The compliance department, in close collaboration with the Compliance Committee, provides an adequate compliance framework and ensures 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 consists of the General Counsel (chair), Corporate Secretary, Senior Legal Counsel and Corporate Directors of Internal Audit, Control, Compliance, Human Resources and HSE and Sustainability.
Business unit management and corporate staff departments are responsible and accountable for raising awareness and compliance within their respective businesses and departments. We have appointed business compliance officers and set up compliance committees in each of the businesses. The compliance officer assesses the main risks, improves and monitors compliance and its effectiveness and ensures training of the relevant employees. The compliance officers also ensure that alleged breaches of the Code of Conduct are investigated and findings and lessons learned are reported to the relevant business management team, who then take appropriate action.