2014 overview


Our training program and curriculum is a cornerstone of our Compliance framework. A wide range of compliance training modules on various topics is available to every new employee. In 2014, we rolled out updated competition law training for designated employees. More than 10,000 employees have completed the course.

The Executive Committee received tailored competition law and export control training. In addition, top management also participated in live competition law and fraud training.

Sensitive Country Program

Our Sensitive Country Program was continued in 2014. Under this program, a small team – consisting of the General Counsel, another member of the Executive Committee and the Director of Compliance – meets regularly during the year. 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 action regarding trade with parties in specific countries, including enhanced internal review and the imposition of additional restrictions, such as bans.

The Sensitive Country Program supplements our Export Control Program, which contains procedures and training that provide up-to-date guidance for employees on regulatory obligations 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 high growth 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 refer to the Sustainability statements section.