Compliance

The social, ethical and business principles embraced by WACKER are summarized in our Code of Conduct. All WACKER employees are required to follow it. 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). The Group’s US subsidiaries have their own compliance programs tailored specifically to US law.

WACKER does not tolerate violations of its Code of Conduct or of any legal requirements. Any employee who has questions about appropriate behavior at work can receive counsel from supervisors, specialist units (e.g. legal department) and employee representatives. We expanded our compliance team beyond Germany, the USA and China in 2010 by appointing and training new compliance officers at other major production locations. As a result, employees in Japan, India, South Korea, Brazil and Singapore now have direct access to compliance officers. In 2010, WACKER Greater China set up a compliance hotline that enables employees and business partners to report any breaches of compliance anonymously. Every year, employees in the region must sign a declaration regarding proper conduct.

In 2010, the Compliance Management team held numerous classroom seminars to inform employees about WACKER’s ethical and legal management principles. We developed and implemented a mandatory online course that has been used to train employees who have regular business contacts. Enforced throughout the Group, this course complements the existing online training on European antitrust law (WACKER Antitrust Program).

Instruction in antitrust law is essential for WACKER sales and marketing employees. US staff receive antitrust law training 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. Global rollout of antitrust training commenced in 2009. A year later, WACKER launched online training on data protection.

Our compliance programs are 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 such organizational methods as the separation of responsibility and our dual-control policy. Separation of responsibility makes it impossible for any one employee to single-handedly carry out transactions involving payments. The purchasing unit is thus quite distinct from the ordering unit. Dual control ensures that every critical transaction is checked by a second person.

Our internal Corporate Auditing department regularly checks all corporate entities on behalf of the Executive Board. The Executive Board adopts a risk-driven approach when choosing audit topics, which, if necessary, are flexibly adjusted during the year to take account of changes in underlying conditions. Its auditors look particularly frequently at processes and areas with a high exposure to corruption or to legal noncompliance. For capital-intensive engineering activities (e.g. project engineering and maintenance), WACKER employs specially qualified industrial personnel as auditors. In total, Corporate Auditing conducted 37 audits in 2010 (2009: 36 audits). The audits did not reveal any major complaints. Audit recommendations to optimize processes are being implemented.

WACKER’s corporate culture is characterized by mutual respect and trust. However, inappropriate behavior on the part of individual employees can never be eliminated. In these cases, we rely on our internal risk assessments.