Our Group-wide Compliance Program aims to ensure adherence to legal regulations and the company’s internal guidelines. The foundations of this program are our value “We strictly adhere to our compliance standards” and the globally established Codes of Conduct, which provide the content framework and show employees possible courses of action in doubtful cases.
Our efforts are principally aimed at preventing violations from the outset. To this end, all employees are required within a prescribed timeframe to take part in basic compliance training, refresher courses and special courses dealing with, for example, antitrust law or trade control regulations. In 2011, more than 73,000 employees worldwide took part in around 78,500 hours of compliance training.
BASF’s Chief Compliance Officer (CCO) manages the implementation of the program, supported by around 100 Compliance Managers worldwide. The CCO regularly reports to the Board of Executive Directors on progress in the program’s implementation as well as on any significant findings; furthermore, the CCO reports to the Supervisory Board’s Audit Committee in at least one of its meetings each year on the status of the Compliance Program as well as any major developments. In the event of significant incidents, the Audit Committee is immediately informed by the Board of Executive Directors.
BASF’s Corporate Audit department monitors adherence to compliance principles. In 2011, 75 Group-wide audits of this kind were performed (2010: 48).
If violations occur despite preventive measures, we aim to investigate and rectify these as quickly as possible. In 2011, 264 calls and emails were received by our 47 external hotlines worldwide. These related to topics ranging from questions about personnel management to the handling of company property and information on the behavior of business partners. We launch an investigation into all cases of suspected misconduct that we become aware of. Confirmed violations are penalized and can lead to dismissal.
In 2011, we continued the evaluation of our suppliers. We also expanded the checklist-based evaluation of other business partners, in particular agents, distributors and contractors.
Outside of our company as well, we support the fight against corruption and the respect of human rights. We are a member of the U.N. Global Compact as well as Transparency International Deutschland, and are active in the Partnering Against Corruption Initiative (PACI) of the World Economic Forum in Davos, Switzerland. We actively support the implementation of these organizations’ objectives.
As a result of the positive experience with the compliance survey carried out in BASF SE in 2010, we have decided to add this topic to our global employee survey in 2012 in order to gain more information that will help to improve our compliance standards and adherence to them.