Compliance training
|
|
2020 |
|
2021 |
|
2022 |
|
2023 |
|
2023 |
||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Total number of persons trained on |
|
28,827 |
|
5,790 |
|
5,082 |
|
6,688 |
|
486 |
||||||||
Total number of employees trained on anti-corruption guidelines |
|
28,805 |
|
5,772 |
|
5,071 |
|
6,671 |
|
486 |
||||||||
% of employees trained on anti-corruption |
|
50 |
|
10 |
|
8 |
|
11 |
|
12 |
||||||||
by employee category3 |
|
|
|
|
|
|
|
|
|
|
||||||||
Number of Role 2+ employees trained on anti-corruption |
|
27,123 |
|
5,284 |
|
4,658 |
|
6,325 |
|
463 |
||||||||
% of Role 2+ employees trained on anti-corruption |
|
90 |
|
17 |
|
14 |
|
18 |
|
18 |
||||||||
% of employees below Role 2 trained on anti-corruption |
|
6 |
|
2 |
|
1 |
|
1 |
|
2 |
||||||||
by region (%) |
|
|
|
|
|
|
|
|
|
|
||||||||
Europe |
|
51 |
|
8 |
|
7 |
|
10 |
|
2 |
||||||||
North America |
|
45 |
|
11 |
|
8 |
|
8 |
|
not applicable |
||||||||
Asia-Pacific (APAC) |
|
44 |
|
12 |
|
9 |
|
14 |
|
not applicable |
||||||||
Latin America |
|
44 |
|
8 |
|
7 |
|
13 |
|
not applicable |
||||||||
Middle East and Africa (MEA) |
|
66 |
|
12 |
|
9 |
|
16 |
|
not applicable |
||||||||
|
||||||||||||||||||
The (employee) target audience for a specific training is related to the risk level associated with employee positions and Role levels. Target audiences therefore may not include all Group employees and also may vary from training to training.
In order to address the special responsibility held by management personnel, and staff with HR responsibility, trainings on anti-corruption guidelines for these employees are in focus. This applies to all employees rated Role 2+.
At the beginning of 2020, the old e-learning course on anti-corruption was rolled out for a broad target group. The majority of this target group already completed the e-learning in 2020. The number of employees trained is comparatively lower in 2021 and 2022, as the training was only assigned to new joiners, internal transfers or employees who did not yet complete the e-learning. In 2023, we record an increase again as we replaced the former e-learning course with a new one in November. In addition to anti-corruption, the new training also covers the topic of money laundering.
Internal audits on corruption
|
|
2020 |
|
2021 |
|
2022 |
|
2023 |
|
2023 |
||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Number of audits relating to corruption |
|
52 |
|
56 |
|
55 |
|
53 |
|
17 |
||||
% of audits relating to corruption |
|
66 |
|
67 |
|
70 |
|
66 |
|
21 |
||||
|
||||||||||||||
Human rights violations
|
|
2020 |
|
2021 |
|
2022 |
|
2023 |
||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|
Number of reported violations of Social and Labor Standards Policy |
|
108 |
|
121 |
|
136 |
|
184 |
||||
Number of confirmed violations of Social and Labor Standards Policy |
|
29 |
|
41 |
|
68 |
|
60 |
||||
thereof number of incidents of discrimination |
|
2 |
|
6 |
|
7 |
|
71 |
||||
|
||||||||||||
Reported compliance violations
|
|
2020 |
|
2021 |
|
2022 |
|
2023 |
|
2023 |
|---|---|---|---|---|---|---|---|---|---|---|
Total number of reported compliance violations |
|
|
|
|
|
|
|
|
|
|
Number of reported compliance incidents |
|
81 |
|
79 |
|
79 |
|
106 |
|
9 |
Number of confirmed cases |
|
41 |
|
42 |
|
28 |
|
32 |
|
1 |
Confirmed cases by category |
|
|
|
|
|
|
|
|
|
|
Bribery and corruption |
|
6 |
|
1 |
|
2 |
|
1 |
|
0 |
Violation of cartel laws and fair competition rules |
|
0 |
|
0 |
|
1 |
|
0 |
|
0 |
Fraudulent actions against the Group |
|
11 |
|
6 |
|
11 |
|
3 |
|
0 |
Other violations of the our Compliance Principles for the relations with business partners |
|
0 |
|
0 |
|
2 |
|
3 |
|
0 |
Other violations of our values, internal guidelines or legal requirements |
|
24 |
|
35 |
|
12 |
|
25 |
|
1 |
Data Privacy
|
|
2020 |
|
2021 |
|
2022 |
|
2023 |
|
2023 |
||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Reported violations of Data Privacy Guidelines |
|
3 |
|
3 |
|
4 |
|
7 |
|
0 |
||||
Customer Privacy1 |
|
|
|
|
|
|
|
|
|
|
||||
Total number of substantiated complaints received from outside parties |
|
0 |
|
0 |
|
0 |
|
0 |
|
0 |
||||
Total number of complaints from regulatory bodies |
|
0 |
|
0 |
|
0 |
|
0 |
|
0 |
||||
Total number of identified leaks, thefts, or losses of customer data |
|
0 |
|
0 |
|
0 |
|
1 |
|
0 |
||||
|
||||||||||||||
Legal actions
|
|
2020 |
|
2021 |
|
2022 |
|
2023 |
|
2023 |
||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Total number1 of legal actions pending or completed (for anti-competitive behavior, violations of anti-trust or violations of monopoly legislation) |
|
4 |
|
4 |
|
3 |
|
2 |
|
1 |
||||
pending |
|
4 |
|
3 |
|
2 |
|
1 |
|
1 |
||||
completed |
|
0 |
|
1 |
|
1 |
|
1 |
|
0 |
||||
|
||||||||||||||
For further information please see our annual reports:
Annual Report 2020, pages 125-127 and pages 252-256, No. 27
Annual Report 2021, pages 100-101 and pages 280-284, No. 27
Annual Report 2022, pages 97-98 and pages 282-285, No. 27
Annual Report 2023, pages 90-91 and pages 284-287, No. 27