COMPLIANCE and ANTI-cORRUPTION
Our Company Charter and our Guideline on Corruption Prevention define in detail what we consider correct ethical business conduct, and clarify that we comply with law and order and do not tolerate corruption. These principles culminate in organisational measures that are valid and binding across the Company. In addition, we regularly train all employees involved in purchasing processes on the topics of procurement fundamentals, anti-corruption and compliance. In 2016, we conducted ten training seminars with a total of 115 employees; four seminars with another 48 employees are scheduled for 2017.
Since 2010, a guideline has been in effect in our organisation that regulates our whistle-blower system and stipulates the establishment of an internal Compliance Committee and an external ombudsman. The Compliance Committee consists of one member from the Legal department and one from the Human Resources department, as well as the compliance coordinator. Once per year, the ombudsman submits a written report to the Compliance Committee about any contacts and the number of leads received (more on this topic in the Annual Report in the chapter “Our corporate governance” on p. 38). In 2016, our ombudsman received one lead. The complaint, however, was not based on any circumstance concerning indications of corrupt conduct, violations of competition law or general unlawful conduct.
When the ombudsman relates a justified complaint to 50Hertz, the Compliance Committee is called in immediately to deal with the case and initiate further steps if necessary. The committee reports to the management of 50Hertz once per year and as warranted by specific occurrences. In 2016, the committee did not receive any pertinent complaints, so no investigations were conducted.
Our compliance record is also reflected in the fact that during the 2016 reporting period no significant fines connected to line construction projects or operation were legally imposed on 50Hertz.