ALTANA introduced a Compliance Management System (CMS) in 2008. A manager was assigned to each area. These compliance managers, together with the Head of Internal Audit, form a so-called Compliance Committee, chaired by ALTANA’s General Counsel, who in turn reports to the Chief Financial Officer. The Compliance Committee deals at the ALTANA AG level with various topics that are important for compliance.
Compliance-relevant topics at ALTANA
• Corruption and fraud
• Antitrust legislation
• Financial reporting
• Environment and safety
• Human resources (HR)
• Customs and foreign trade
• Data protection
• Information technology (IT)
The compliance organization helps avoid conflicts of interest. Internal audits are carried out to check whether the compliance guidelines have been adhered to. In 2012, the Compliance Committee formulated targets for the company’s compliance culture, risk assessment, and compliance program and improved the system. With its CMS, ALTANA also covers the topics of corruption, environment and safety, as well as discrimination, child labor, and collective agreements.
Basic elements of ALTANA’s Compliance Management System
Since 2002, a Code of Conduct has existed at ALTANA that sets binding standards for the conduct of all managers and employees groupwide. At the end of 2011 and beginning of 2012, around 650 of the employees who have joined ALTANA since 2010 in German- and English-speaking countries learned about the Code of Conduct and Compliance via e-learning. Starting in August 2012, 450 Chinese colleagues followed suit. The program is also planned for all employees in Italy. Furthermore, 1,100 employees have received training in antitrust matters through e-learning.
Additional training took place regarding the topic of corruption, e.g. during ELANTAS and ACTEGA management meetings. Issues such as active and passive corruption, granting of undue advantages, fraud, and antitrust law were discussed. Within the framework of ALTANA’s global procurement training, 70 purchasers received training in compliancerelated matters. BYK Korea introduced annual compliance control by the HR manager (internal) and auditors (external).
In addition to sensitizing employees, control is important. Within the framework of internal auditing, matters such as assigning contracts to third parties and commission agreements were audited. In 19 internal audits in 2012, some potential for improvement was identified, for which we took the appropriate organizational measures. No cases of corruption were registered via hotlines or other channels. In the periodical inquiry made in March /April 2012 in all companies, no compliance violations in the form of discrimination and child labor were registered. According to the estimates of local HR managers, adherence to legal and ALTANA specific rules and regulations is ensured everywhere. In regular visits to all sites, managerial staff also look into possible violations due to child labor, among other things.
Female employees at the Wesel site have established an ALTANA wide women’s network. By the end of 2012, possible goals and activities had been developed. The project is being sponsored by the company. In the future, the women’s network could deal with possible disadvantages encountered by women.