Anti-Corruption/Anti-Trust Laws

The social, ethical and business principles embraced at WACKER are summarized in our Code of Conduct. All WACKER employees worldwide are obligated to behave accordingly. There are separate and/or supplemental guidelines for individual Group companies (e.g. Siltronic AG’s Code of Ethics) and corporate sites (e.g. WACKER Greater China’s Employee Handbook). Group companies in the USA have their own compliance programs tailored specifically to US law.

At WACKER, we do not tolerate violations of our Code of Conduct or of any pertinent legislation. Any employee who has questions about appropriate behavior at work can receive counsel and assistance from supervisors, specialist units (e.g. legal department) and employee representatives. Compliance officers are available as trusted third parties in Europe, Asia and the USA.

Our compliance program is designed to prevent misconduct, minimize the repercussions of misconduct, and – in accordance with the UN’s Global Compact – identify any cases of corruption or other legal infringements. To promote compliance, we use diverse organizational methods, such as the separation of responsibility and our dual-control policy. In the first case, we ensure that payment-triggering processes, for example, are not in one person’s hands (the purchasing unit is quite distinct from the ordering unit). In the latter case, dual control ensures that every critical transaction is checked by a second person.

Corporate Auditing inspects units for risk exposure. Its auditors look most frequently at those processes and areas with a high exposure to corruption or to legal noncompliance (including anti-trust and tax infringements). In the case of capital-intensive engineering activities (e.g. project engineering and maintenance), WACKER employs specially trained industrial forepersons as auditors.

For several years, European-based employees with direct customer/competitor contact have received online training about European anti-trust law. WACKER’s anti-trust program is compulsory for employees in Marketing and Sales. Employees in the USA receive anti-trust training that has been tailored to the market there. In addition to online training (which participants must regularly complete), employees have the opportunity to attend courses on the subject during divisional and regional meetings and international sales conferences. Since 2009, we have been applying our anti-trust training program worldwide.

WACKER’s corporate culture is characterized by mutual respect and trust. However, inappropriate behavior on the part of individual employees can never be completely eliminated. In these cases, we rely on our internal risk assessments. The disclosure of road-salt price-fixing agreements between 1998 and 2007 shows that our control mechanisms work. WACKER voluntarily reported the incident, cooperated with the authorities and, as the principal witness, remained immune from anti-trust penalties.