Our Code of Conduct covers the various areas where risks can arise for our businesses. Those areas are addressed by specific programs to guide our employees in abiding by the code. In 2012, we continued to adapt our compliance programs to ongoing changes and kept them up-to-date. We also trained our employees and businesses to be aware of risks that can arise in the various areas. Special attention is given to competition law compliance during the compliance training program.
As part of the actions to further implement anti-bribery regulations into our compliance framework, we developed a new online training program for an appropriate number of employees in 2012. This program provides guidance on the ban on facilitation payments and sets out norms on gifts and hospitality. We also updated the AkzoNobel Share Dealing Code, as well as the disclosure controls and procedures, in order to comply with new Dutch legislation.
Our Export Control program contains procedures and training that provide up-to-date guidance to employees on regulatory and enforcement activities, especially those coming from the US and the EU and including rules with extra-territorial effect. In addition, a global network of export control officers has been established to support the businesses in implementing and complying with the Export Control program. Business unit management, including the BU compliance officers, the BU export control officers and corporate staff departments, are supported by the Compliance department.
To confirm our commitment that every employee is entitled to be treated with dignity and respect as an individual, and the obligation of every employee to uphold high standards of personal conduct at work, a new corporate directive on anti-harassment was launched in 2012. A self-assessment was held to ensure continued compliance with privacy and data protection laws for our data management systems in the Netherlands. This, as well as the implementation of various new information management tools and applications, led to improvement measures and required privacy and data protection training of specifically targeted employees.
The Code of Conduct also sets out our approach to human and labor rights. This approach is based on the principles of the United Nations Universal Declaration of Human Rights, the key conventions of the International Labor Organization and the OECD Guidelines for Multinational Enterprises. In addition, we continue to integrate into our strategy and operations the principles on human rights, labor, environment and anti-corruption of the United Nations Global Compact, to which AkzoNobel is a signatory. As a critical element of being a socially responsible company, our businesses and employees are required to respect the human rights of other employees and the communities in which we operate. Our code pays particular attention to the company’s presence and operations in emerging markets, as compliance frameworks risk being less advanced in emerging, as compared to mature economies. For more information on stakeholder engagement and our environmental strategy, please turn to the section.