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, Directors of Internal Audit, Control, Compliance, Human Resources and Sustainability. 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 department is directed by the Director of Compliance, who reports directly to the General Counsel.
Business unit and function management are responsible and accountable for raising awareness and compliance within their respective businesses and functions. We have appointed business and function compliance officers and have set up compliance committees in the businesses. Together with the compliance department, the compliance officer assesses the main compliance 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 or function management team, who then take appropriate action.
Compliance and integrity reporting and monitoring
AkzoNobel has developed a set of corporate reporting tools to manage compliance and integrity at the company. The compliance department manages these tools/reports and reports on outcome and effectiveness to the Compliance Committee.
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 2014, more than 12,000 employees signed this declaration.
Non-financial letter of representation (NFLoR)
At the end of the year, the Managing Director/Corporate Director of each business and function signs the NFLoR to confirm compliance with the Code of Conduct and other corporate non-financial requirements. The NFLoR process is a comprehensive certification by various levels of AkzoNobel management that our business has been conducted in compliance with external and internal rules. Exceptions are noted and explained and action plans are developed to address weaknesses. The NFLoR process starts deep in the organization; results are rolled up to business unit, corporate function, country and Business Area level. 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 function and progressed. The outcome of the NFLoR process, in combination with the internal control self-assessment process and internal audit results, forms the basis for the Statement of the Board of Management in this Report 2014.
Share Dealing Rules 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 Rules.