As a global business, dormakaba is committed to acting as a socially responsible corporate citizen and to upholding the principles of and adherence to international conventions, laws and internal rules and regulations.
As a member of the UN Global Compact, dormakaba has committed itself to not only avoid bribery, extortion and other forms of corruption but also to develop related policies and concrete programs internally and within its supply chain.
As for any company with global operations, the relevance of a sound management approach on the topic is clear. The so-called Corruption Perceptions Index (CPI), an index developed by Transparency International that ranks the perceived level of public sector corruption, is high in some countries where dormakaba is active.
Through our management approach, dormakaba ensures compliance with the law and with our Code of Conduct by raising awareness through employee trainings and offering legal support and guidance. Enabling employees to comply with legal requirements will help avoid negative financial impact on the company and safeguard our reputation.
dormakaba sets a clear tone from the top regarding anti-corruption and ethical business dealings through our Code of Conduct (CoC). The CoC is binding for all dormakaba employees. Even if a national law would allow a practice forbidden by the dormakaba Code of Conduct, employees must comply with the CoC.
Anti-corruption is included in chapters 1 (Compliance with Laws and Regulations), 5 (Conflict of Interests), 9 (Protection against Corruption and Bribery) and 10 (Donating and Sponsoring) of the CoC. A more detailed Anti-Corruption Directive will be developed in the 2018/19 financial year.
No kind of corruption is tolerated. All illegal benefits to third parties directly or indirectly, whether public authorities or in the private business sector, are forbidden. The same applies regarding receiving such benefits. Facilitation payments are forbidden.
dormakaba's Group Compliance releases new Directives and further respective internal communication. This includes personal email-distribution targeted to the employees who might be affected by the Directive. In the case of the Group Directive Anti-corruption, a communication to all employees is planned. Guidance on how to use the Group Directive including additional supporting documents, e-learning, webinars of face-to-face training is offered.
A word on our Code of Conduct
The company’s values are included in the dormakaba Code of Conduct (CoC), which sets standards for ethical business behavior covering human rights, forced, compulsory and child labor, and environmental responsibility. The CoC also governs other areas such as equal opportunities and non-discrimination, and how to report misconduct.
The CoC is available to employees in various languages, both in electronic form and as printed document. All new employees receive the CoC with their employment contract. In addition, a user-friendly interactive PDF version of the CoC with additional information is available in various languages on the company’s intranet.
To raise awareness of the topic, Group Compliance, part of the Group Legal organization, develops the related training concept and provides the training material. Segments may amend as necessary after consultation. Group Compliance is supported by over 50 so-called Compliance Ambassadors throughout the whole organization.
Incidences of suspected corruption are reported to Group Compliance. Then, Group Compliance, in collaboration with Group Internal Audit, reviews the facts and circumstances. Based on the results of the review, Group Compliance derives countermeasures in collaboration with management and defines an action plan. Group Compliance then tracks the progress. The General Counsel regularly reports to the Board of Directors regarding corruption proceedings.
Besides this bottom-up approach, the Audit Committee makes use of a top-down approach by mandating audits (either by Group Internal Audit or through third-party support) with a focus on bribery or corruption matters. Triggers include hints from the organization itself, their impressions during on-site visits, whistleblowers, (bad) news from competitors, or regional risk factors.
In addition, Group Internal Audit integrates the CPI as one criterion for developing their internal audit plan. Procurement and sales functions and processes are regularly audited. In each audit engagement, Group Internal Audit verifies whether the principle of segregation of duties is maintained.
Corruption risks are also addressed in dormakaba’s risk model as part of the company’s global risk management process, conducted every six months.
Beyond the four-eyes principle
At dormakaba there are clear and structured processes which ensure transparency and minimize the likelihood of corruption. The company follows the four-eyes principle in decision making processes, meaning important decisions or critical activities are not made by one person alone. For example, besides adhering to the company-wide four-eyes principle, the purchasing department must obtain at least three offers for larger bids.
Possible conflicts of interest must be reported to the supervisor, Human Resources or Group Compliance. The situation must be resolved in the best interest of the organization based on a consultation between the employee, the supervisor, and Human Resources. The consultation must be documented and related summary minutes provided to Group Compliance.
Further, employees are made aware of the approval process for granting or receiving benefits during the Code of Conduct training. From a certain threshold onwards, the employee must ask his or her direct manager for approval. If benefits exceed a higher threshold, Group Compliance must give approval. Group Compliance processes, documents, and files such requests. These are reported to the Audit Committee on an aggregated basis.
In addition, donations and sponsoring totaling more than CHF 1,000 per recipient per fiscal year must be reported to Group Compliance. Group Compliance evaluates the data received and follows up on any conspicuous activities. These and other activities are reported to the Audit Committee, CEO, and CFO in the annual Corporate Compliance Report.
dormakaba ensures key activities on the topic through three working streams: (1) increasing awareness through training activities, (2) advisory services and (3) audits.
As mentioned, Group Compliance develops training concepts and activities. However, the responsibility for carrying out the training lies within the Segments through Compliance Ambassadors and in collaboration with Human Resources. This cross-functional and cross-departmental method further fosters the exchange of information on anti-corruption.
As part of the CoC training in the reported fiscal year, over 80% of all dormakaba employees were taught about the general anti-corruption processes including how to deal with conflicts of interest, how to seek approval for benefits, etc. Training for the remaining employees will take place in the financial year 2018/19.
An awareness-raising video on the topic was also released in the financial year 2017/18. To ensure that all employees understand the context and to minimize reservations on the topic, Group Compliance created a 5-minute animated film to explain anti-corruption. The film was published on the intranet and is used by all CoC trainers.
In-depth anti-corruption/fraud training is offered upon request. The systematic roll-out of further anti-corruption training is planned after concluding current training initiatives on the CoC and anti-competitive behavior, at the end of the financial year 2018/19. Refresher courses and special topic courses are planned subsequently.
Group Compliance together with Group Legal offers direct anti-corruption consultancy whenever due diligence processes reveal related issues. External legal expertise can be retained if necessary. Consultancy is offered on strategic projects but also occurs ad hoc. Duration of the actions depends on the related project or request. Actions are prioritized depending on the impact on dormakaba and urgency.
Group Internal Audit has performed two audits with a focus on anti-corruption and anti-bribery in the financial year 2017/18. The audits did not reveal any misconduct.
The CoC outlines the standard procedure for reporting grievances and/or breaches of the law. In a first step, the employee may contact their respective manager. Subsequently the matter may be escalated to the local human resources or legal team, Group Legal or Group Compliance.
On topics related to our Transparency focus area, the most likely path would be for the respective manager to contact Group Compliance directly. dormakaba strives to create a culture where employees speak up and are encouraged to address concerns as outlined in the above-mentioned process.
Group Compliance will carefully consider all notifications received and, depending on the matter, will create an action plan or set up a project to solve any issue. This might include but is not limited to direct legal advice, involving external experts, investigations, or developing workshops or tailored trainings. Depending on the assumed effect of the actions planned, Group Legal and Group Compliance will involve the CEO and/or relevant members of the Executive Committee.
Evaluation of the effectiveness of the management approach takes place, for example, when Segment management gives feedback or states concerns in case they think the anti-corruption training strategy or content needs adjustments based on the local setting, or challenge proposed budget allocations.
Further, within the company’s risk-evaluation process, the Segments can address risks, including any perceived gaps within internal organization and processes. In addition, Segment management can address related issues to Group Internal Audit within the regular audit planning and on an ad hoc basis.
Finally, the progress and the maturity grade of the Compliance Management System (CMS) are reported to the Audit Committee. The Audit Committee (including the CEO) provide feedback to the dormakaba CMS as necessary, taking into consideration their knowledge of related actions by other Swiss stock-listed companies.
There have been no major adjustments to the management approach in the financial year 2017/18.