Compliance and integrity management

A compliance framework supported by implementation processes and monitoring and control procedures, based on a comprehensive Code of Conduct and assesed by the Supervisory Board, is one of the essential foundations of good corporate governance and social responsibility. In everything we do we aim for the highest standards of performance and behavior. Our conduct must be exemplary wherever we operate.

Compliance framework

Compliance framework (graphic)

AkzoNobel Code of Conduct

The Code of Conduct serves as a common reference document which reflects our values and sets out our fundamental principles and rules for doing business. The code applies equally to our corporate actions and the behavior of individual employees, regardless of the market segment, function or country in which we operate. The code is supported by a cascaded structure of internal regulations in the form of corporate directives, policies, practical manuals and guidelines that are applicable to all employees and guide them in their day-to-day decisions. The Code of Conduct is available in 27 languages, is regularly distributed in paper form and is widely available online.

AkzoNobel is subject to local, regional and international laws and regulations, regulatory controls and customs and practices in the countries in which we do business. Our legal and compliance experts are monitoring and adapting to significant and rapid changes in a wide range of legal and compliance areas, to ensure that the code and our internal regulations remain suited for purpose and are properly applied.

Code of Conduct for joint ventures, acquisitions and our supply chain

We have a task to ensure that all employees – including those at joint ventures we operate and at newly acquired companies – are aware of, and comply with, laws and regulations that are relevant to their specific role, as well as the Code of Conduct and related internal regulations. In those joint ventures we do not control, we encourage our partners to consistently apply the values and principles reflected in our code when doing business.

AkzoNobel expects employees of newly acquired companies to adhere to the Code of Conduct in their daily actions and to live up to our strategic values, our fundamental principles and rules for doing business. They receive extensive training which enables them to fully acquaint themselves with the compliance framework and the code.

The code also governs the behavior of our suppliers, agents, distributors, contractors and other trading partners with whom we work. This is directly reflected in what is called our Vendor Policy. This policy asserts that we want a sustainable supply chain and therefore do business with trading partners who comply with our integrity values and our social and environmental standards. Those partners are required to sign the AkzoNobel Vendor Policy Declaration, which is rooted in our Code of Conduct. In a gradual process of enhancing assurance that our business partners comply with our Vendor Policy, the socially responsible performance of our business partners will be verified to create a sustainable supplier base. See the Sustainability statements section.

Code of Conduct training, communication and awareness

We appreciate that raising awareness through effective communication and training is pivotal to our compliance framework, and assists us in protecting the company and our employees against economic and reputational harm. Communication on the Code of Conduct starts for new employees from the moment they join AkzoNobel and includes online and classroom training. By the end of 2012, we had invited all employees with access to our intranet to complete the Code of Conduct training module. Our employee completion rates (at 96 percent in 2012) are monitored monthly and form an element of the annual Performance and Development Dialog discussion. The compliance training curriculum also offers specialized training to improve critical competencies and skills to a designated group of employees on topics such as competition law, anti-bribery, export control, privacy, fraud awareness, anti-harassment, careful communications and trade secrets.

Code of Conduct complaints procedure (SpeakUp!)

We value an open dialog on integrity and responsibility in our actions with our employees worldwide. We investigate all alleged breaches of our code and apply appropriate measures when complaints turn out to be substantiated. Our employees are encouraged to report their views on processes and practices to their manager or the relevant business level compliance committee, the compliance department or the Compliance Committee. A global reporting helpline is permanently available to our employees to report, confidentially and, if so desired, anonymously, breaches of our Code of Conduct. These reporting mechanisms are part of the complaints procedure and are described in our SpeakUp! policy and manual. We seek to ensure that lessons learned from the SpeakUp! procedure are addressed in the form of case studies in our compliance training curriculum, to reflect as much as possible our day-to-day business reality.

In 2012, a total of 295 alleged breaches of the Code of Conduct were reported. Most of the cases related to business integrity and treatment of employees. Company-wide, we had 131 dismissals on grounds related to breaches of the Code of Conduct (2011: 99). The results are addressed in the non-financial letter of representation process (see later in this section). Although the issues reported were not material for AkzoNobel, we are conscious of the need to continue to conduct root cause analyses and take appropriate actions.

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