High standards for compliance

Various departments are working together on the continuous optimization of existing processes regarding compliance topics. The five topic areas “compliance with anti-trust legislation”, “prevention of corruption”, “employee rights”, “product liability” and “environmental protection” are at the forefront of this effort. Price-fixing, cartels and other competition-distorting activities are categorically rejected. During the year under review, around 700 employees (managing directors, employees in the sales companies at the management level and field service employees) in Europe received training on the subject of anti-trust legislation by means of a comprehensive e-learning program. The program is to be repeated every two years. In addition, new employees from the relevant business sectors are trained in anti-trust legislation by means of this e-learning program. In addition, as an active member of the international organization Transparency, Geberit orients itself to high standards in combating corruption and implements them accordingly. In 2009, all managing directors in all countries were questioned in detail about the financial contributions they make. Instructions at the Group and at the local level afterwards emphasized legally permissible behavior. This survey will be repeated in 2012.

Compliance with the directives in all organizational units is bindingly monitored on the occasion of the annual report on the employee Code of Conduct. This Code of Conduct reporting includes a total of around 50 questions on the five topics areas mentioned above. The survey has been carried out annually since 2009. The annual Compliance Report is compiled for the attention of the Group Executive Board on this basis. In addition, onsite audits are carried out and corrective measures are taken in the event of misconduct. Results are presented in the Sustainability Performance Report. No violations of the Code of Conduct were discovered in 2011.