Fair competition & Anti-corruption11 min
By standing up to and rejecting anti-competitive behavior and corruption in all forms, we enhance the trust our stakeholders place in us while protecting our reputation and securing the basis for future business.
Why it matters
Read about how our Compliance team builds trust in an interview with our Compliance Officer, Michael Vorhold
The dormakaba mission is to make access in life smart and secure. This can only be realized if we work together and consistently apply a legal and ethical approach in all matters. Trust and credibility are built over many years but can be lost in a single moment. In particular, corruption and anti-competitive behavior are unfair business practices that destroy society’s trust in the economy and business community. By standing up to and rejecting anti-competitive behavior and corruption in all forms, we enhance the trust our stakeholders place in us while protecting our reputation and securing the basis for future business.
dormakaba aims to be a trusted global partner and believes our customers’ interests are best served by focusing on our company value “Customer First” and strict adherence to all applicable laws. Illegal business practices, such as corruption, subvert the rule of law and erode trust, while anti-competitive behavior distorts markets and produces inefficiencies. Therefore, we emphasize integrity, governance and responsible business practices, and regard fair competition as the soundest basis for our growth and corporate success. As a member of the UN Global Compact, dormakaba has committed to not only avoid bribery, extortion and other forms of corruption, but to develop related policies and specific programs, both internally and within our supply chain.
dormakaba Code of Conduct & Directives
dormakaba sets a clear tone from the top regarding compliance by providing guiding documents and training to all employees. Principles of antitrust regulations, anti-corruption and ethical business dealings, for example, are part of our Code of Conduct (CoC). The dormakaba CoC is binding for all our employees and management. It is each employee’s responsibility to comply with laws and internal regulations as per the CoC. The respective manager is responsible for ensuring that employees know regulations and understand expectations. In the course of the recruitment and onboarding process, new employees receive and acknowledge the dormakaba CoC.
Group Compliance publishes new Directives on compliance-relevant topics and manages internal communication of any related publications and topics. This includes, for example, personal e-mail distribution targeted to employees who may be affected by a new Directive.
Group Compliance revised and published the Group Directive Antitrust which came into effect during the financial year 2018/19. It replaced the previous Fair Competition Directive. The publication was accompanied by other internal communication initiatives and supports the global antitrust training initiative (see below section on increasing awareness).
A detailed Anti-Corruption Directive is in development, and upon approval it will be rolled out across the company through our various internal communication channels. It will be followed by customized training for impacted employees, which may include face-to-face trainings, webinars and eLearning sessions, or further supporting documents. The start of this initiative is scheduled for the financial year 2019/20.
Reporting misconduct & grievances
The CoC outlines the standard procedure for reporting grievances and/or breaches of law. As a first step, any employee should ideally contact his or her direct manager. Subsequently, the matter may be escalated to the local HR function, Group Legal or Group Compliance.
dormakaba strives to create a culture where employees speak up and are encouraged to address concerns as outlined in the above-mentioned process. On matters of transparency, the respective manager is encouraged to contact Group Compliance directly. Group Compliance carefully considers all notifications received and, depending on the matter, creates an action plan or sets up a project to solve any issues. The remediation progress is tracked by Group Compliance and may include direct legal advice, the involvement of external experts, internal investigations, or the development of workshops or customized training. If necessary, Group Legal and Group Compliance will involve the CEO and/or other relevant members of the Executive Committee.
Although employees are encouraged to speak up, potential whistleblowers may want to stay anonymous for various reasons. Group Compliance implemented an integrity line (whistleblowing tool) in the financial year 2018/19, allowing dormakaba employees and third parties (e.g. customers or suppliers) to submit notifications about potential violations of laws and threats to our reputation. The system has been successfully tested and went live in July 2019. The dormakaba whistleblowing tool is available globally 24/7 and is offered in various languages.
Identifying & addressing risks
Antitrust and corruption risks are identified top-down and bottom-up. Risks can be addressed in the company’s risk model as part of the global risk management process which is conducted every six months. Within our risk-evaluation process, the segments can address risks, including any perceived gaps within the internal organization and processes. Segment management can also address relevant issues to Group Internal Audit during regular audit planning and on an ad hoc basis. 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 and corruption matters. Triggers include hints from whistleblowers (received through anonymous letters, e-mails or further whistleblowing reports), from the organization itself, from impressions during on-site visits, external factors, or regional risk factors.
Regarding anti-corruption, Group Internal Audit integrates the Corruption Perceptions Index (CPI), an index developed by Transparency International as one criterion for developing its internal audit plan. Procurement and Sales functions, as well as processes, are regularly subjected to internal audits. In each standard audit engagement, Group Internal Audit verifies whether the principle of segregation of duties is maintained. Furthermore, risks are identified and addressed in the course of advising the business or in training sessions.
Increasing awareness through training activities
dormakaba aims to ensure compliance with applicable laws by strengthening awareness through employee training. Enabling employees to comply with legal requirements will help avoid breaches of laws, negative financial impact to the company and safeguard our reputation. Group Compliance develops training models and activities, e.g. on fair competition and anti-corruption. Group Compliance liaises with segment management about the training initiatives within their segments. The latter can then give feedback on the training strategy or indicate whether training content should be adjusted based on the local setting or local legislation.
dormakaba aims to train every employee on our Code of Conduct (CoC). In the financial year 2018/19, the CoC training initiative which began in the previous financial year was concluded, with each segment having at least 92% participation rates. As the basic rules of fair competition and anti-corruption are part of the CoC, almost all employees have been introduced to these general principles. Dedicated antitrust and anti-corruption training is provided to management and employees of relevant departments.
In the financial year 2018/19, training focused on the antitrust initiative. Group Compliance developed an antitrust training concept that included eLearning and live training workshops to increase internal awareness and knowledge. The relevant target group for antitrust training (e.g. Sales, Procurement, General Management) was identified and then assigned the eLearning module, which was made available in different languages. Following the completion of the module, participants were asked for feedback and to nominate other colleagues to participate in the eLearning. Around 70% of the participants provided feedback, which was used to customize the subsequent face-to-face training to each audience’s specific training needs.
In-depth anti-corruption and fraud training is offered upon request, however the global anti-corruption training initiative will be launched shortly, once the ongoing antitrust training initiative is completed. The target group will include management and employees from Sales and Procurement.
Milestones of Group Compliance’s work in the last financial year include the completion of the initial Code of Conduct training, the rollout of the global antitrust training initiative, and the implementation of the whistleblowing tool allowing employees to reveal misconduct globally and anonymously, which was launched in July 2019.
With operations in over 50 countries, it is vital that dormakaba complies with all applicable laws and regulations at the local, national and international level. Compliance with laws and regulations is a key factor for the sustainability of our business. We confirm that there were no legal actions pending or completed for anti-competitive behavior in the financial year 2018/19. There were also no confirmed incidents of corruption in the financial year 2018/19.
In the financial year 2019/20, dormakaba Group Compliance aims to complete the ongoing antitrust training initiative, including through live training sessions. Group Compliance will continue to coordinate legal advice on antitrust and monitor the topic globally. In addition, Group Compliance intends to launch the global anti-corruption training initiative, thereby comprehensively addressing our two most prominent compliance topics.
An interview with Michael Vorhold, dormakaba Compliance Officer
dormakaba aims to be the trusted industry leader. What is your personal experience with the company’s promise to build brand value and trust?
In my experience, dormakaba is a company in which colleagues listen to each other and value the opinion of others. To talk openly to each other is – in my opinion – a question of mutual trust. Trust in this sense means working in a collaborative environment, in which the voices of all relevant stakeholders are taken into account. It also includes the opportunity to address potential compliance issues to my team directly or using our integrity line, i.e. whistleblowing tool.
What are the biggest challenges in your area right now?
We earn trust by doing what we say. This, of course, also includes complying with legal requirements, acting according to our values and following our internal rules and regulations. Unfortunately, we sometimes fail to act in compliance with those rules. Often this is not done with bad intentions but merely due to unawareness. It is a big challenge for us to publish our internal rules and regulations to targeted addressees, and to offer customized workshops and training, in order to raise the knowledge and awareness level of our colleagues.
How are you addressing these challenges?
My team is working closely with the owners of Directives and Group Communications to announce all the new internal rules and regulations. We are considering the best roll-out strategy and also planning additional initiatives for the next financial year. When offering workshops and training, my team pays attention to identifying the right focus areas and presenting the information in a “non-legal” manner, in other words: we aim to talk the language of our clients. We foster open discussions and offer practical advice subsequent to the workshops.