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. Our compliance program safeguards us against potential reputational, financial and legal damage resulting from non-compliance or unethical business conduct.
Compliance at HUBER+SUHNER is about living the company’s values and speaking up if we witness or suspect unethical behavior or any non-compliance with the Code of responsible business conduct. We follow various approaches in ensuring ethical business conduct.
Published in six languages, our Code of responsible business conduct 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 relationships with our organisation. In 2022, HUBER+SUHNER launched a Supplier code of conduct in line with the Code of responsible business conduct, which addresses more in depth required sustainability standards. The Supplier code of conduct is also published in six languages. For certain matters, specific guidelines with more detailed information and instructions have been issued. Aligned with the code’s principles and obligations, HUBER+SUHNER has established a group-wide compliance program, which specifies our policies and guidelines, procedures, and actions within a defined process to help prevent risks and detect potential violations.
Overall responsibility for implementation of the corporate compliance program has been assigned by the Board of Directors to the chief financial officer (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 with continuously improving the compliance program through a set of measurements such as:
The group compliance officer has the power to veto business transactions that jeopardise the Group’s reputation as a result of threatened or existing infringements of the Code of responsible business conduct. However, the final decision about execution lies with the CEO.
Twice annually, the group compliance officer meets with the area compliance officers who are responsible to ensure compliance within the Group. 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 management system of HUBER+SUHNER. The country managing director and line managers are required 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, the supply chain’s adherence to our standards is ensured.
An annual compliance report, which is part of the risk report, was 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 our internal and external grievance mechanisms, management reviews and internal quality audit reports.
In 2021, HUBER+SUHNER implemented an independent and secure whistleblowing 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. The whistleblowing platform can be accessed around the clock. It is available in several languages, and reports can be submitted anonymously. The company has developed guidelines encourage employees to voice their concerns about suspected misconduct within HUBER+SUHNER or in connection with the company’s business relationships with respect to the principles set out in the Code of responsible business conduct.
On a yearly basis, one compliance topic is defined according to its relevance and timeliness for an online compliance training. For office employees, topics like anti-bribery, conflict of interest, and non-competition are regularly addressed. Additionally, an online onboarding compliance training – developed specifically for HUBER+SUHNER – is available in seven languages and all employees working in office environments are asked 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 our manufacturing facilities have daily meetings with shift leaders where the topic of compliance in their sphere of influence is included on a regular basis.
Safeguarding our customers’ and employees’ data as well as data critical to our operations is a key concern for HUBER+SUHNER. We are taking decisive action to mitigate the risks of cyberattacks and proactively answer potential threats. In addition to training our employees, constant cyber security awareness monitoring allows us to understand our risk exposure and define follow-up actions where necessary. Our susceptibility rate to phishing simulations is significantly lower than the industry average.
HUBER+SUHNER commits to visible culture of integrity, ethics, and compliance which is built on our group-wide Code of responsible business conduct. Our compliance programme, which specifies the organisation’s policies and guidelines, procedures, and actions within a defined process, helps prevent risks and detect potential violations.
To continuously strengthen our corporate compliance programme and ensure continuous commitment from our employees, actions in 2023 included:
96.5 %
of office and indirect production employees globally completed the online compliance training on supply chain due diligence
1
case of violation of the Code of responsible business conduct
In 2023, one violation which substantiated was reported related to the Code of responsible business conduct via the whistleblowing platform. Employees and other stakeholders can also use other reporting channel or sources (immediate or next line manager, human resources manager, local compliance officer, or local external service provider) to raise any non-compliance issues.
To ensure an active culture of compliance, key actions for the year 2024 will include: