12. Society (SO)

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 rolled out for the employees in 2015. in order to guarantee compliance with the requirements of the Code of Conduct, Geberit has established an effective compliance system that focuses on compliance in the five key topic areas “antitrust legislation”, “corruption”, “employee rights”, “product liability” and “environmental protection”. In practice, the system comprises various elements such as guidelines, continuous training, job orientation for new employees, e-learning campaigns, info circulars, compliance-related audits and the  Geberit Integrity Line, a whistleblower hotline for employees launched in 2013.

Anti-corruption, anti-competitive behavior and statutory compliance requirements are particularly important aspects in the category Society. Legal Services is responsible for their implementation.

As part of reporting on the Code of Conduct for Employees, compliance with the regulations set out there is subject to binding controls each year. All Geberit Group companies receive 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 this Sustainability Performance Report. An in-depth audit in the area of compliance was additionally carried out by the Internal Audit Department in 2014 in cooperation with an external partner.

With respect to the measures and objectives concerning the Code of Conduct, see also  Sustainability Strategy.

12.1 Anti-Corruption (SO)

Management Approach – Anti-Corruption

As a member of Transparency International Switzerland and the UN Global Compact, Geberit is committed to high standards in combating corruption. There are clear guidelines for the purposes of prevention and employees receive training in this area. Compliance with the guidelines is monitored as part of an annual binding survey at all Geberit Group companies (see the individual indicators for the results). Internal auditing is supplemented by on-site audits. In the event of misconduct, corrective measures are taken.

G4-SO3 Analysis of business units for risks of corruption

According to the annual binding survey carried out at all Geberit Group companies, there were no cases of corruption in 2014.

The topic of corruption is also a component of the audit program for the periodic inspections of the production plants and sales companies by the Internal Audit Department. The annual audit planning of the Internal Audit Department is oriented to risks. Each company is audited at least every five years, or considerably more frequently if it has a heightened risk profile. In 2014, the Internal Audit Department audited a total of 15 companies. This represents approximately one third of all Geberit companies. No cases of corruption were discovered in these audits.

In addition, approximately two to three in-depth audits are carried out each year, whereby the audit focus is on the processes of Group-wide functions. One of these in-depth audits covered the topic of compliance with the support of an external partner. The audit concluded that Geberit essentially had a good and effective compliance organization that covered the risk areas relevant for Geberit in a practical manner.

G4-SO4 Training on anti-corruption policies

In 2008, more than 98% of employees were informed of and trained in the Code of Conduct. With the aid of short films (“animatics”), the training focuses on gray areas in four topics of relevance: bribery (corruption), sexual harassment, workplace bullying and IT misuse. In 2014, as before, new employees were also trained accordingly as part of the Welcome events. In addition, since 2012 contributions toward increasing awareness of the Geberit Code of Conduct have been published on the intranet.

G4-SO5 Actions taken in response to incidents of corruption

No measures were necessary, as no cases of corruption were revealed in 2014.

12.2 Anticompetitive Behavior (SO)

Management Approach – Anticompetitive Behavior

According to the  Materiality analysis, the prevention of anti-competitive behavior is a most material aspect. Cartels of any kind and other anti-competitive behavior are categorically rejected.

The training on antitrust legislation was continued in 2014. In Germany, all new employees received training and 12 seminars were provided for training internal and external sales staff. A focus was placed on the topic of Internet sales. In Austria, the management received training on antitrust legislation issues. Training and seminars, including e-learning programs, will be continued in the Geberit Group companies in Europe in 2015.

G4-SO7 Anti-competitive behavior

There were no pending complaints alleging anti-competitive behavior in the reporting year.

12.3 Compliance (SO)

Management Approach – Compliance

The  Geberit Code of Conduct requires Geberit to comply with all local, national and international laws, directives and internationally recognized standards concerning business activities. The minimum statutory requirements are often exceeded here. This applies not only to business activities within a given country or area but also to matters outside the country if these have a significant impact on the competitive situation of the country or area.

G4-SO8 Sanctions due to non-compliance with regulations

Geberit incurred no fines in 2014 resulting from violations of statutory requirements.

12.4 Supplier Assessment for Impacts on Society (SO)

Management Approach – Supplier Assessment for Impacts on Society

See  chapter Suppliers

G4-SO9 Screening of suppliers using criteria for impacts on society

See  chapter Suppliers

G4-SO10 Significant impacts on society within the supply chain

See  chapter Suppliers