GRI 2-27 Compliance with laws and regulations
The Geberit Code of Conduct describes the basic principles that have to be met in order for Geberit to be an exemplary, reliable and fair business partner and employer. The Geberit Compass, a key compliance element, describes the cornerstones of the corporate culture, namely the joint mission, the shared values, the operational principles and the success factors to be considered by all employees. The Geberit Compass was presented and explained in the Group-wide employee magazine, which is published in six languages.
In terms of the environment, Geberit states in its Code of Conduct that it will limit the environmental impact of its business activities to a minimum. This calls for consistent compliance with all applicable laws, internationally recognised guidelines and industry standards. With many of the initiatives that it implements, Geberit goes above and beyond legal and official requirements. Reviewing and ensuring compliance with the law is a mandatory element of ISO 14001 (environment) certification; as of 2020, this process was simplified with the roll-out of a new EHS (environment, occupational health and safety) compliance tool in logistics and the production plants in Switzerland, Poland, Ukraine, Germany, Austria and Slovenia, see GRI 2-24.
In order to guarantee compliance with the requirements of the Code of Conduct, Geberit has established an effective compliance system that focuses on the following key topics (the respective department responsible is then detailed in brackets): antitrust legislation, corruption, data protection (Corporate Legal Services), product liability (Corporate Product Quality), fundamental employee rights (Corporate Human Resources) and environment, health and safety (Corporate Sustainability and Process Management). In practice, the system comprises various elements such as guidelines, continuous training, job orientation for new employees, eLearning campaigns, compliance-related audits, annual reporting on the Code of Conduct and the Geberit Integrity Line – a whistleblower hotline for employees. Since 2017, an Integrity Line has also been available to suppliers. The training concepts and tools were also developed further and training sessions further intensified in the reporting year. The focus remained unchanged on the topics of antitrust legislation and data protection.
As only very few sales companies work with agents, there is no significant risk exposure in this area. Nevertheless, a Code of Conduct for Business Partners was drawn up in 2016 based on the Geberit Code of Conduct and communicated to the agents by the managing directors of the local sales companies.
For further information on the topic of compliance, see Business Report > Business and financial review > Financial Year 2022 > Compliance.
As part of the annual reporting on the Code of Conduct for Employees, compliance with the requirements set out there is subject to controls. All companies receive over 60 questions on the above-mentioned key topics. In addition, on-site audits are performed by the Internal Audit Department and corrective measures taken in the event of misconduct. The audits also comprise special interviews with the managing directors of the individual companies on the topics mentioned in the Code of Conduct. The respective information is verified. The findings from the survey and audits form the basis for the annual Compliance Report submitted to the Board of Directors and the Group Executive Board, and are published in the annual report.
In 2021, KPMG also carried out a comprehensive external audit of the compliance organisation, focusing on antitrust legislation, corruption, sustainability, employee rights and product liability, with good results achieved overall.
In the reporting year, non-material fines were imposed on two companies – one for a minor infringement of occupational health and safety regulations and one for a minor infringement of environmental regulations. There were no non-monetary sanctions due to non-compliance with environmental laws and regulations.