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Our global compliance organization aims to ensure compliance with internal and external regulations and with our company requirements.

The compliance management system is an important part of our “three lines of defense” model and is part of the second line of defense involving risk management and control. For more information, please see the Risk Management Report.

Taking account of the reporting of internal and external stakeholders is an important part of the compliance management system. Our whistleblower system ensures that potential violations of the rules are identified, clarified and stopped in good time. Any reports are treated fairly, immediately and adequately and with the utmost confidentiality.

Whistleblower system and compliance

In 2021, WACKER launched a global whistleblower system (based on the BKMS reporting platform) that is available to whistleblowers both internally and externally. Reports can be made in person or anonymously online or using an external hotline. They can also be forwarded to local compliance officers, managers or employee representatives. In the USA, WACKER also offers an additional option for reports in the form of the Navex software platform. The whistleblower process is continuously reviewed for improvement.

Communication and transparency

In 2024, we standardized communication in the whistleblower process and published it on our company intranet and on the company’s website to achieve global coverage. Social audits in employee interviews are one of the tools used to inquire as to employees’ knowledge of the whistleblower system. Reports of potential compliance risks or violations are investigated immediately, independently and objectively. The process underlying this is shown on the intranet and on our website. The decision to launch a compliance investigation is based on circumstances in individual cases and on the findings of the evaluation.

Reporting channels and protective measures

Reports of potential violation of the rules can be submitted by employees, business partners, customers and other third parties via various channels and in several languages. These reports are received by WACKER Group Compliance or the relevant contacts, which conduct thorough and appropriate investigations confidentially and in good time. Protecting whistleblowers and the individuals concerned is one of the basic principle’s of our whistleblower system. We respect the right to confidentiality and we uphold the presumption of innocence and fairness of investigations.

Investigation process

1. Submission of a report: reports can be made at any time and in any language. Group Compliance reviews every report thoroughly and systematically in line with company rules. Whistleblowers receive confirmation of receipt and the reported matter in question is reviewed in terms of content.
2. Investigation of the matter: if suspicion of a violation of the rules is justified, an investigation is launched. The findings are assessed from a legal viewpoint and suitable actions taken. Reports that do not indicate a severe violation of the rules can be passed on to a suitable office within WACKER.
3. Further course of action: the outcome of the investigation will determine whether process-related changes, expansion of monitoring mechanisms or disciplinary measures are taken. Relevant reports are communicated to the appropriate units within the company and whistleblowers are informed of the status and the outcome of the investigation.

Protection from retaliation

WACKER has established extensive measures to afford protection from retaliation in line with the German Whistleblower Protection Act (HinSchG). This includes training and confidential meetings with whistleblowers, individuals under suspicion, and other parties that provided information. We make it our utmost priority to protect the right to privacy, data-protection regulations and confidentiality. Once an investigation has been completed, follow-up action is initiated by the departments responsible. In certain cases, Group Compliance contacts the whistleblowers again to review the effectiveness of these protective measures.

Compliance regulation

Our identification, reporting and investigation mechanisms are set out in our internal guidelines, particularly in the Group’s Compliance regulation. The Group’s Compliance regulation describes the underlying conditions and procedures in the global process for reporting (potential) compliance risks and violations. This regulation is reviewed on a regular basis to ensure it is up to date and if it is not, it is adapted as required.

Our global compliance organization is independent and not bound by any instructions. Our investigation officers (the Group Compliance Officer and Corporate Auditing employees) or any investigation committees that have been set up (e.g. the local compliance committee or human rights task force) are independent of the management chain involved. These investigations are initiated independently, neutrally, without delay and confidentially if the evidence available can be easily comprehended and an investigation is justified.

Compliance and antitrust training

Compliance and antitrust training courses are mandatory training courses that must be completed by all employees every two years groupwide. In the reporting period, we also held training courses and workshops around the world for the groupwide introduction of WACKER’s new global Code of Conduct. Our qualification rate worldwide in the reporting period was 90 percent.

Functions that are at high risk of bribery and corruption include Procurement & Logistics and Sales & Distribution Management.

In the year under review, we established and rolled out new safeguards and a fundamental strategy for managing our worldwide distributors from a compliance perspective. Key subprocesses, actions and controls had already been part of various compliance management processes in the past. Nonetheless, in the year under review, we refined our overall conceptual approach, redefining standard processes and assessment methods, and revising specific compliance training measures.

Communication and compliance policies

WACKER communicates its policies on its intranet and company website as well as in dedicated workshops and training courses. We also devised and published a “tone from the top” message worldwide in the reporting period. All employees can access the company’s rules on the intranet and using our document management system.