The compliance department, in close collaboration with the Compliance Committee, provides an adequate compliance framework and assures its enforcement via various methods. These methods include the application of monitoring and reporting tools, developing the compliance training curriculum and managing the corporate complaints procedure as a whole, including root cause analyses. The Compliance Committee assists the Executive Committee in its ultimate responsibility to report to the Audit Committee of the Supervisory Board.
The Compliance Committee comprises the General Counsel (chair), Secretary to the Executive Committee, and Corporate Directors of Compliance, Internal Audit, Control and HR, and Legal Counsel Compliance. A total of 24 alleged complaints that were possibly material in character were handled at the level of the Compliance Committee (2011: 24). Of these, three are still under review. Only part of those investigated complaints were substantiated and the Compliance Committee took appropriate actions. However, none of those were considered material for AkzoNobel.
Business unit management and corporate staff departments are responsible and accountable for awareness raising and compliance within their respective businesses and departments. We have appointed BU compliance officers in each of the businesses. A compliance officer assesses the main risks, improves and monitors compliance and its effectiveness and trains the relevant employees. The compliance officers investigate alleged breaches of the Code of Conduct and report their findings and lessons learned to the relevant business unit management team. The management team then takes appropriate action.