Annual Report 2022

Compliance and business ethics

Compliance is a fundamental prerequisite for value-driven and ethical business conduct. This applies to both the workplace and when doing business.

As a global player exposed to numerous potential risks, HUBER+SUHNER seeks to promote a visible culture of integrity, ethics and compliance which is built on the HUBER+SUHNER group-wide Code of responsible business conduct[1]. The Code lays out important principles on how we conduct our business in a responsible manner and is the guiding document for every employee of the HUBER+SUHNER Group as well as for all stakeholders which enter into a relationship with our organisation. For certain matters, specific guidelines with more detailed information and instruction have been issued. According to the Code’s principles and obligations, HUBER+SUHNER has established a groupwide compliance programme, which specifies the organisation’s policies and guidelines, procedures, and actions within a defined process to help prevent risks and detect potential violations.

Governance of compliance within HUBER+SUHNER

The overall responsibility for the implementation of the corporate compliance programme has been assigned by the Board of Directors to the CFO, who in this function vests the position of Group Compliance Officer.

The Group Compliance Officer with the support of the General Counsel is tasked to continuously improve the compliance programme through a set of measurements such as:

The Group Compliance Officer has the power to veto business transactions that may put the Group’s reputation at risk as a result of threatened or existing infringements of the Code of responsible business conduct. The final decision about execution however lies with the CEO.

Area Compliance Officers and country managing directors

Twice per year, the Group Compliance Officer meets with the eight Area Compliance Officers who are responsible to ensure compliance within the Group, as well as with the Global Head of Corporate Responsibility to discuss about the following overarching topics:

The Area Compliance Officers make sure that a top down implementation of control measures is guaranteed by Country Managing Directors and line managers, and is reflected in the HUBER+SUHNER management system. On country level, compliance functions may be established, however, the country managing director is responsible for compliance matters towards local authorities.

The Country Managing Director and line managers have to inform Area Compliance Officers about any suspected or actual non-compliance or emerging topics for assessment and subsequent actions. Through close cooperation with the Global Head of Procurement, it is ensured that the supply chain is equally adhering to our standards. In 2022, HUBER+SUHNER launched a Supplier Code of Conduct in six languages which needs to be signed by every HUBER+SUHNER supplier.

Annual compliance report

An annual compliance report, which is part of the risk report, is being submitted to the Group Compliance Officer for presentation to the Board of Directors in December. The report includes the bottom-up information provided by the Area Compliance Officers, the findings of the other reporting tools such as the Trustline, management reviews, internal quality audit reports and an annual summary on customer audit findings.

Compliance training for employees

Compliance at HUBER+SUHNER is about living the company’s values and speaking up when witnessing unethical behaviour or any non-compliance with the Code of responsible business conduct. An online compliance training – developed specifically for HUBER+SUHNER – is available in seven languages and all employees working in an office environment are requested to complete the interactive online course within the first 90 days of their employment with the company as part of their orientation training programme. Employees working at HUBER+SUHNER manufacturing facilities have daily meetings with shift leaders where the topic of compliance in their sphere of influence is included on a regular basis.

On a yearly basis, one compliance topic is defined according to its relevance and timeliness. For office employees topics like anti-bribery, conflict of interest and non-competition are regularly addressed in intervals. In 2022, all our office staff as well as employees from production with access to desktop/laptops underwent a thorough training on data protection, making sure everyone understands what it means to keep personal data of employees, customers and suppliers safe. Data protection is an important aspect of our compliance policy, 96.9 % of our office and indirect production employees completed the training successfully.

Uncovering ethical disparities with our whistle-blowing platform Trustline

In 2021, HUBER+SUHNER implemented Trustline, an independent and secure whistle-blowing platform, provided by a third party. The platform offers all employees worldwide, including temporary staff, apprentices and trainees, an additional reporting channel to easily raise alleged violations or breaches of the Code of responsible business conduct by phone or in writing. Trustline can be accessed around the clock. It is available in several languages, and reports can be submitted anonymously. With Trustline, the company has developed guidelines for employees to encourage them to voice their concerns about suspected misconduct within HUBER+SUHNER or in connection with HUBER+SUHNER business relationships with respect to the principles set out in the Code of responsible business conduct.

To address reported issues, HUBER+SUHNER has a SpeakUp Steering Committee, composed of two Area Compliance Officers (Legal compliance, Human rights and labour) and the Head of Global Corporate Responsibility. It is responsible to handle any complaints that are reported via the HUBER+SUHNER Trustline. The Committee is the body towards the independent operator of the platform as well as the person who filed the complaint.

Reported issues in 2022

In 2022, no violations were reported related to the Code of responsible business conduct via the whistle-blowing platform or any other reporting channel or sources (immediate or next line manager, human resources manager, local compliance officer, or local external service provider). 

Product compliance

The purpose of the product compliance team is to ensure that HUBER+SUHNER operates in compliance with all relevant legislation and regulations related to materials used in our products. Establishing a global HUBER+SUHNER product compliance culture is critical to achieve this goal, and we foster this culture through a variety of means.

One key aspect of our material compliance efforts is the creation of a dedicated product compliance team. Its responsibilities include coordinating and overseeing all material-compliance activities at HUBER+SUHNER, including:

We plan to work closely with our suppliers and other stakeholders to ensure that all materials used in our products meet the highest compliance standards. This involves regular assessments of our supply chain, the implementation of processes to monitor and track compliance, as well as to work with external experts to ensure that we are always up to date on the latest material-compliance developments.

Overall, our vision for the product compliance team is to create a strong, proactive, and globally focused organisation that is dedicated to ensuring that HUBER+SUHNER is at all times in compliance with relevant material-compliance regulations and standards. By working together and leveraging all stakeholders’ expertise, we will be able to achieve this vision and create a culture of compliance that will benefit our company and our customers for today and in the future.

Managing product compliance

At HUBER+SUHNER, we take material compliance seriously and have implemented a number of initiatives to ensure that our products meet all applicable regulations and standards. This includes a robust system to manage compliance with registration, evaluation, authorization, and restriction of chemicals (REACH), restriction of hazardous substances (RoHS), and waste electrical and electronic equipment (WEEE) regulations.

To comply with REACH, we closely monitor the substances used in our products and conduct regular assessments to ensure that they are safe and do not pose any risks to human health or the environment. We also maintain detailed documentation on the materials used in our products and their potential impacts, and we work closely with our suppliers to meet REACH requirements.

In terms of RoHS compliance, we are committed to reducing the use of hazardous substances in our products and have implemented a number of initiatives such as replacing hazardous substances with safer alternatives whenever possible and conducting regular assessments of our products. We also maintain a database of all materials used in our products and their RoHS compliance status, and cooperate with our suppliers to ensure that all materials meet these standards.

With regard to WEEE compliance, we have implemented a number of measures to ensure that our products are properly recycled and disposed of at the end of their life cycles. These measures include working with certified recycling partners, providing clear and accurate labelling on our products to facilitate their proper disposal, and establishing internal processes to track and monitor our compliance with WEEE regulations.

HUBER+SUHNER is committed to upholding the highest standards of material compliance and meeting all applicable regulations and standards.

A global team looking after product compliance

HUBER+SUHNER has had a product compliance officer since 2022, and has established a dedicated, global, cross-functional team. Further, we have a team of material compliance master data specialists in India who are specialised in the topic.

Special substances of very high concern

The company adheres to requirements for substances as outlined in REACH Article 33: Duty to communicate information on substances in articles, including the need to disclose the presence of substances of very high concern (SVHC) above 0.1 % weight by weight (w/w). We are committed to transparency and disclose materials and substances used in our products upon customer requests.

HUBER+SUHNER declares that all of our products are compliant with the substance restrictions of EU Directive 2011/65/EU for RoHS, including the amendment under Commission Delegate Directive (EU) 2015/863. This declaration is based on the best of our current knowledge and on the current law at the date of issue.

Working towards lead-free products

Last year, our company launched an internal development project with the aim of building the necessary engineering and manufacturing skills for lead-free products in response to potential changes in EU RoHS legislation. The directive imposes restrictions on the use of certain hazardous substances, including lead, in the electronic and electrical equipment manufacturing process. While the directive currently allows for some exemptions, there is a possibility that lead will be completely banned in the future. In anticipation of this possibility, we have allocated resources to investigate whether the transition to lead-free radio frequency products is possible and economically viable.

[1] https://www.hubersuhner.com/en/company/sustainability/related-documents
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