribery or present other signs of bribery risk.
Check all potential business partners against applicable sanctions lists. When planning transactions that have connections with countries subject to trade sanction programs, follow our due diligence procedures.
Stay alert for red flags for potential money laundering and terrorist financing. Red flags can include complex or unusual payment structures or methods (like cash), requests for payments to an unrelated account or third party, or lack of an apparent business purpose for the transaction.
Before engaging with a party based in a tax haven country, make sure it is a legitimate business. Our Ethics and Compliance team can provide a test for this.

Q: I’m about to close a deal. The customer’s mill is located in Central Europe but the customer’s sourcing contract is for a legal entity registered in the Bahamas. The customer explained that all goods should be shipped to their mill in Central Europe but invoices must be sent to and settled with the company in the Bahamas. Can I sign the contract?

A: By signing the contract you could be assisting in tax evasion. Any business transaction with a company in a Tax Sensitive Country such as the Bahamas must pass the substance test (detailed in our Business Practice Policy). A multi-country deal structure like this can also pose tax and even money laundering risks. Consult Group Tax for advice.

We compete fairly

Stora Enso’s high-quality products and services as well as our talented and committed employees are what makes us successful and competitive. Supporting free and fair competition in the market works in our interest and benefits society at large.

We believe that all companies should be able to trade and compete with us as they wish, as long as they follow local laws and regulations just as we do. We never get involved in fixing prices artificially high or low or take part in any other practices or agreements that restrict competition. We do not exchange confidential information with competitors.

As a general rule, do not agree on price fixing, output levels, market sharing, or customer allocations.
Do not share confidential market-related information with competitors. The safest way to do this is to avoid all unnecessary contacts with our competitors – always make sure you have a well-founded and lawful reason to contact a competitor. All unnecessary contacts with our competitors should be avoided. If a competitor instigates a discussion relating to market-related issues, stop the discussion immediately and inform Ethics and Compliance.
Do not make public price announcements or share commercially sensitive information with external parties without first consulting the Ethics and Compliance team.
Make sure you get legal advice before making any agreements with competitors or entering into exclusive long-term contracts with suppliers or customers.

Q: I work in sales and meet with employees of Stora Enso’s competitors at trade fairs and Trade Association events on a regular basis. Sometimes the topic of market trend comes up. What should I take into consideration during these conversations?

A: In general, any type of information discussed that could affect a competitor’s market strategy can amount to an illegal information exchange. You should take particular care when discussing aspirational and forward-looking statements on topics such as prices, capacity, and customers.

We protect our assets and value privacy

Innovation is at the core of Stora Enso’s transformation journey and we want to protect what is ours to remain competitive. In your work, you probably use computers, mobile phones, applications, and other technology that belong to Stora Enso. They should primarily be used for their intended business purpose – neither professional nor private use of company-provided technology or equipment may conflict with Stora Enso’s interests, policies, or guidelines. Naturally, all use must also be in line with applicable laws and regulations.

We protect sensitive information

Working for Stora Enso means that you are trusted to treat any sensitive information you learn in your work with absolute confidentiality. Sharing sensitive information with outsiders or using it for your personal gain may hurt Stora Enso. Do your part to protect it.

To prevent market abuse, we also set restrictions on share trading, disclosure, and other use of inside information.

We value privacy

Digitalisation brings great opportunities for Stora Enso but it also presents challenges such as how to treat the personal data of our employees, customers, suppliers, and other stakeholders. Collecting and processing this data will always be done with specified and legitimate business purposes and in compliance with applicable laws.

Protect the technology and equipment entrusted to you and only use them in legal and ethical ways. Respect copyrights, only install authorised software on company computers, and steer clear from unsecured websites.
Do not store offensive or obscene material (such as pornography) on company-owned devices.
Only discuss sensitive information in private settings and with people who are authorised to do so. Avoid discussing it with family or friends; in public places like restaurants, hotel lobbies, or public transport; at trade association meetings; or on social media.
Do not re-use the same password on multiple sites. Leaked access credentials are very easily tested against other services, especially if the username is the Stora Enso email address.
Also remember that you may not use non-public company information to buy or sell stocks or securities – or for other personal gain.
All collection and processing of personal data must have a clear and justified business purpose and comply with applicable laws. It should be relevant and necessary to the work you are doing.
Only collect the amount of personal data necessary for the specified purpose, make sure it is accurate and up-to-date, and delete it from all folders when outdated or no longer needed.
Be fully transparent about how the data will be used.
Keep all personal data safe and secure. Only authorised employees and external parties with a justified reason should view the data.

Q: I’m working on a confidential project related to a potential acquisition of a company in Spain. It is commonly known in the market that this company is up for sale but the potential buyers are not known. I’m flying to Spain to inspect the company’s facilities and would like to post on social media how nice it is to travel to warm and sunny Madrid for a work trip. Is this ok?

A: This is probably not a good idea. When you are entrusted with confidential information, you must be careful not to share it with unauthorised people. This also applies to situations where people are able to make conclusions based on incomplete information such as here: our competitors will likely know the company is up for sale and that Stora Enso does not have operations in Madrid, and may be able to determine what the work trip is about.

We communicate clearly and transparently

It is important for Stora Enso that our stakeholders understand and trust us. This means that we must communicate with them in a clear, transparent, and timely manner and make sure that everything we write or say, both internally and externally, is true and balanced. We also listen to our stakeholders to understand their views.

Stora Enso must follow the rules and regulations set for stock markets and financial reporting. Certain company information, for example, must be shared with all stakeholders at the same time.

Not all Stora Enso employees can speak on behalf of the company. Our main corporate spokespersons are the CEO, the CFO, the heads of Communications and Investor Relations, and Country Managers. When needed, our Communications functions will appoint and support other spokespersons.

If you are not an appointed spokesperson, do not publicly speak on behalf of Stora Enso. This includes platforms such as social media, traditional media, and stock exchanges. If you receive a request for comment, always forward them to the correct spokesperson.
When on social media, especially if you can be identified as a Stora Enso employee, conduct yourself in line with the Stora Enso Code and be clear about your views being your own, not Stora Enso’s. For more information, see our Social media guidelines.
When using your company email, remember that you are representing Stora Enso. Act professionally and with integrity.
Do not share confidential information about Stora Enso, our customers, suppliers, or other business partners on the internet.
Respect copyrights and do not engage in communications that may cause damage to the reputation of yourself, your colleagues, or Stora Enso.
Never share anything that may be seen as a threat, harassment, or bullying.

Q: I saw someone write on Facebook that Stora Enso is lying about its environmental efforts in my area and in reality, pollutes the soil and the sea with their operations. I know this isn’t true and really want to respond to the post to defend Stora Enso but I’m not sure how to do that.

A: You should not speak on behalf of Stora Enso unless you have been specifically asked to do so, even when you have good intentions and want to defend our company. You can always contact our communications team for advice; they are trained in responding to comments made about Stora Enso.