Compliance governance

Corporate Compliance Committee

The Corporate Compliance Committee supports the Executive Committee in establishing, monitoring and assessing the company’s Compliance Framework and with its responsibility to report to the Audit Committee of the Supervisory Board. The Corporate Compliance Committee consists of the General Counsel (chair), the Directors of Compliance, Internal Audit, Control, Human Resources and Sustainability and Health, Safety, Environment, as well as the Corporate Secretary.

Compliance organization

Compliance and integrity management – Compliance organization (graphic)Compliance and integrity management – Compliance organization (graphic)

Compliance function

The Compliance function manages the Compliance Framework on behalf of the Corporate Compliance Committee. It makes the and directives available, manages the compliance education program, develops and communicates rules and procedures necessary to implement compliance programs and manages and supervises investigations of compliance incidents. The Compliance function reports on compliance risks and trends, on compliance breaches and on progress in compliance programs to the Executive Committee and the Audit Committee of the Supervisory Board. Legal experts provide advice in key compliance areas, monitor developments in laws and regulations and drive change to ensure that our rules and Compliance Framework remain up to standard and are suitable for purpose.

Compliance Committees and Compliance Officers

Business and functional management is responsible and accountable for raising awareness of laws and regulations that apply to their operations and for ensuring compliance with the same. Each business and function has a Compliance Committee and a Compliance Officer. The Compliance Officers are responsible for managing the compliance programs and processes in their business or function. They are responsible for ensuring that employees are trained and for managing and reporting on any compliance incidents. The Compliance Committees, chaired by the Managing Directors of the businesses and the leaders of the functions, each meet quarterly to decide on and review progress on compliance matters.

Sensitive Country Committee

The Sensitive Country Committee, consisting of the General Counsel (chair), an Executive Committee member with business responsibility and the Director of Compliance, reviews countries with risks relating to export controls, corruption, human rights, safety and security and finance transactions and makes proposals on such matters to the Executive Committee.

Privacy Committee

In 2015, a Privacy Committee was established, which consists of the members of the Corporate Compliance Committee, along with representatives from Sales, Information Management and Legal. The Privacy Committee is responsible for creating and maintaining the privacy framework and is chaired by the Director of Compliance.

Code of Conduct

Our Code of Conduct defines our core principles and how we work. It incorporates fundamental principles on issues such as business integrity, labor relations, health, safety, environment and security and community involvement.