Compliance
Principles and Guidelines
Our company’s ambition for operational excellence and a prime position among the best in our industry needs a solid commitment to lawful and ethical conduct. Therefore, the Code of Business Conduct describes our values of high ethical and legal standards for all our business activities, from strategic planning to day-to-day procedures in all countries in which we operate.
Moreover, Heidelberg Materials commits to its responsibility to respect human rights. This commitment is summarized in the Policy Statement on Human Rights.
Compliance
We comply with the applicable laws and regulations as the legal basis of our business activity. As a globally active company, we are moreover committed to global values and standards. We are committed to the principles of the following internationally recognized standards:
- OECD Anti-Bribery Convention
- COE Criminal/Civil Law Convention on Corruption
- United Nations Convention against Corruption
- The Universal Declaration of Human Rights
- The eight core labor standards of the International Labor Organization (ILO)
- The United Nations Guiding Principles for Business and Human Rights (“Protect, Respect and Remedy” Framework)
We expect our employees and business partners to comply with the key guidelines and recommendations.
Consequently, ethical and compliant behavior of our employees, as stipulated in our Code of Business Conduct, is assessed and documented as part of our annual performance review system.
Responsibility and organization
The compliance program, firmly anchored in the group-wide management and supervisory structures, is part of our management culture. It comprises the entire compliance organization within the group, the set-up of guidelines, and the verification of compliance with these guidelines. The compliance management addresses all compliance topics that Heidelberg Materials (HM) has identified as relevant in the compliance risk assessment. These include, in particular, competition law, anti-corruption, and human rights.
At the group level, the compliance organization is under the authority of the Chairman of the Managing Board, to whom the Director Group Legal and Compliance reports directly. On the local level, the compliance function is managed by the Senior Compliance Manager, reporting to the Legal and Compliance Director with direct reporting lines to HME Managing Director and HM Group Legal and Compliance Director. However, responsibility for ensuring that employees’ conduct complies with the law and regulations lies with all managers and, of course, with the employees themselves.
Compliance processes
We have implemented an integrated compliance program across the group to achieve conduct that is compliant both with the law and with regulations. A central element of this program is the self-commitment made by the group management not to tolerate violations of applicable laws and to impose sanctions. The program also includes internal guidelines and measures that express the legal provisions in concrete terms.
In addition to regular communication of these guidelines, group-wide implementation of the compliance program is monitored by regular and special audits by Group Internal Audit as well as via special half-yearly compliance reporting by the Director Group Legal and Compliance to the Managing Board and the Audit Committee of the Supervisory Board. The latter monitors the effectiveness of the compliance program and verifies in particular, whether it adequately satisfies the legal requirements and recognized compliance standards. An additional quarterly report regularly informs the Managing Board members with regional responsibility about the most important compliance incidents in their group areas.
Compliance Incidents Reporting System “Speak-Up”
In order to support our commitment to compliance with applicable laws and international ethical standards, we offer our employees as well as external persons, the possibility to report concerns regarding any kind of unlawful behavior or violation of internationally acknowledged conventions via our compliance hotline, Speak-Up.
Examples of incident types to be reported:
- Corruption, bribery, kickbacks
- Child or forced labor
- Discrimination
- Data breach/breach of privacy
- Environmental issues/sustainability
- Health and safety issues, etc.
- The description of the incident should be as precise and straightforward as possible.
Access to Speak-Up
The Speak-Up internet portal can be accessed by clicking the below link:
The portal provides a means for communication between the reporting and the investigating person with the possibility to guarantee full anonymity of the reporting person if required.