Corporate governance and compliance

Responsible business practices
Full compliance—not only with all relevant laws and regulations, but also with high ethical standards that we set ourselves as a company—is a central element of our business responsibility and a prerequisite for sustainable business success. Any infringement of laws and ethical rules by a company’s employees and its representatives can severely damage the company’s reputation and its stakeholders’ confidence in it. We have a zero-tolerance policy in this area: any employee violating laws, regulations or company standards has to face strict disciplinary consequences permitted under the respective labor law.

Clear operational guidelines
What principles guide our business conduct? What should an employee do if offered a valuable gift? Who has the authority to make what decisions? How should personal data be handled? We have clear operational guidelines to answer these and many other questions. Our Code of Conduct, for example, requires compliance not only with all applicable laws but with the highest ethical standards. The Corporate Governance and the Corporate Guidelines also list procedures and principles that must be adhered to in day-to-day business activities for the relevant business areas.

Here are examples of the main topics of practical relevance:

• Export controls: As required by international regulations, our highest aim is to avoid any business relationships with states which are subject to trade embargos. Business relationships in politically unstable states are closely monitored, and are only permitted under certain circumstances. All relevant laws and regulations relating to the export of products, services and technologies must be complied with.
  
  
• Bribery: We do not tolerate any form of corruption, active (offering bribes) or passive (accepting bribes).
  
  
• Competition: No Cognis employee shall act in any way that infringes antitrust law. To ensure strict compliance with antitrust laws, we conduct trainings for all relevant employees on a regular basis.
  
  
• Purchasing: We adhere to strict principles in the procurement of raw materials concerning quality, selection of suppliers, and negotiation for example. more
  
  
• Sales: We have clear material rules and responsibilities relating to the sales process. The aim of these is to mitigating risk in connection with the sale of Cognis products and related services.
  
  
• Working conditions: We are committed to ensuring safe and fair working conditions for all our employees. more
  
  
• Safety & health: Health and safety are a top priority for all Cognis employees around the world. Its extreme importance is always first in mind when taking quality, productivity and costs equally into consideration.  more
  
  
• Environmental protection: We are constantly working to reduce our environmental footprint. The “25 by 2012” initiative sets out our intention of improving environmental performance by 25% (over 2002 levels), as measured by a range of key indicators. more
  

Putting compliance into practice
Regular and comprehensive training ensures that all employees are aware of all current corporate policies and legal requirements relating to their working environment. Employees can access policies and guidelines such as the Code of Conduct, the Management Policy and the Safety & Health Philosophy on the corporate intranet and in the SHEQ database. Printed copies are also displayed in the workplace or distributed directly to the employees. And we intend to place our corporate policies – as well as our commitment to upholding them – increasingly in the public domain.

As an ISO-certified company, we are regularly subjected to external quality, safety and environmental audits by independent, professional certification bodies such as TÜV and DQS (German Association for Certification of Quality Management Systems). Our membership of various industry associations (for example the VCI in Germany) and working parties means we are always up-to-date with new laws and regulations. We also observe the “four-eyes principle”, meaning that any actions which create, amend or terminate a legal obligation upon Cognis require the approval of at least two qualified employees.

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