Code of Conduct

AkzoNobel Code of Conduct

The Code of Conduct serves as the common reference document which sets out our fundamental principles and rules for doing business. It applies equally to our corporate actions and the behavior of individual employees, regardless of the market segment, function or country in which we operate. Available in 27 languages, the Code of Conduct is distributed in paper form and is widely available online.

The Code of Conduct, together with directives, rules, manuals, guidelines and procedures, are part of the company’s Directives framework, which sets out mandatory internal rules for employees.

AkzoNobel is subject to local, regional and international laws and regulations, regulatory controls and customs and practices in the countries in which we do business. Our legal and compliance experts are monitoring and adapting to significant and rapid changes in a wide range of legal and compliance areas, to ensure that the Compliance framework remains suited for purpose and is properly applied. We are dedicated to minimizing our compliance risk, as identified in the Enterprise Risk Management process. Reference is made to the Risk management chapter in the Strategic performance section of this Report 2014.

Code of Conduct for joint ventures, acquisitions and our supply chain

We make sure that all employees – including those at joint ventures we operate and at newly-acquired companies – are aware of, and comply with, laws and regulations that are relevant to their specific role, as well as the Code of Conduct, directives, rules, manuals, guidelines and procedures that form the Directives framework. In entities we do not control, we encourage consistent application of the values and principles reflected in our Code of Conduct when doing business.

AkzoNobel expects employees of newly-acquired companies to adhere to the Code of Conduct in their daily actions and to live up to our core principles, values and rules for doing business. They receive training, which enables them to fully acquaint themselves with the Compliance framework.

We want to do business with suppliers who share our values and principles. Our Vendor Policy, designed to help ensure a sustainable supply chain, specifically states our desire to do business with partners who endorse our ethical, social and environmental standards, as formulated in the Code of Conduct. Vendors confirm that they conduct their business in accordance with core compliance principles through the AkzoNobel Vendor Policy Declaration. In 2014, we continued with Together for Sustainability, an initiative designed to develop and implement a global audit program to assess and improve sustainability practices within the supply chains of the chemical industry. See Note 7 of the Sustainability statements for more details.

Code of Conduct communication, awareness and training

We appreciate that raising awareness through effective communication and training is pivotal to strengthening our Compliance framework, and assists us in protecting the company and our employees against economic and reputational harm. Communication on the Code of Conduct starts for new employees from the moment they join AkzoNobel and may include online and classroom training.

Around 90 percent of employees with online access have completed the Code of Conduct training module. Each year, our online annual performance appraisal system requires employees to sign off on their awareness of the Code of Conduct. The compliance training curriculum also offers specialized training to improve critical competencies and skills to designated groups of employees on topics such as competition law, anti-bribery, export control, privacy, fraud awareness, anti-harassment and trade secrets.

Code of Conduct complaints procedure (SpeakUp!)

We value an open dialog with our employees worldwide on our core principle of integrity. Our employees are encouraged to report potential issues regarding the Code of Conduct to either their manager, the next line manager or HR manager, the relevant business unit or function compliance committee, the compliance department, or the Compliance Committee. In addition, a global reporting helpline is available to our employees 24 hours a day to report confidentially – and, if desired, anonymously – potential breaches of the Code of Conduct.

These reporting mechanisms are part of the complaints procedure and are described in our SpeakUp! manual. All alleged breaches of the Code of Conduct that are brought to the attention of the compliance department are investigated.

The system is also available for temporary employees or third parties with whom AkzoNobel has a business relationship (such as customers, suppliers and agents) and members of the general public.

In 2014, a total of 170 alleged breaches of the Code of Conduct were reported, both through SpeakUp! and other channels. Of the 170 matters, 67 were substantiated, with 22 still in progress. Eleven were managed by the Compliance Committee as they met defined criteria. Company-wide, 46 employees were dismissed on grounds related to breaches of the Code of Conduct. Other sanctions and remedial actions in (partially) substantiated matters included: review of procedures/controls (12), coaching/training (8), warnings (6), probation (2), and other disciplinary actions (1).