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. This protects our reputation and secures the basis for future business.
Why it matters
Our 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 the business community.
We aim to be a trusted global partner and believe 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, we are committed not only to avoiding bribery, extortion, and other forms of corruption, but to developing related policies and specific programs, both internally and within our supply chain.
dormakaba Code of Conduct & Directives
We set 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. 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 the 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 and supports internal communication of any related publications and topics, such as in the case of the Group Directive Antitrust. Functional owners of the directives must ensure appropriate communication and training for the respective addressees.
Group Compliance revised and published the Group Directive Antitrust and a new Group Directive Anti-corruption. The latter was published early in the financial year 2020/21. This directive sets Group-wide minimum standards for granting and accepting of benefits in the public and private business sectors, including documentation and approval requirements depending on certain thresholds, and the mandatory consideration of additional principles to prevent even the mere appearance of corruption. These include the principles of social adequacy, transparency, and separation. As part of the roll out program, the focus in the financial year 2020/21 was on internal communication and the global anti-corruption training initiative (see below section on increasing awareness).
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 their direct manager. Subsequently, the matter may be escalated to the local HR function, Group Legal, or Group Compliance.
We strive to create a culture where employees speak up and are encouraged to address concerns as outlined in the abovementioned 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 potential 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) that allows dormakaba employees and third parties (e.g., customers or suppliers) to submit notifications about potential violations of laws and threats to our reputation. The dormakaba whistleblowing tool is available globally 24/7 and is offered in various languages. Whistleblowers using the online tool receive a first response within 2–3 days and are provided with regular updates on their case, if a postbox allowing anonymous communication has been set up.
An overview of reports of misconduct and investigative activities is shared with the senior management, including in the annual Corporate Compliance Report, which is discussed with the Audit Committee in detail.
Additionally, the whistleblowing system was assessed compared to the effectiveness criteria for grievance mechanisms provided by the UN Guiding Principles on Business and Human Rights. The results of the assessment are found in the Human Rights Assessment chapter.
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 can make use of a top-down approach by mandating audits (either performed 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 helps avoid breaches of laws and negative financial impact to the company, and safeguards 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.
Our goal is to train every employee on our Code of Conduct (CoC). New employees receive and acknowledge the CoC upon hiring, and an eLearning module on its contents are regularly part of the onboarding package.
Since the publication of the Group directives on antitrust and anti-corruption, we have focused on dedicated training for management and employees of relevant functions.
The antitrust training includes a blended training concept consisting of an eLearning and (virtual) live trainings to increase internal awareness and knowledge on antitrust issues. The relevant target group (e.g., sales, procurement, general management) was identified and then assigned the eLearning module, which was made available in different languages. More than 1,200 employees worldwide have participated in the eLearning, of which 100 participated in the financial year 2020/21. In addition, virtual classroom trainings were conducted globally by Group Compliance in the financial year 2020/21, with participation of more than 60 employees across all segments and various Group functions.
As regards anti-corruption, Group Compliance again applied a training concept comprising a mix of eLearning and virtual live trainings. The target group includes management and employees from sales and procurement, among others. While the anti-corruption eLearning campaign is now well advanced with more than 3,100 participants, the live trainings have recently re-started wherever feasible and subject to the ongoing Covid-19 restrictions. By 30 June 2021, more than 80 employees had participated in a live training on anti-corruption and more will follow in the upcoming financial year.
The biggest milestones of Group Compliance’s work in the financial year 2020/21 include the publication of the Group Directive Anti-corruption, the launch of the corresponding training initiative, and the further development of the Compliance Organization, focusing on internal training, best practice sharing and further enhancing collaboration between Group Compliance and the Compliance Ambassadors of all segments. It was also the second year of implementation of the whistleblowing tool, which allows employees and third parties to disclose possible misconduct globally and anonymously. Awareness of the tool is promoted via several means, including through feature stories on our intranet.
Our whistleblowing tool is available in 9 languages for our internal and external stakeholders
Through all reporting channels, including the whistleblowing tool, 20 incidents have been reported and thereafter investigated in the financial year 2020/21. This is a slight increase of received reports of potential misconduct compared to the previous financial year (19). In around 50% of incidents reported, misconduct was confirmed, and appropriate corrective action has been taken. Two incidents remain under investigation as at 30 June 2021.
With operations in over 50 countries, it is vital that we comply 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 2020/21 known to us. There were also no confirmed incidents of corruption in the financial year 2020/21 known to us.
In the financial year 2021/22, dormakaba Group Compliance aims to continue its antitrust and anti-corruption trainings.