Compliance processes designed for effectiveness
The Geberit Code of Conduct describes the basic principles that have to be met in order to be an exemplary, reliable and fair business partner and employer. The content of the Code of Conduct was updated in 2014 and will be introduced and actively communicated to the employees in 2015. For its implementation, Geberit has established an effective system that focuses on compliance in the five key topic areas “antitrust legislation”, “corruption”, “employee rights”, “product liability” and “environmental protection”. In practice, it comprises various elements such as guidelines, continuous training, job orientation for new employees, e-learning campaigns, info letters, compliance-related audits and the Geberit Integrity Line, a whistleblower hotline for employees launched in 2013.
Compliance is subject to binding controls each year as part of reporting on the Code of Conduct for Employees. All Geberit Group companies receive 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 2014. In the interests of advancement and risk minimization, the compliance organization itself is also audited. At the end of 2014, the Internal Audit department and external auditors began examining the compliance processes with the specific aim of identifying possible improvements. Geberit is also a member of the compliance working group of SwissHoldings, in which compliance officers from all major Swiss companies exchange views on current compliance issues two to three times a year.
According to the materiality analysis, the prevention of anti-competitive behavior is a key aspect. The comprehensive training on antitrust legislation was continued, with Germany and Austria the countries focused on in the reporting year. Awareness-raising and further training – among other things via e-learning programs – will be continued in the remaining Geberit Group companies in Europe in 2015.
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. The company began developing a Code of Conduct for these partners in the reporting year.