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 Geberit Compass, a key compliance element 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, e-learning campaigns, info circulars, compliance-related audits, annual reporting on the Code of Conduct and the Geberit Integrity Line – a whistleblower hotline for employees. A separate Integrity Line has been available for suppliers since 2017.
As only very few companies work with agents, there is no significant risk exposure in this area. Nevertheless, a Code of Conduct for business partners was drawn up in 2016 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 in particular are material aspects in the GRI category Society. Corporate Legal department 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 the annual 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.
G4-SO3 Analysis of business units in terms of risks of corruption
According to the annual survey carried out at all Geberit Group companies, there were no cases of corruption in 2017.
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 high risk profile. In 2017, the Internal Audit Department audited a total of 23 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. Guidance on the correct handling of donations (i.e. anti-corruption guidelines) were updated in 2015 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 case of corruption was identified in 2017.
12.2 Anticompetitive Behaviour (SO)
Management Approach – Anticompetitive Behaviour
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 intranet.
E-learning courses represent an efficient way to train staff on antitrust legislation, an issue that is particularly sensitive for Geberit. In the reporting year, the sales companies outside Europe were trained on the topic of antitrust legislation using this mode of learning. The same topic was also taught to staff directly at the sales company in the UK by one of the Group’s antitrust legislation specialists.
G4-SO7 Anti-competitive behaviour
Proceedings against Geberit have been pending with the Swedish competition authorities since 2015. Geberit is cooperating fully with the authorities.
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.
12.3 Compliance (SO)
Management Approach – Compliance
The Code of Conduct ensures that Geberit complies with all laws, directives and internationally recognised standards. Often, the company even exceeds the minimum statutory requirements.
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
In 2017, fines were imposed on Geberit in two cases. In the first case, an employee who had been absent for a lengthy period of time had not been paid a visit by the company physician prior to reintegration in the workplace. In the second case, a threshold value in the waste water was exceeded, see G4-EN29.