Increasingly comprehensive compliance processes

The five topic areas “antitrust legislation”, “corruption”, “employee rights”, “product liability” and “environmental protection” are at the forefront of efforts in the area of compliance. The relevant processes are continually optimized by the departments involved. Cartels of any kind and other competition-distorting activities are cat­e­gor­i­cally rejected. Adherence to compliance in all organizational units is subject to binding controls each year as part of reporting on the Code of Conduct for Employees. In 2013, this survey, which has been implemented since 2009 and continuously expanded ever since, comprised around 50 questions on the five above-mentioned topic areas. In addition, on-site audits are performed by the Internal Audit department and corrective measures taken in the event of misconduct. The audits also comprise special interviews with the managing directors of the individual companies on the topics mentioned in the Code of Conduct. The respective information is verified. The findings from the survey and audits form the basis for the annual Compliance Report submitted to the Group Executive Board and are published in the → Sustainability Performance Report in accordance with the guidelines of the Global Reporting Initiative (GRI). No significant breaches of the Code of Conduct were identified in 2013.

To raise awareness on the topic of compliance, a “Corporate Compliance Info Letter” was sent to Group managers in 2013 for the first time. This letter contained information on the latest developments in case law, legislation and practice in the areas of antitrust legislation, product liability and corruption. Com­pre­hen­sive training on antitrust legislation via an e-learning program was carried out as planned at the sites in China, India, South Africa, Southeast Asia, Australia and the USA. During this training, the respective members of management and the field service employees were brought up to the same level of knowledge and prepared for the market challenges. As in 2011, all sites in Europe will take part in the updated e-learning program in 2014.

As an active member of Transparency International, Geberit is committed to high standards in combating corruption, which it implements accordingly. Guidelines on donations that apply Group-wide are in place in this regard. A high level of aware­ness with respect to the correct practice regarding donations – which particularly plays a role during marketing campaigns – can be seen in the company. In cases of uncertainty, local business and marketing managers can have marketing concepts examined early on and consult the Group’s Legal department. Awareness of compliance issues is also raised among sales partners at locations without Geberit rep­re­sen­ta­tion, with a Code of Conduct for these partners currently in preparation.

The → Geberit Code of Conduct, which is currently being revised, will be published in 2014 and demonstrates the company’s ongoing commitment to further development. This includes the → Geberit Integrity Line for employees launched in 2013, the goals of which include identifying breaches of the Code and enabling the company to take the necessary measures. Overall, since the introduction of the Code of Conduct and the related training, employees’ awareness of misconduct and their understanding of compliance topics have increased considerably, all of which contribute to risk minimization.