Transparent and intelligible compliance processes were especially important in 2015 following the acquisition of the Sanitec Group. The subject of compliance had to be uniformly positioned throughout the Geberit Group. As is the case with other issues, the launch of the joint Intranet provided a suitable opportunity for this, presenting and explaining the compliance organisation on a dedicated page. In parallel to this, the management at all Group companies was called upon by the CEO to communicate in a suitable way to employees - including those without Intranet access - the information made available on the subject.
Effective Compliance organisation
A thorough review of the Compliance organisation at the end of 2014 yielded a very satisfactory result. The Internal Audit department and external auditors concluded that responsibilities are clearly regulated within the various Group functions and the mechanisms are geared towards effectiveness. Geberit is guided by the relevant criteria that are typical of the industry and, accordingly, places the emphasis on the areas of antitrust legislation, corruption, environmental protection, employee rights and product liability. Once an assessment of the existing compliance structures had been completed, the Geberit Group's Compliance Programme was also extended to the companies of the former Sanitec Group.
The focal areas mentioned are described in detail in Geberit's Code of Conduct, a new version of which has been available since the start of 2015. The Code of Conduct has existed since 2008. Compliance with the Code has always been audited annually in all organisational units, by means of a detailed questionnaire, and this now includes the organisational units of the former Sanitec Group. No significant breaches of the Code of Conduct were identified in 2015. The Code of Conduct attaches special importance to the particularly sensitive subjects of antitrust legislation and corruption. The corresponding directives have been updated and made accessible to all relevant employees through suitable communication channels. Over the coming year, there will be a repeat of a Group-wide survey on correct practice regarding donations. The Geberit Integrity Line, which was established in 2013, was opened to employees of the former Sanitec Group in 2015. This service is intended to enable employees to anonymously report cases such as sexual harassment or when a corrupt payment is covered up. There were no reports of significant violations of the Code of Conduct, either via the Integrity Line or the checks described.
Training events geared specifically towards antitrust legislation matters were held in 2015 for the Managing Directors of the European sales companies. An e-learning course on the subject of compliance in the sphere of antitrust legislation will be held for all employees concerned in the first quarter of 2016.
Overhauled identity launched
In 2015, a key compliance element was remodelled in the Geberit compass, which describes the cornerstones of the corporate culture: the joint mission, the shared values, the operational principles and the success factors to be considered by all employees. The CEO presented and explained these cornerstones in the first joint edition of the Group-wide employee magazine, which is published in six languages. At the end of 2015, a physical copy of the Compass was sent to the home addresses of all employees, with a letter from the CEO.