Compliance

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.

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, human rights and supply chain, competition law (in the case of exposed employees only), and the online whistleblower system. 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.

All employees are required to comply with the Code of Conduct and the directives and instructions that apply to them. The head of division is responsible for the implementation and enforcement of the Code of Conduct and the regulations. The processes are monitored by the internal control system, and the cases that occur and their settlement are monitored through twice-yearly Group-wide compliance reports. Any serious issues are escalated immediately. The compliance processes are also included in the regular internal audits.
With regard to “Compliance with laws and regulations”, the Group has set itself the targets of ensuring that there are no major issues concerning compliance with laws and regulations, that all relevant employees complete full compliance training and that there are no material deviations from the 
Group-wide control system.

Employees may report any breaches of our Code of Conduct, the Human Rights Statement or policies 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 impartial persons.

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. Our anti-corruption guideline raises awareness of the dangers of corruption and provides concrete guidance on how to deal with the issue. A separate policy 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 the protection of customers and consumers in particular. Our policy on competition law explains the basic provisions of competition law and provides guidance on how to avoid anti-competitive behaviour.

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 compliance with these global trade regulations. As the divisions have different business lines and organisational structures, the trade compliance controls 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. 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 policy 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 page Human rights

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 the page Human rights.

We strive to protect the environment and to use natural resources responsibly, efficiently and in accordance with all applicable laws and regulations.