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Integrity management


Integrity and responsibility in our actions is one of AkzoNobel’s core values, embedded in our Business Principles and the Code of Conduct.

Code of Conduct

Our Code of Conduct, which was updated in 2007, incorporates fundamental principles on issues such as business integrity, labor relations, health, safety and environment, and community involvement. It provides strict rules for doing business in a fair and open way, while forbidding anti-competitive behavior and bribery. During 2008, our Anti-bribery and Competition Law compliance manuals were updated.

These documents are available in the nine corporate languages and have associated online and face-to-face material to support employee training and future induction training in each business. Around 18,500 employees have already completed the online Code of Conduct training. Our target is to train all employees by mid-2009.

Managing compliance

The AkzoNobel Compliance Committee, comprising the General Counsel and Corporate Directors of Internal Audit, Compliance, Human Resources and Corporate Control, was set up to foster awareness of, and control compliance with, the AkzoNobel Code of Conduct. Each business unit has appointed a member of the management team to act as the Compliance Focal Point, to manage the roll-out of compliance projects and monitor compliance with the Code of Conduct.

During 2008, the Compliance Committee and Focal Points developed a compliance risk profile for each business unit, using a standard risk identification process. The profile identifies the compliance risks that require special focus. These will be subject to periodic reviews and updates.

AkzoNobel has a number of important tools to measure compliance:

  • A corporate complaints procedure allows employees to express their concerns on (alleged) breaches of the Code of Conduct
  • Non-financial Letter of Representation. Each business unit has processes in place to assure compliance with the Code of Conduct and other corporate requirements. At the end of the year, each senior manager and the business unit Managing Director signs the non-financial Letter of Representation to confirm compliance. The outcome is reviewed with the responsible Board member and General Counsel and the results are reported to the Board of Management and the Audit Committee
  • Compliance audits are conducted within AkzoNobel and the outcome shared with the Compliance Committee.

Complaints procedure

Both AkzoNobel and the former ICI operated global complaints procedures which encouraged employees to report potential violations of the Code of Conduct to their supervisor, to the office of the Legal Counsel, or via an independent whistle blowing process. During 2008, we reviewed and started a project to amalgamate the different procedures into a single process. A global supplier will be appointed to operate a confidential telephone and web-based reporting system.

All breaches of the Code of Conduct are fully investigated under the supervision of the General Counsel. In 2008, we received 89 (2007: 92) calls on our external alert lines. Most were minor HR issues which were treated locally; a few were treated as compliance issues. In total 84 (2007: 36) alleged violations of the Code of Conduct were reported through a variety of routes. These have resulted in 61 (2007: 18) terminations. Breaches included fraud cases, but none of the investigations identified any material issues or evidence of systematic failure of company systems.

Compliance type

 

 

Download XLS

 

 

 

 

 

2008
AkzoNobel1

2007
AkzoNobel1

2007
reported

 

 

 

 

1

2008 AkzoNobel and 2007 AkzoNobel data represent the new AkzoNobel including ICI.

Business integrity: fraud/bribery

52

4

2

Use and protection of assets

10

10

9

Equal and fair treatment

7

11

11

Conflict of interest

6

5

5

Health and safety

5

3

1

Free market competition

1

3

3

Other

3

0

0

 

 

 

 

Total

84

36

31

Compliance source

 

 

Download XLS

 

 

 

 

 

2008
AkzoNobel1

2007
AkzoNobel1

2007
reported

 

 

 

 

1

2008 AkzoNobel and 2007 AkzoNobel data represent the new AkzoNobel including ICI.

Corporate complaints procedure/
US alert line

17

13

8

External investigation

1

1

1

Internal Audit review

14

3

3

Letters to Board of Management

6

2

2

Internal BU investigation

46

17

17

 

 

 

 

Total

84

36

31

 

 

 

 

Reports closed by December 31

71

31

26

Reports open on December 31

13

5

5

Number of dismissals

61

18

12

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Copyright © 2009 Akzo Nobel N.V.