Business Integrity and Compliance

Sibelco’s Compliance Program aims at ensuring that the company's business practices are compliant with applicable laws, regulations and ethical business principles, as well as contribute to a culture of integrity, in line with our core value of Integrity.

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Our commitment

Sibelco is dedicated to maintaining the highest standards of integrity in every aspect of our business. We are committed to acting professionally, fairly, and transparently in all our dealings, building trust with our stakeholders through ethical practices. We proudly adhere to the Ten Principles of the United Nations Global Compact, alongside all applicable laws and regulations, ensuring that our operations reflect our core values and our commitment to sustainable, responsible business practices.

"Sibelco’s Code of Conduct outlines our commitment to ethical and sustainable practices. Rooted in our purpose—Material Solutions Advancing Life—and guided by our core values of Integrity, Respect, Ownership, Excellence, and Teamwork, this Code encourages all employees and stakeholders to act with integrity and responsibility. Our vision is to lead in the mining and processing of essential materials, with a focus on integrity, sustainability, safety, and CO₂ emissions reduction."

Hilmar Rode, CEO

Our Code of Conduct

Our Code of Conduct is central to upholding Sibelco’s high standards of ethics and integrity. It serves as a practical guide, empowering every employee to live our values—acting lawfully, responsibly, and with integrity in all business decisions. This Code applies to everyone at Sibelco, regardless of location or role, with leaders setting the example. We also expect our suppliers and business partners to uphold these values through our Supplier Code of Conduct. For specific guidance, related policies are referenced throughout the Code, encouraging a comprehensive understanding and commitment across all teams.

The Code of Conduct undergoes regular reviews. It is available in 20+ languages.

Regular training is provided to managers and employees to help understand and apply the principles of the Code of conduct. The mandatory Code of Conduct online training includes a knowledge assessment to ensure proper understanding.

A dedicated compliance organization

Our compliance organization ensures adherence to our Code of Conduct through a structured oversight system, involving our Board of Directors, the Ethics Core Team, and a dedicated compliance team. Together, they uphold our commitment to ethical practices, monitor compliance standards, and support a culture of integrity across all levels of the company.

The Compliance Director oversees Sibelco’s compliance program and ensures its effectiveness and alignment with laws, regulations and best practices globally. The Compliance Director reports to the Chief Legal Officer and has direct access to Sibelco’s CEO and to the Chairman of the Board’s Audit Committee. The Compliance Director presents twice a year an update to the Board’s Audit Committee on Sibelco’s compliance policies, processes and matters.

The Ethics Core Team (ECT) supports the Executive committee in ensuring the effectiveness of the compliance program and the proper management of potential breaches of the Code of Conduct. The ECT, comprised of the Chief Finance Officer, the Chief HR Officer, the Chief Legal Officer and the Compliance Director, meets monthly and informs regularly the CEO on compliance matters updates.

Our Compliance Program

While our Code of Conduct is the pillar of our culture of integrity, we develop more detailed policies and controls aiming at maintaining the highest standards of integrity in every aspect of our business.

Our Compliance Program addresses the main compliance risk areas Sibelco faces. Our employees are required to comply with our compliance policies and are encouraged to report any potential breach of these policies. Compliance with our compliance policies is essential, and violations may lead to disciplinary action, including termination of employment.

Anti-Corruption

Our strict prohibition of corruption and bribery reinforces our dedication to ethical business conduct. Sibelco prohibits any form of corruption, whether public or private, active or passive.

Our Anti-Bribery and Anti-Corruption Policy prohibits any direct or indirect offers, promises, or exchanges of benefits intended to improperly influence decisions in our favour. We neither request nor permit others to make payments, promises, or offers on our behalf, and we strictly reject any form of bribery from government officials or private individuals.

Our Anti-Bribery and Anti-Corruption Policy is complemented by specific procedures addressing key corruption risk areas such as the engagement of third parties, or the offer of gifts and entertainment to third parties.

Anti-Trust

Sibelco is committed to fair competition and fully complies with antitrust laws. We avoid any actions that could unfairly limit competition, such as colluding on prices, dividing markets, or restricting production. Our employees are expected to uphold these standards and avoid sharing confidential information with competitors or engaging in any conduct that could compromise a fair marketplace.

International Trade Controls and Regulations

Sibelco is dedicated to full compliance with all import and export laws, restrictions, and sanctions that govern our international trade activities. Every Sibelco employee involved in international transactions is responsible for adhering to these laws, no matter their location. Accuracy in providing information to the relevant authorities is essential, and transactions should not proceed if there is any uncertainty about legal compliance.

Data Privacy

At Sibelco, we prioritize the privacy and protection of personal data in accordance with applicable data protection laws and regulations. We are committed to ensuring that all personal information collected, processed, and stored is handled responsibly and securely. Employees must be vigilant in safeguarding sensitive data, using it only for legitimate business purposes and within the scope of applicable laws. Unauthorized access, disclosure, or misuse of personal data is strictly prohibited and may result in disciplinary action.

Conflicts of Interest

All Sibelco employees should proactively avoid conflicts of interest and any situations that may give the appearance of such conflicts. Employees are also prohibited from competing with Sibelco, either directly or indirectly, or assisting others in competing against us.

Every employee is required to disclose any potential or actual conflicts of interest to their line manager, Internal Audit, or the Legal and Compliance Team. Any exceptions to this policy must receive approval from a member of the Executive Committee.

Insider dealing

The shares of SCR Sibelco NV are traded on the Expert Market of Euronext Brussels. Our share dealing policy prevents unfair advantages for insiders with privileged information. The purpose of the policy is to establish Sibelco’s rules to prevent insider dealing, unlawful disclosure of inside Information, and market manipulation as well as the perception of insider dealing and market manipulation.

Supplier Code of Conduct

The Sibelco Supplier Code of Conduct aligns with our commitment to sustainability and responsible business practices, reflecting our purpose of Material Solutions Advancing Life. This Code outlines four non-negotiable principles that all suppliers and subcontractors are expected to uphold and replicate throughout their supply chains. Compliance with these principles is essential for Sibelco's supplier selection and evaluation process, and all suppliers are responsible for educating and ensuring adherence to the Code among their employees, agents, and sub-tier suppliers.

Our whistleblowing channels

Our employees and business partners are encouraged to report any potential breach of our Code of Conduct, compliance policies or local laws and regulation. Sibelco offers several reporting channels to its employees:

Their line manager
Human Resources representatives for work-related matters
Internal Audit or the Legal and Compliance Team
An email to the Compliance office (compliance@sibelco.com)

Employees and third parties can also report their concerns through the ReportLine, our external platform comprising a 24/7 Web report tool and a hotline available in 58 languages. The ReportLine offers the possibility to report anonymously where permitted by law.

All reports made is good faith are thoroughly and independently investigated and when substantiated appropriate corrective actions are implemented.

Non-Retaliation Policy

Sibelco is dedicated to fostering a safe environment where employees feel empowered to report potential misconduct. We strictly prohibit any form of retaliation against those who make good-faith reports or participate in investigations. Employees are protected from negative actions, even if their concerns are found to be inaccurate, provided they are reported in good faith. At Sibelco, you can speak up freely, knowing you are safeguarded as long as your reports are sincere and honest.

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