Our Code of Conduct
Supervisors’ responsibilities
Special responsibility of supervisors
Without exception for prestige or power, supervisors ensure that:
- There are no violations of applicable law or internal regulations, which could have been prevented or impeded through appropriate controls.
- Compliance with applicable law and internal regulations is continuously and properly monitored in their particular area of responsibility.
- Their associates are aware that violations can lead to disciplinary consequences, regardless of their role or hierarchy.
It is important that supervisors:
- Act as role models for their associates.
- Inform associates about the rules of our Code.
- Discuss Code rules with associates.
- Are available for questions or guidance about our Code’s principles or other internal regulations.
Supervisors are the driving force behind the Compliance Dialogs conducted routinely in their departments.
What is the “Compliance Dialog”?
In the Compliance Dialog, supervisors and associates openly discuss Compliance and its impact on their work environment. Topics can include uncertainties about Compliance requirements and dilemmas encountered in everyday work. More information on the Compliance Dialog can be found here.
If supervisors receive information about possible violations of the Compliance Requirement by associates or third parties, they contact the Compliance department or another responsible department. They forward legally significant matters to the department responsible for legal advice.
