Compliance

Our Code of Conduct prohibits all forms of bribery and corruption. None of our employees or business partners may use corrupt practices in any countries where they operate. They must behave honestly and correctly in their dealings with both public officials and persons from the private sector and must learn about the local legal requirements in any countries in which they operate. Our anti-corruption guideline raises awareness of the dangers of corruption and provides concrete guidance on how to deal with the issue. A separate guideline specifies how to ensure due diligence services and how to deal with intermediaries such as agents and distributors.

Our Code of Conduct states the guiding principle of adhering to fair competition, which ensures fair pricing and customer and consumer protection in particular. Our directive on competition law explains the basic provisions of competition law and provides guidance on how to avoid anti-competitive behaviour. It raises awareness of situations that could be problematic from a competition law perspective.

In accordance with our Code of Conduct, we comply with all applicable trade control laws. Numerous import and export regulations apply to us because we operate in a global business environment. Our Trade Compliance Directive sets the framework for all of our divisions regarding compliance with these global trade regulations. Since the divisions have different business lines and organisational structures, the trade compliance controls (including their internal compliance programmes and related processes) must be risk adjusted and adapted to each division

Our Code of Conduct states that we collect and store the personal data of employees and third parties in accordance with all applicable laws and regulations. This includes the right of individuals to be informed and to make decisions about any operations related to their personal data, including the collection, use, disclosure, retention, alteration and erasure. Our Data Protection Directive implements the EU General Data Protection Regulation (GDPR) by setting out and implementing its provisions and defining roles and responsibilities. We also comply with any applicable local data protection regulations.

Employees are duty bound by the Code of Conduct to treat insider information as confidential, and the Code of Conduct forbids employees from making use of such insider information. The guideline on insider trading defines the terms “insider” and “prohibition on trading and making recommendations”, as well as the regular blocking periods for insiders and regulations for ad hoc blocking periods.

See the sections on “Supply chain – sound procurement practices” and the webpage “Human rights”

The divisions are responsible for implementing the Group-wide principles and directives. The compliance organisation consists of a Group Compliance Officer and divisional and local compliance officers. These officers help the divisional and local management to implement the directives and serve as contact persons for the employees.

Employees may report any breaches of our Code of Conduct, the Human Rights Statement or directives to their line managers or the compliance organisation. Alternatively, employees or third parties may report actual or suspected serious breaches anonymously through our online whistleblower system. It is ensured that any actual or suspected compliance breaches are investigated and decided by unbiased persons.

During the induction process, all employees receive our Code of Conduct and any directives that relate to their functions. As part of online training sessions on the Group-wide compliance programme, employees receive annual training primarily on the topics of the Code of Conduct, corruption, conflicts of interest, data protection, competition law (in the case of exposed employees only) and the reporting system. In the coming year, there will be an additional focus on the topics of human rights and sustainable supply chains. The divisions conduct further training in specific areas (e.g. trade controls). Employees who do not have access to online training are trained by the divisions as required. The local and divisional compliance officers receive special and regular training for their tasks.

Compliance with the regulations is monitored through twice-yearly Group-wide compliance reports and is included in regular internal audits. Any serious issues are escalated immediately. The internal control system also covers compliance-related issues.
The Group ensures that all relevant employees complete full compliance training and that there are no material deviations from the Group-wide control system. In doing so, it aims to prevent any material incidents regarding compliance with laws and regulations from occurring.

Well-functioning supply chains are crucial for us as an industrial company. When assessing our suppliers, we apply the Group-wide criteria of regionality, interest in long-term business relationships, competitive prices, financial soundness, and high delivery capability and quality.

Respect for human rights, as set out in the fundamental international conventions, is embedded in our core values and in particular in our Human Rights Statement. We are committed to respecting these as well as the laws that apply in the countries in which we operate. We expect our partners in the supply chain to apply the same standards, in particular the prohibition on child labour, forced labour and oppression, as well as occupational health and safety, freedom of association, the right to equality, the right to privacy, fair wages and working conditions, and the prohibition on corruption and bribery. Further information on human rights can be found on webpage “Human rights”.

We strive to protect the environment and to use natural resources responsibly, efficiently and in accordance with all applicable laws and regulations. In our supply chain, in our own activities and with respect to our products in operation, we work on the premise that ecological sustainability includes protecting the environment throughout our products’ life cycles.