The Geberit Code of Conduct describes the basic principles that have to be met in order to be an exemplary, reliable and fair business partner and employer. The content of the Code of Conduct was updated in 2014 and implemented at Geberit – including the former Sanitec Group – in 2015.
In 2015, the Geberit Compass, a key compliance element, was updated. It describes the cornerstones of the corporate culture, namely the joint mission, the shared values, the operational principles and the success factors to be considered by all employees. This was presented and explained in the Group-wide employee magazine, which is published in six languages.
In order to guarantee compliance with the requirements of the Code of Conduct, Geberit has established an effective compliance system that focuses on compliance in the five following key topics: antitrust legislation, corruption, employee rights, product liability and environmental protection. In practice, the system comprises various elements such as guidelines, continuous training, job orientation for new employees, eLearning campaigns, info circulars, compliance-related audits and the Geberit Integrity Line, a whistleblower hotline for employees launched in 2013. A thorough review of the compliance organisation at the end of 2014 yielded a very satisfactory result. The Internal Audit department and external auditors concluded that responsibilities are clearly regulated within the various Group functions and the mechanisms are geared towards effectiveness. Once an assessment of the existing compliance structures had been completed, the Geberit Group’s Compliance Programme was also extended to the companies of the former Sanitec Group.
Anti-corruption, anti-competitive behaviour and statutory compliance requirements are particularly important aspects in the GRI category Society. Legal Services is responsible for their implementation.
As part of the annual reporting on the Code of Conduct for Employees, compliance with the requirements set out there is subject to binding controls. All companies – including the new companies from the former Sanitec Group – receive around 50 questions on the five above-mentioned topic areas. In addition, on-site audits are performed by the Internal Audit Department and corrective measures taken in the event of misconduct. The audits also comprise special interviews with the managing directors of the individual companies on the topics mentioned in the Code of Conduct. The respective information is verified. The findings from the survey and audits form the basis for the annual Compliance Report submitted to the Group Executive Board and are published in this Sustainability Performance Report.
With respect to measures and objectives in the Code of Conduct, see also Sustainability Strategy.
12.1 Anti-Corruption (SO)
Management Approach – Anti-Corruption
As a member of Transparency International Switzerland and the UN Global Compact, Geberit is committed to high standards in combating corruption. There are clear guidelines on prevention and employees receive training in this area. Compliance with the guidelines is monitored as part of an annual, binding survey at all Geberit Group companies (see the individual indicators for the results). Internal auditing is supplemented by on-site audits. In the event of misconduct, corrective measures are taken.
The guidelines on donations were updated and communicated in 2015 via the managing directors of all companies and the Geberit intranet.
G4-SO3 Analysis of business units for risks of corruption
According to the annual, binding survey carried out at all Geberit Group companies, there were no cases of corruption in 2015.
The topic of corruption is also a component of the audit programme for the periodic inspections of the production plants and sales companies by the Internal Audit Department. The annual audit planning of the Internal Audit Department is oriented to risks. Each company is audited at least every five years, or considerably more frequently if it has a heightened risk profile. In 2015, the Internal Audit Department audited a total of 18 companies. No cases of corruption were discovered in these audits.
G4-SO4 Training on anti-corruption policies
In 2008, more than 98% of employees were informed of and trained in the Geberit Code of Conduct. Since then, new employees joining the old Geberit have received training as part of Welcome events, with media such as training film s on the topics of corruption, IT misuse, workplace bullying and sexual harassment developed especially for this. The companies from the former Sanitec Group are gradually adopting the implementation of Welcome events and other measures.
Employees throughout Geberit, including the former Sanitec Group, are provided with information via the intranet about what is permitted and what is not. Supplementary guidelines for the prevention of corruption have been updated and made accessible to the relevant employees (Purchasing, Sales) via the various communication channels.
G4-SO5 Actions taken in response to incidents of corruption
No measures were necessary, as no cases of corruption were identified in 2015.
12.2 Anticompetitive Behavior (SO)
Management Approach – Anticompetitive Behavior
According to the Materiality analysis, the prevention of anti-competitive behaviour is a most material aspect. Cartels of any kind and other anti-competitive behavior are categorically rejected.
The guidelines on antitrust legislation were updated and communicated in 2015 via the managing directors of all companies and the Geberit intranet.
Ongoing training in antitrust legislation was continued in 2015. Training events geared specifically towards antitrust legislation matters were held in 2015 for the managing directors of the European sales companies and the sales employees in Germany. In order to reach a wider group of employees in this matter, an eLearning course on the subject of compliance in the sphere of antitrust legislation will be held in the first quarter of 2016. This will enable the eLearning approach already conducted successfully in previous years to be continued.
G4-SO7 Anti-competitive behavior
One accusation was lodged by a wholesaler at the Swedish competition authorities in the reporting year. The proceedings are still pending. There was also one case in Germany of unlawful comparative advertising, which resulted in a declaration to cease and desist issued to a competitor. The appeal proceedings before the European Court of Justice initiated by the European Commission against a ruling by the European Court of first instance remain pending. These concern the known “bathroom antitrust proceedings” dating from 2010 that affected companies of the former Sanitec Group.
12.3 Compliance (SO)
Management Approach – Compliance
The Geberit Code of Conduct requires Geberit to comply with all laws, directives and internationally recognized standards. The minimum statutory requirements are often exceeded here.
Geberit deploys a comprehensive process for the implementation of the Code of Conduct and its review of compliance, see chapter society.
G4-SO8 Sanctions due to non-compliance with regulations
Geberit incurred no fines in 2015 resulting from violations of statutory requirements, with the exception of the case cited under EN29.