02: Woco as a responsible business partner

Compliance

Compliance

The Woco Group regards proper conduct marked by integrity as the basis for value-based corporate governance geared toward sustainability – and thus as key to economic success. Economic success and a good reputation require compliance with the applicable legal framework and generally applicable standards on the part of our Group companies; our Executive Board, Works Council and shareholders; and ultimately all employees. 

Standards such as the United Nations Global Compact supplement the internationally applicable legal requirements. Proper conduct marked by integrity may be determined from the applicable legal regulations and the supplementary ethical standards.
 


Code of Conduct of the Woco Group

A key compliance management tool is the Woco Group’s Code of Conduct, which is meant to provide uniform, practical and consistent guidance on proper conduct marked by integrity in everyday business situations. 

The Code of Conduct applies to all Woco Group companies, both in Germany and abroad, as well as to all companies in which Woco holds a majority stake, whether directly or indirectly. All temporary employees and anyone who acts on behalf of Woco are also subject to the Code of Conduct. The Code of Conduct and the related rights and obligations are communicated clearly to all employees. The Code of Conduct extends to internal operations at the company and external relations with customers, suppliers, politicians, administrative officials and other parties and individuals. The UN Global Compact has been included in the Code of Conduct as a standard of corporate conduct.



Principles and guidelines

Reliability, openness, trust and mutual esteem are the cornerstones of the culture of the Woco Group. We live and act upon this culture together with our business partners and employees. It is the basis for close and successful collaboration. Woco is aware of its social responsibility and upholds the principles of the UN Global Compact. Woco and its employees comply with laws, regulations and guidelines. 


“The key to profitable growth and success may be found not least of all in Woco’s corporate culture. Proper conduct marked by integrity as well as fairness help build a good reputation for a company and are also key criteria for the economic success of a global corporation.”
(Excerpt from the statement of the CFO on the Code of Conduct and the training documents provided for this purpose)

By making these values an integral part of our value system, the Woco Group aims to contribute to the achievement of Sustainable Development Goal 16, which calls on organizations to do their part in creating peace, justice and strong institutions.

Compliance management

The Woco Group established a comprehensive, central compliance management system in 2017 due to the major importance of these topics. The aim of the Woco Group’s compliance management system is to ensure compliance with the applicable laws, regulations and guidelines and to counteract potential problems or violations. It serves to stave off material damages and prevent a loss of reputation. 

The Compliance organization is responsible for performing compliance management. It is closely linked with Group-wide risk management. The Compliance organization’s tasks are composed of three sections, specifically the duty to inform, to monitor and to document, as depicted in the following diagram:

 

 

The Woco Group’s Compliance organization is headed by the Group’s compliance officer, who, as in the case of risk management, is assigned to the CFO. This person reports to the Executive Board and, where appropriate, directly to the shareholders. The compliance officer is responsible for designing and managing the activities intended to inform of, monitor and document related efforts. Situated below the compliance officer are the risk coordinators for individual locations or companies, who carry out the Compliance organization’s tasks at a local level and report to the Group’s compliance officer. Training is overseen by the respective plant managers, who are responsible for having new employees trained.

We have also included compliance management in the internal Group audit process. 

Compliance training

The Code of Conduct is available on the Woco Group intranet in German and English and can be viewed by employees at any time. A printed version is available for employees without access to the intranet (especially those who work in production). 

A compliance training course that has been launched across the Group provides employees with in-depth explanations of the Code of Conduct’s content and context. Training is carried out by plant managers using standardized materials. When necessary, the documents have been translated into other languages. 

The training program kicked off in the first half of 2017, with almost 100 percent of employees having completed it by mid-2017. Since then it has been mandatory for new hires and transfers, and proof of training is documented for each employee. 
 

Reporting and managing incidents and violations

The Code of Conduct provides clear rules on how to submit complaints and report violations. There are contacts for this purpose both at plant level (risk coordinator) and at Group level who can be addressed directly or contacted via a special compliance e-mail address or an emergency number in urgent cases. To streamline reporting, a form is available in the appendix to the Code of Conduct. 

All notifications submitted by employees will be handled confidentially, upon request. Employees who report a violation in good faith will be protected and in no way disadvantaged due to their notification. 

The compliance officer observes strict confidentiality when handling incoming notifications. If necessary, the compliance officer will conduct interviews and other investigations and notify the Executive Board of all incidents.
 

Reporting flagged violations and external sanctions

The creation of a comprehensive Code of Conduct and the establishment of a Group-wide Compliance organization in early 2017 marked important milestones for Woco in its efforts to set up an effective compliance management system. 

The Group’s compliance officer is available to employees as a contact. Questions are received by e-mail or clarified at training events on site. 

Written inquiries often require to involve confirmation that workplace procedures comply with the requirements of the Code of Conduct. However, questions sometimes relate to areas outside the Code of Conduct too.

No serious cases were reported in the economic/social area (socio-economic compliance) during the reporting period. 

In terms of compliance with environmental laws and regulations, internal and external environmental audits in connection with ISO 14001 serve to monitor external standards. Legal conformity is reviewed in separate audits. Any deviations identified are addressed through changes at the plants.

 

Continuous improvement process

  • In order to emphasize the importance of the Code of Conduct, our aim is to make the document available together with the employment contract in the respective national language. This is currently being implemented at our headquarters, and prompt introduction is planned for all other plants. 

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