Preventing and Detecting Bribery and Corruption

Our Compliance Management System described under the “Strategy & governance” and “Mechanisms to identify, report and investigate concerns of unlawful behavior” sections also includes preventing and detecting bribery and corruption.

Compliance

Potential violations of the Code of Conduct by suppliers and business partners, including risks and violations relating to human rights and environmental obligations, can be reported to Group Compliance as well. Group Compliance conducts an initial evaluation of, and, if necessary, a further investigation into, the report. Necessary action is also taken to minimize or eliminate violations and risks. This is also designed to reduce the risk of white-collar crime, such as corruption and bribery, within the supply chain and among distributors and sales staff.

Compliance training

Web-based compliance training is mandatory across the Group for all employees every two years. The areas it covers include strategies and methods, general definitions in anti-fraud and compliance management, an introduction to techniques and investigative approaches, existing reporting and communication channels at WACKER, as well as an illustration of potential risk and fraud scenarios using concrete examples and presentation of potential transactions.

At WACKER, employees in Procurement & Logistics, Engineering and Sales & Distribution Management are considered at-risk functions. In addition to mandatory standard training, they must undergo more extensive training, such as in-person compliance training covering specific risks and challenges as well as further-reaching compliance awareness using, for example, transactions that reflect actual practice.

Since all WACKER employees worldwide have to take part in compliance training, the courses fully cover all compliance risk functions too. As a result, our coverage of at-risk functions in the reporting period was 100 percent.

WACKER also offers voluntary training and continuing professional development courses, which employees can access and use via the training portal. Targeted training sessions are also available for externals, for example on topics such as fraud prevention and compliance management.

Members of the global administrative and management bodies are covered by the groupwide compliance training sessions. WACKER’s Supervisory Board receives training on the main insider-trading legislation and director dealings. As a rule, training is provided as soon as a new Supervisory Board member has been appointed. In addition, the Legal department performs regular checks in connection with conflicts of interest.

Confirmed cases of bribery or corruption

During the reporting period, WACKER received reports of potential compliance-related incidents. There were no cases of bribery or corruption. In the reporting period, there were no fines for violations of bribery or corruption regulations.

To maintain transparency and the ability to produce evidence, reports received and investigative action are documented centrally by the Compliance organization and individual Group companies. To meet requirements under data protection regulations, investigative action is recorded in detail at the subsidiary concerned.