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.

Complaints procedure (SpeakUp!)

As mentioned earlier, this is the internal system, available 24 hours a day, which encourages employees to report alleged breaches of the Code of Conduct. The system is also available for temporary employees, third parties with whom AkzoNobel has a business relationship (such as customers, suppliers and agents) and members of the general public.

Integrity management

 

 

 

 

 

 

 

2010

 

2011

 

2012

 

2013

*

By definition this number is not yet known.

 

 

 

 

 

 

 

 

 

Code of Conduct reporting

 

 

 

 

 

 

 

 

Code of Conduct number of alleged breaches reported

 

260

 

245

 

295

 

151

Code of Conduct breakdown of alleged breaches

 

 

 

 

 

 

 

 

Health & Safety

 

22

 

18

 

42

 

8

Business integrity

 

122

 

112

 

152

 

82

Treatment of employees

 

113

 

112

 

101

 

61

Other

 

3

 

3

 

0

 

0

 

 

 

 

 

 

 

 

 

Code of Conduct investigation

 

 

 

 

 

 

 

 

Code of Conduct alleged breaches investigated (in %)

 

100

 

100

 

100

 

100

Code of Conduct alleged breaches handled by the Compliance Committee (in numbers)

 

23

 

24

 

24

 

9

Code of Conduct alleged breaches handled by the relevant businesses (in numbers)

 

237

 

221

 

271

 

142

Substantiated Code of Conduct breaches (within year)

 

170

 

149

 

163

 

57

Substantiated Code of Conduct breaches (total, including breaches substantiated in a later year)

 

170

 

149

 

178

 

–*

Number of dismissals for Code of Conduct breaches within year

 

118

 

99

 

131

 

43

Dismissals for Code of Conduct breaches (total, including employees dismissed in a later year)

 

120

 

108

 

139

 

–*

 

 

 

 

 

 

 

 

 

Compliance monitoring

 

 

 

 

 

 

 

 

Competition Law Compliance Declaration (number of confirmations)

 

13,000

 

14,400

 

15,900

 

12,700

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

 

100

 

100

 

100

 

100

 

 

 

 

 

 

 

 

 

Code of Conduct training

 

 

 

 

 

 

 

 

Code of Conduct trained (% online employees)

 

95

 

95

 

96

 

95

Competition law compliance declaration

Employees who meet defined criteria, such as contact with customers or suppliers, confirm their compliance with competition law as articulated in our Competition Law Compliance Manual through an annual declaration. Any possible concerns are reported to the General Counsel and appropriate actions are taken. In 2013, 12,700 employees signed this declaration.

Non-financial letter of representation (NFL)

At the end of the year, the Managing Director 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 2013.

Share Dealing Code Statement

Members of the Board of Management, Executive Committee and Supervisory Board, along with certain designated employees, are made aware of their obligations under the AkzoNobel Share Dealing Code.