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 implemented at Geberit – including the former Sanitec Group – in 2015.
In 2015, the Geberit Compass, a key compliance element, was also updated. It describes the cornerstones of the corporate culture, namely the joint mission, the shared values, the operational principles and the success factors to be considered by all employees. This was presented and explained in the Group-wide employee magazine, which is published in six languages.
In order to guarantee compliance with the requirements of the Code of Conduct, Geberit has established an effective compliance system that focuses on the five following key topics: 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, eLearning campaigns, info circulars, compliance-related audits and the Geberit Integrity Line, a whistleblower hotline for employees. A separate Integrity Line will also be available for suppliers from 2017 onwards for reporting anonymously irregularities in the procurement process.
The reporting year also saw the completion of risk assessment in relation to agents, which involved all local sales companies being surveyed on their collaboration with agents. The outcome of this is that only a small number of companies work with agents and there is no exposure to risk. A code of conduct for business partners was nevertheless drawn up based on the Geberit Code of Conduct and communicated to the agents by the managing directors of the local sales companies.
Anti-corruption and anti-competitive behaviour are particularly material aspects in the GRI category Society. Legal Services is responsible for their implementation.
As part of the annual reporting on the Code of Conduct for Employees, compliance with the requirements set out there is subject to controls. All companies receive over 50 questions on the five above-mentioned key topics. 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.
With respect to measures and objectives in 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 on prevention and employees receive training in this area. Compliance with the guidelines is monitored as part of an annual survey at all Geberit Group companies (see the individual indicators for the results). The Internal Audit Department conducts additional on-site audits. In the event of misconduct, corrective measures are taken.
In the reporting year, there was a repeat of the Group-wide survey on the correct practice regarding donations. The survey showed that the giving of donations to business partners continues to be very moderate in nature. All managing directors gave explicit confirmation that no donations in the form of money, no donations to public officials and no donations in connection with ongoing projects were made. This was confirmed by the audits conducted internally.
G4-SO3 Analysis of business units for risks of corruption
According to the annual survey carried out at all Geberit Group companies, there were no cases of corruption in 2016.
The topic of corruption is also a component of the audit programme 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 2016, the Internal Audit Department audited a total of 20 companies. No cases of corruption were discovered in these audits.
G4-SO4 Training on anti-corruption policies
All new employees at Geberit are trained on the Code of Conduct as part of the Welcome events, with specific training films on the topics of corruption, IT misuse, workplace bullying and sexual harassment, deployed especially for this.
Employees throughout Geberit are also provided with information via the intranet about what is permitted and what is not. Supplementary guidelines for the prevention of corruption have been updated and made accessible to the relevant employees (Purchasing, Sales) via the various communication channels.
G4-SO5 Actions taken in response to incidents of corruption
No measures were necessary, as no cases of corruption were identified in 2016.
12.2 Anticompetitive Behavior (SO)
Management Approach – Anticompetitive Behavior
According to the Materiality analysis, the prevention of anti-competitive behaviour is a most material aspect. Cartels of any kind and other anti-competitive behaviour are categorically rejected.
The guidelines on antitrust legislation were updated and communicated in 2015 via the managing directors of all companies and the Geberit intranet.
A range of training events on antitrust legislation were held for the managing directors of the European sales companies on the one hand and members of the sales teams in Scandinavia on the other. The eLearning course on antitrust legislation was also repeated at the European sales companies.
G4-SO7 Anti-competitive behavior
One set of proceedings against Geberit from the previous year is pending at the Swedish competition authorities and Geberit is cooperating fully with the authorities. There was also one case of legal proceedings in Germany due to an alleged trademark infringement.
The appeal proceedings before the European Court of Justice initiated by the European Commission against a ruling by the European Court of first instance remain pending. These concern the known “bathroom antitrust proceedings” dating from 2010 that affected companies of the former Sanitec Group.
12.3 Compliance (SO)
Management Approach – Compliance
The Geberit Code of Conduct hält fest, dass Geberit alle Gesetze, Richtlinien sowie international anerkannte Normen und Standards befolgt. Dabei wird häufig sogar über die gesetzlichen Mindestanforderungen hinausgegangen.
Geberit deploys a comprehensive process for the implementation of the Code of Conduct and its review of compliance, see chapter Society.
G4-SO8 Sanctions due to non-compliance with regulations
Geberit incurred no fines or sanctions in 2016 resulting from violations of statutory requirements.