WACKER’s ethical principles of corporate management exceed legal requirements. They are summarized in our Code of Conduct. All WACKER employees are required to follow this code. There are separate and/or supplemental guidelines for individual corporate sites (e.g. WACKER Greater China’s Employee Handbook). The Group’s US companies 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. The chief 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 law 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.

In the period under review, Compliance Management devised globally applicable measures in consultation with international sites to ensure compliance with local requirements. Another focal point was protection against cybercrime. Employees working in high risk areas, such as accounting and finance, received instruction in effective strategies to combat cyberattacks.

As of 2014, employees involved in import and export processes must complete online training on export control every two years. Individuals working in particularly sensitive jobs, such as managing directors of regional subsidiaries and export control representatives, must complete a refresher course every year. Export control is based on national and international laws and aims to prevent the spread of weapons of mass destruction, combat international terrorism and uphold human rights. In this regard, it is important to inspect not only the item to be exported, but also the country of destination, the customer and the end use of the products.

Corporate Auditing is part of our risk management system. On behalf of the Executive Board, this department regularly reviews all corporate entities with regard to processes, focusing on internal control systems. The Executive Board – in consultation with the Audit Committee – 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. Processes and areas that constitute a high risk in terms of corruption or legal non-compliance are scrutinized more frequently by the auditors. 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.

The auditing emphasis in 2013 and 2014 was on sales topics, the settlement of investment projects and external maintenance work, and solving cybercrime. In addition, cross-functional audits were used to review the business processes of eight subsidiaries. Corporate Auditing conducted a total of 29 audits in 2014 and 30 in 2013. No major complaints came to light. Audit recommendations to optimize processes are being implemented and systematically followed up.

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.