| Policy/Guideline |
Content |
Target Group |
|
1. Compliance Policy
(Updated 2021)
|
This policy outlines the HeidelbergCement compliance programme:
- Responsibilities (general and specific compliance management)
- Compliance in joint entities
- Contents and tools
- Sanctions in case of non-compliance
|
Upper management |
2. Code of Business Conduct
(Updated 2021) |
The Code of Business Conduct sets the ethical and legal standards
for day-to-day business activities in terms of:
- Compliance with applicable laws and internal policies
- Antitrust law
- Health and safety
- Environmental and sustainability issues
- Human rights
- Plenty of more compliance topics
Emphasis is laid on the responsibility of all employees to uphold
these standards and the fact that violations are not tolerated
|
All employees |
|
3. Anti-Corruption Guideline
(Updated 2021)
|
This document provides guidance in situations which could bear corruption risks, such as:
- Giving or receiving gifts or hospitality to or from business partners
- Gifts or hospitality with respect to representatives of public authorities
- Conflicts of interest
- Corporate citizenship activities
- Cooperation with agents and advisors
- Merger and Acquisition projects
Risk-mitigating measures include
- Personnel-rotation
- Two-person integrity and segregation of duties
- Adequate documentation
- Information and training of employees exposed to corruption risks
|
- All employees and focus on Management
- Employees involved in procurement, i.e. purchasing employees as well as engineers (e.g. by determination of specifications)
- Employees of specialist departments that use external service providers (e.g. attorneys, accountants, auditors, consultants, etc.)
- Employees of departments responsible for obtaining governmental permits of all kinds and other approvals
- Sales employees
- Employees involved in corporate acquisitions
- Employees involved in Corporate Citizenship activities (sponsorships, donations, etc.) that accompany HC CAPEX projects.
|
4. Competition Law Guidline
(Updated 2021) |
This guideline gives an overview over the following topics:
- Responsibilities in terms of competition law
- Competition law infringements relevant to our business and their legal consequences
- Rules of conduct in order to avoid competition law violations
- Instructions for conduct in the event of competition law
- investigations
- Reporting on competition law incidents
- Implementation of and minimum requirements for national
- Competition law guidelines
- Mitigation measures, such as:
- Adequate documentation,
- Yearly risk assessment,
- Information and training of employees exposed to
- Competition law risks
- Specific Grey Cement/Cementitious compliance rules for EEA Countries
|
- Upper management
- Sales managers and officers
- Purchasing managers and officers
- Managers and employees involved in procurement
- Merger and Acquisition projects
- All other
|
5. Compliance Incident Reporting and Case Management Guideline
Updated 2021) |
This document provides guidance on:
- The types of incidents to be reported as compliance incidents
- The various reporting channels
- How a compliance incident should be reported
- How the investigation process is organized (responsibilities, timing, documentation, communication, etc.)
- Which persons need to be informed within the organization in case of reported compliance incidents
- Securing data if severe compliance violations are suspected
- Responsible persons for remedial measures in case of proven
- Misbehaviour
- The investigation principles
|
All employees |
6. Trade Sanctions Policy
(Updated 2020) |
This policy provides:
- An overview of national and international trade sanctions
- The types of EU and U.S. trade sanctions and their scope of applicability
- Details on the responsibilities on Group and local level
|
- Upper Management
- Sales managers and officers
- Purchasing managers and officers
- HR managers and officers
- Managers and employees involved in procurement and
- Merger and Acquisition projects
- All employees charged with screening of business
- Partners for trade sanctions compliance
|
7. Human Right Position
(Updated 2020) |
This policy specifies:
- HC’s commitment to a list of different human rights documents
- The application of human rights in our relationship with our
- Employees,
- Suppliers and customers
- Surrounding of location (corporate citizenship)
|
All employees |
8. Anti-Money Laundering Policy
(Updated 2020) |
This policy specifies HC’s
- Obligations to prevent money laundering
- Regulations for cash payments
- Approach to money laundering risk management
|
- Treasury/staff involved in financial transactions
- Master data requester (purchasing, sales)
- Master data administration
- All employees involved in selection of business
- Partners and business transactions
|
