Communication and education
Our core principles and directives are communicated to employees in several ways, including a comprehensive digital training program, classroom training and compliance communications. They serve to educate our employees and inspire them to apply high ethical standards.
Digital training
The Code of Conduct and Life-Saving Rules online training are mandatory for every employee. In the second half of 2018, we relaunched our Code of Conduct digital training as a refresher to all employees. Mandatory digital training is also provided to designated employees in the field of competition law, export control, bribery, privacy, fraud and information security.
In 2018, new online training was launched on bribery and privacy. The overall completion rate of online compliance training was at 71%, lower than previous years in light of the relaunch of the Code of Conduct, bribery and privacy training during the course of the year.
Classroom training
Classroom training is provided on a variety of topics, including general compliance awareness, the Code of Conduct, SpeakUp!, competition law, export control, privacy and discrimination and harassment.
Communication
The Compliance function issues com-pliance bulletins, spotlights and articles in company digital newsletters on a regular basis. For example, in 2018, we twice issued a company-wide alert on external fraud attempts, supported by a user-friendly animation which explained what to watch out for and what to do in case of attempted fraud. On several occasions, communications on competition law were also issued in support of our pricing acceleration actions, which informed employees about what they can and cannot do.
As with every year, in early December, a year-end integrity message was issued. Sent directly from the General Counsel, it reminded employees of our accounting rules and our rules on gifts and entertainment ahead of the holiday season.
Compliance portal
A comprehensive compliance web portal is available to employees containing guidance, templates and references on various compliance topics. In 2018, a new section was launched to help employees ensure privacy compliance when carrying out personal data processing activities. The portal contains step-by-step guidance and templates, including standard data processing agreements, terms and conditions for websites and cookie policies.
Our Code of Conduct defines our core principles and how we work. It incorporates fundamental principles on issues such as business integrity, labor relations, human rights, health, safety, environment and security and community involvement.