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Compliance and integrity reporting and monitoring


AkzoNobel has developed a set of corporate reporting and monitoring tools to manage compliance and integrity at the company. The compliance department manages these tools and reports on outcome and effectiveness to the Compliance Committee.

Code of Conduct complaints procedure (SpeakUp!)

This is a permanently available internal system which encourages employees to report alleged breaches of the Code of Conduct. The system is also available for temporary employees and third parties with whom AkzoNobel has a business relationship (such as customers, suppliers and agents). The outcome of the reports and root cause analyses are reported to the Compliance Committee and General Counsel and appropriate actions are undertaken.

Integrity management

 

 

 

 

 

 

 

2009

 

2010

 

2011

 

2012

 

 

 

 

 

 

 

 

 

Code of Conduct complaints reporting

 

 

 

 

 

 

 

 

Number of alleged complaints reported

 

198

 

260

 

245

 

295

Breakdown of reported complaints

 

 

 

 

 

 

 

 

Health and Safety

 

22

 

22

 

18

 

42

Business integrity

 

72

 

122

 

112

 

152

Treatment of employees

 

103

 

113

 

112

 

101

Other

 

1

 

3

 

3

 

 

 

 

 

 

 

 

 

 

Code of Conduct investigation

 

 

 

 

 

 

 

 

Alleged complaints investigated (in %)

 

100

 

100

 

100

 

100

Alleged complaints handled by the Compliance Committee (in numbers)

 

18

 

23

 

24

 

24

Alleged complaints handled by the relevant business (in numbers)

 

180

 

237

 

221

 

271

Substantiated Code of Conduct complaints after investigation (of total number of alleged complaints)

 

127

 

170

 

149

 

163

Number of dismissals for Code of Conduct violations

 

69

 

118

 

99

 

131

 

 

 

 

 

 

 

 

 

Compliance monitoring

 

 

 

 

 

 

 

 

Competition Law Compliance Declaration (number of targeted employees)

 

10,000

 

13,000

 

14,400

 

15,900

Non-financial letter of representation (% of operational managers)

 

100

 

100

 

100

 

100

Share Dealing Code Statement (% of designated employees, members of Board of Management, Executive Committee and Supervisory Board)

 

100

 

100

 

100

 

100

 

 

 

 

 

 

 

 

 

Code of Conduct training

 

 

 

 

 

 

 

 

Trained (% employees with access to our intranet)

 

95

 

95

 

95

 

96

Competition law compliance declaration

Employees who have contact with customers, suppliers or competitors confirm their adherence to the Competition Law Compliance Manual through an annual declaration. Any possible concerns are reported to the General Counsel and actions are taken. In 2012, 15,900 employees signed this declaration.

Non-financial letter of representation (NFL)

At the end of each year, the General Manager of each business signs the NFL to confirm compliance with the Code of Conduct and other corporate non-financial requirements. The outcome is reviewed with the responsible member of the Executive Committee and General Counsel and the results are reported to the Board of Management and the Audit Committee. Outstanding actions are followed up in each business and progressed in quarterly reviews. The outcome of the NFL process, in combination with the internal control self-assessment process, forms the basis for the Statement of the Board of Management in this Report.

Share Dealing Code statement

Members of the Board of Management, Executive Committee and Supervisory Board, along with certain designated employees, annually confirm awareness of their obligations under the AkzoNobel Share Dealing Code and the Disclosure Controls and Procedures and agree to comply with such obligations.

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