Compliance and Anticorruption
In its corporate activity, 50Hertz complies with the law. We do not give corruption a chance. In our Company Charter as well as our internal policy for corruption prevention, we have specified what we consider to be ethically correct corporate conduct. We implement these principles as organisational measures. These apply company-wide and are binding for all employees as well as for the 50Hertz Board of Management.
In June 2017, the European Money Laundering Directive was adopted into national law. As 50Hertz does not conduct any cash operations, the introduction of risk management within the meaning of money laundering law was not necessary. However, we are expressly committed in this context to conscientious compliance with the general duty of care obligations. Therefore, our supplier manual includes reference criteria and these criteria are further specified for managers responsible for the different balancing zones. Contradictions in the legal registry entries have been corrected.
In order to minimise the risk of corruption, we regularly train all employees involved in the purchasing process on the basics of procurement, anticorruption and rule-compliant behaviour. Therefore, in 2017, five training courses involving a total of 55 workers took place across all business locations. 14 training courses have taken place since 2016 for 151 employees throughout the company across all locations. For 2018, three training courses for approximately 40 further participants are planned.
Since 2010, a directive has regulated our whistle-blower system and prescribes the establishment of an internal Compliance Committee and an external Ombudsman. The Compliance Committee consists of one member each from Legal and Human Resources as well as the Compliance Coordinator. Once a year, the Ombudsman reports to the committee in writing on his activities and informs of the number of notices received. If the Ombudsman forwards a substantiated notice of an offence to 50Hertz, the Compliance Committee is convened immediately. It addresses the respective case and if necessary initiates internal steps. The committee reports to the 50Hertz Board of Management once a year and as required.
In 2017, the Ombudsman did not receive any corruption notices. The Compliance Committee was convened anyway, as the committee became aware of a proposed contribution to the capital reserves of a foundation. An internal investigation was launched, during which a lack of clarity concerning the process was identified but no breach of a directive could be identified. In the reporting year 2017, no significant fines were legally imposed against 50Hertz in relation to the general business activities, line construction or grid operation. For the delimitation of administrative offences, the reporting threshold was set at EUR 25,000.