Compliance provides clarity
In the reporting year, there was a repeat of the Group-wide survey on correct practice regarding donations. The survey showed that the giving of donations to business partners continues to be very moderate in nature, normally taking the form of non-critical customer invitations to sporting or other events, as well as free material or tool consignments in connection with sales activities. Any local Geberit companies carrying out incentive programmes for their customers first consulted the legal department. All managing directors subsequently gave explicit confirmation that no donations were made to public officials or to business partners in connection with ongoing projects.
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. It was established that only a small number of companies work with agents and that there is no exposure to risk. An adapted code of conduct for agents – based on Geberit’s Code of Conduct – was nevertheless drawn up, with its contents communicated to agents accordingly.
Raising awareness through training and reporting
Geberit’s Code of Conduct, drawn up in 2008, and of which a new version has been available since the start of 2015, focuses on antitrust legislation and corruption – fields with their own dedicated guidelines which are accessible to relevant employees. 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. In addition, the sales employees of the European sales companies and members of the Group management again attended an eLearning course on antitrust legislation. A repeat of the antitrust legislation eLearning course is also planned for 2017 at the non-European sales companies, while supplementary face-to-face training will take place at more European sales companies. Furthermore, the theme of antitrust legislation will be integrated as a standard element in the internal audit team’s audit programme.
The Geberit Integrity Line, which was established in 2013 and has also been available to employees of the former Sanitec Group since 2015, recorded a number of cases during the reporting year that were subsequently investigated. One of these cases resulted in the discovery of shortcomings at a local company, which ultimately led to changes in personnel.