Global Guidelines Provide FrameworkCompliance, Risk Management and Internal Audit are grouped under NORMA Group’s Risk, Compliance & Internal Audit department.
NORMA Group ensures that effective compliance management systems are in place and communicates this to its employees in a transparent manner. (CR Roadmap 2018)
Our corporate culture is characterised by responsibility, integrity and mutual respect – by our managers and employees as well as between NORMA Group and its business partners. NORMA Group expects that its employees do not just comply with the existing laws and regulations, but also respect important ethical standards. NORMA Group’s compliance policies serve as a model for other companies.
The implementation of compliance-specific frameworks ensures that rules are set out clearly and transparently. NORMA Group’s core compliance policies are the Code of Conduct, the Conflicts of Interest Policy, the Anti-Corruption Policy and the Supplier Code of Conduct. We reviewed and refined our key compliance documents in 2015 together with an external law firm. The final documents were submitted to the Management Board and the Supervisory Board for approval in 2016 and then distributed internally. Almost all of NORMA Group’s employees have already received training on the Code of Conduct. We also aim to repeat the recently introduced refresher training module (with varying content) on a regular basis going forward. These documents can be viewed online at the following address: http://normagroup.com/compliance-policies_EN. GRI [G4-56]
NORMA Group’s compliance officers take appropriate measures to support and review compliance with these policies in their respective areas of responsibility. They are the point of contact for questions and for reporting potential illegal, unethical or improper conduct. Compliance officers can be approached by anyone, including customers, contractual partners, suppliers or anyone else in a business relationship with NORMA Group. All information is treated with the necessary discretion.
Comprehensive Training Ensures that Compliance Standards Are Observed
NORMA Group offers compliance training in the form of face-to-face and online courses. Employees are assigned training to be completed based on their needs and in line with their tasks and responsibilities. Every NORMA Group employee is required to complete the basic training modules – “Code of Conduct & Compliance Basics” and “Information Security.” In addition, a refresher course was created in 2015 that recaps the main points of the two mandatory courses to keep employees’ knowledge up to date at all times.
Depending on their individual tasks and responsibilities, employees are assigned further training from the available catalog of courses. This training is compulsory. These include courses on anti-corruption, competition law or product liability, for example. All compliance training is mandatory for NORMA Group’s compliance officers.
Once a year, a group of employees defined by the Compliance department (such as senior executives in relevant functions) across the Group are required to submit a Declaration of Compliance. This confirms that the content and requirements of the Code of Conduct and the other compliance policies are known and observed, were observed in the previous year, that all violations have been reported to NORMA Compliance and that no violations by other persons are known that have not already been reported. The rate of submission in 2015 was 100 percent. GRI [G4-SO4]