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More Henkel Corporate Reporting 2015
Our Compliance organization has global responsibility for all preventive and reactive measures. It is supported by integrated management systems and an organizational structure with clearly defined responsibilities.
The Chief Compliance Officer reports directly to the Chairman of the Management Board. He is supported by the Corporate Compliance Office, our interdisciplinary Compliance & Risk Committee, and 50 locally appointed compliance officers all over the world. Our Corporate Data Protection Officer is also part of our Compliance organization. Together, this team coordinates the flow of information and helps our employees to implement our requirements locally – for example, through specially adapted training courses. The Chief Compliance Officer reports on any infringements, as well as the measures taken to deal with them, to the Management Board and the Audit Committee of the Supervisory Board on a regular basis.
Our internal reporting and complaints channels are also augmented by a compliance hotline, which was set up to enable employees to report infringements of our Code of Conduct, internal standards, or applicable laws. It is run by an independent external provider and is available in 76 countries.
Since we operate on a global scale, our employees find themselves in a variety of legal and value systems. Many of our employees work in countries where, according to surveys by organizations such as Transparency International, there is a greater risk of encountering corrupt practices. Even in such surroundings, the same applies to all employees without exception: Henkel strictly opposes infringement of laws and standards, and rejects all dishonest business practices. To impart clear rules of conduct to our employees, and especially to avoid any conflicts of interest in everyday work situations, we focus on regular training courses and communication measures. In 2015, we trained more than 12,000 employees around the world in face-to-face seminars on compliance topics.
Our managers play a key role in regard to compliance. Given their position within the company, they bear a special responsibility to set an example for their staff. For this reason, all of our 10,400 managers across the globe must participate twice a year in our mandatory Compliance eLearning program, which addresses many different compliance topics. The main emphasis in 2015 was on antitrust law and data security.
Improper conduct is never in Henkel’s interest. The Management Board and senior management circles at Henkel all subscribe to this fundamental principle. Improper conduct undermines fair competition and damages our trustworthiness and reputation. Our employees attach great importance to a correct and ethically impeccable business environment. We react forcefully to violations of laws, codes and standards. Where necessary, we initiate appropriate disciplinary measures. In 2015, 12 employees received written warnings, and 42 contracts were terminated as a result of conduct violating compliance rules.
Henkel’s compliance culture involves continuous monitoring and improvement of the compliance process. As a result, our global Compliance Management System was audited by external auditors in 2013 based on the IDW PS 980 auditing standard with respect to the appropriateness, implementation and effectiveness of the compliance processes in the areas of competition law and anticorruption. A complete description of the Compliance Management Systems in place at Henkel can be found on the internet.