"Our professional compliance management system helps us to mitigate the risks associated with global business."
In the wake of some major business scandals, compliance has become increasingly important over recent years, regardless of the sector. Have you observed this trend at ElringKlinger?
Definitely. After all, success in business is based on all involved parties conducting themselves with integrity and responsibility. Even an aberration by one individual can have grave and far-reaching consequences for the entire company. Therefore, compliance, by which we mean the observance of laws, legislation, and internal guidelines, is a joint corporate task to which our Group has devoted more and more attention over recent years.
What is needed to ensure good compliance?
The significance and the importance of conduct in line with the rules must be fundamentally clear to all employees – and most importantly of all, adherence to regulations must be a firmly established part of the way we work from day to day. This presupposes a healthy degree of regulation, since not every situation can be regulated. With this in mind, our company provides employees with a framework in which they can act responsibly. The framework is designed to guide them so that they can ultimately make correct decisions in difficult situations. Within the ElringKlinger Group, the Code of Conduct provides the benchmark for the actions and behavior of all employees. It defines core principles as regards corruption, conflicts of interest, gifts and other benefits, (travel) expenses, data protection, discrimination, occupational health and safety, and environmental protection. It also promotes competition and deals with the handling of insider knowledge. These principles are substantiated by other directives, such as our anti-corruption and antitrust guidelines. All managers are required to make every effort to support their staff, take note of suggestions, clarify specific questions regarding the Code of Conduct, and introduce measures as necessary. Needless to say, our compliance officers and I are very happy to assist.
What preventive steps are you taking to avoid compliance violations?
Compliance training sessions are a key tool in prevention. They raise the awareness of employees as regards specific aspects of the relevant internal regulations and legal provisions. The main target groups for our compliance training courses are managerial staff and those faced with certain compliance risks in their roles – for example, in the areas of purchasing and sales. In addition, all employees with PC access in the Group must attend mandatory training on the content of the Code of Conduct. In this case, we make use of web-based training. Elsewhere, we have expanded our compliance presence on the internet. All relevant content has been grouped in a separate compliance section, with general corporate principles expanded to incorporate the aforementioned guidelines on anti-corruption and antitrust law. In parallel to the internet, we have overhauled our internal communications platform in the area of compliance, with useful new content added.
How are you preparing for the EU directive on protecting whistleblowers, with legislation expected to come into force in Germany at the end of 2022?
We are already meeting our legal obligations in this area, with our own digital whistleblower system now active. The “share with us” system enables staff members to submit compliance breaches directly to our compliance department using a predefined online form. Reports can be submitted in complete anonymity, without revealing the identity of the whistleblower.
By facilitating the reporting, investigation, and resolution of misconduct, violations of the law, and infringements of rules, the system can avert disadvantages for the company, our employees, and business partners as well as the general public. Metaphorically speaking, the whistleblower system works like a fire alarm – it is not normally needed, but when a fire breaks out, it can save lives. Potential breaches of compliance can also be reported to the compliance organization in other ways – directly or via managers. While we realize you can never eliminate risks entirely, we hope our professional compliance management system will reduce them to a minimum.
Thank you for the interview.