WACKER’s ethical principles of corporate management exceed legal requirements. They are summarized in our Code of Conduct, which all WACKER employees are required to adhere to. There are separate and/or supplemental guidelines for individual 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, employee representatives and 22 compliance officers worldwide. Alongside the existing compliance officers, additional ones were appointed and trained in Mexico, the United Arab Emirates and Asia in the period under review. The Group compliance officer reports to WACKER’s president & CEO.

Employees are instructed to inform their supervisors, the compliance officers, the employee council or their designated HR contacts of any violations they notice. WACKER follows up every justified suspicion. WACKER Greater China has a compliance hotline that enables employees and business partners to report any breaches anonymously. Furthermore, every year, employees in the region must sign a declaration regarding proper conduct.

Employees who have regular business contacts must complete a mandatory online course on compliance. Enforced throughout the Group, the course also covers antitrust law. All WACKER sales and marketing employees must additionally undergo an online training on European antitrust law (WACKER Antitrust Program) and receive detailed instruction in antitrust law at classroom seminars. In addition to online training, employees have the opportunity to attend courses on the subject during divisional and regional meetings and international sales conferences. US staff receive antitrust law training tailored to the market there. In Germany, online training on data protection complements the compliance courses.

WACKER’s 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.

One focus of our compliance management in 2011 was on non-German sites. More overseas employees were included in both online and classroom-based compliance training. In 2012, Compliance Management focused on devising and implementing globally applicable measures (in response to the UK Bribery Act 2010, for example) in consultation with international sites to ensure compliance with local requirements.

Our internal Corporate Auditing department systematically checks the effectiveness of WACKER’s control system. Supported by the auditing manual, this department – on behalf of the Executive Board – regularly audits all corporate entities. In consultation with the Executive Board, the department adopts a risk-driven approach to choosing audit topics and sets an annual schedule. If necessary, the schedule is 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 non-compliance. Criteria for the risk assessment include:

• Country classified as having a high risk of corruption
• High possible risk of damage (financial or reputation-related)
• Compliance issue (suspected cases)
• Previous audit revealed substantial need for action
• Legal obligation to have regular audits

For capital-intensive engineering activities (e.g. project engineering and maintenance), we employ specially qualified industrial personnel as auditors.

In 2011 and 2012, WACKER focused on the following topics:

• Plant safety
• Accounting processes
• The settlement of investment projects and external maintenance work
• Obligation by external planners to observe confidentiality whenever they handle WACKER data

Corporate Auditing conducted a total of 32 audits in 2012 and a total of 37 in 2011. 21 of these audits dealt with the inspection of our subsidiaries’ business processes (covering all manner of job functions). The 2012 audit plan was, on the whole, implemented, with nine topics or items for review to be completed in the course of 2013. No major complaints came to light. We are implementing and systematically following up any comments and suggested measures from the audits, for example for improved workflows.

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.

According to Transparency International’s Corruption Perceptions Index (CPI), WACKER is predominantly active in countries that have a low or very low risk of corruption.