Our training program and curriculum is a cornerstone of our compliance program. In 2013, we focused in particular on strengthening our anti-bribery compliance framework by introducing a refreshed online anti-bribery training for designated employees. More than 13,000 employees have completed the course. This program provides guidance on the ban on facilitation payments and sets out norms on gifts and hospitality.
We continue to emphasize competition law compliance in the training curriculum. The Executive Committee and Supervisory Board received competition law training in 2013. In addition, the Managing Director of each business met with competition counsel to discuss recent trends and developments in competition law compliance.
Sensitive Country Program
The Sensitive Country Program was implemented in 2013. Under this program, a small team – consisting of the General Counsel, another member of the Executive Committee and the Director of Compliance – meets on a quarterly basis. They review the extent to which the company does business in countries recognized by monitoring groups such as Transparency International and Freedom House to have significant issues with regards to sanctions and export controls, corruption, human rights, political stability and safety and security. Based on this analysis, we take appropriate action regarding trade with customers in specific countries, including enhanced internal review and the imposition of additional restrictions such as bans.
The Sensitive Country Program supplements our export control framework, which contains procedures and training that provide up-to-date guidance for employees on regulatory and enforcement activities, especially those coming from the US and the EU and including rules with extra-territorial effect. Our established global network of business-based export control officers plays a key role in ensuring export control/sanction compliance.
Business and human rights
The Code of Conduct also sets out our approach to human and labor rights. Our approach is based on, and confirms, our support for the United Nations Universal Declaration of Human Rights, the key conventions of the International Labor Organization and the OECD Guidelines for Multinational Enterprises. We are a signatory of the United Nations Global Compact and continue to integrate principles on human rights, labor, environment and anti-corruption into our strategy and operations.
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. This is reflected in our Code of Conduct, our global HSE standards, and our Vendor Policy for suppliers. We pay particular attention to the company’s presence and operations in emerging markets, as compliance frameworks risk being less advanced in these regions compared with mature economies.
For more information on stakeholder engagement and our safety, environmental and supplier processes, please turn to the Sustainability statements.