Compliance

Our corporate conduct is characterized by a sense of responsibility as well as ethical principles. Compliance with legal and regulatory requirements is integral to our operations. It is only in this manner that we can sustainably increase the company’s enterprise value and safeguard our reputation.

Compliance culture and targets

In our Corporate Compliance Policy, Covestro has specified a Group-wide code of conduct that mandates fundamental principles and rules for all employees. This code of conduct details our commitment to fair competition, integrity in business dealings, the principles of sustainability and product stewardship, data protection, upholding of foreign trade and insider dealing laws, the separation of business and private interests, proper record-keeping and transparent financial reporting, as well as to providing fair, respectful and nondiscriminatory working conditions. The requirements of our Corporate Compliance Policy apply within the company as well as to all interactions with external partners and the general public. Our code of conduct furthermore provides a decision-making framework for our company and our employees. Our Corporate Compliance Policy is available online and on our intranet. New employees receive a comprehensive set of information documents, including our Corporate Compliance Policy.

Covestro is aware that employees will likely embrace and exhibit integrity if managers are excellent role models. As the Board of Management of Covestro states very clearly in its Corporate Compliance Policy for all staff, Covestro does not conduct any business activities that would be legal yet violate our rules. In addition, supervisors are prohibited from instructing employees to violate any Covestro rule. In this way, management continuously fosters our compliance culture by, for example, regularly drawing employees’ attention to compliance topics and their significance to the company. At Covestro town hall meetings, for example, Board of Management members present recent compliance cases to employees as well as underscore the importance of complying with statutory requirements and in-house regulations.

We want to utilize our compliance management system in order to:

• Foster and reinforce conduct per compliance requirements;
• Minimize or even eliminate compliance violations;
• Identify risks for potential violations;
• Implement preventive measures;
• Uncover, remedy and proactively eliminate a repeat occurrence of any compliance violations committed by individuals acting without authorization and in breach of clear rules; and
• Achieve continuous improvement of our compliance management system.

Compliance organization

At Covestro, the Chief Compliance Officer oversees compliance activities and reports in this capacity directly to the Board of Management. A central Compliance department coordinates compliance activities throughout the Covestro Group. The Compliance Committee, chaired by the CFO of Covestro, is the Group's top-level decision-making body on compliance issues. In addition, the Compliance Committee is in charge of the following: exercising a Group-wide compliance governance function, initiating and approving compliance-related regulations and approving the annual training plan. In the reporting period, the Compliance Committee met a total of four times.

A local Compliance Officer has also been appointed for each country in which Covestro has employees. This person serves as a local point of contact for employees on all questions regarding legally and ethically correct conduct in business situations. The country organizations also have local compliance committees.

Communication

Covestro systematically conducts training courses on compliance. Once areas of emphasis have been specified, specialists define target groups for each category of course content and determine which employees require which type of training.

Covestro expressly encourages its employees to openly address any doubts about proper conduct in business situations and to solicit advice. We inform all employees whom they can contact if they have any doubts or questions. Covestro has also set up a whistleblowing portal. Internal and external persons can report potential compliance violations through a hotline accessible worldwide or use an email address that also permits anonymous reports. In addition, employees can also report any compliance incidents to their supervisors, to the local Compliance Officer of their company, or to the Global Compliance Office.

An internal policy sets out the principles for handling compliance incidents at Covestro. This policy also stipulates that all suspected compliance incidents be recorded in a central database. Confirmed violations are evaluated. Organizational, disciplinary or legal measures are taken if necessary.

Compliance incidents are regularly reported to the Supervisory Board, the Board of Management and the segments’ management teams. In addition, a current overview of compliance incidents, along with news and additional information on various aspects and developments related to this topic, is published in a monthly Compliance Telegram on the intranet and therefore can be viewed by all employees.

On a quarterly basis, all Covestro companies document risks arising from pending or current legal proceedings. Relevant cases are reported to the Audit Committee of the Supervisory Board, and the major risks are disclosed in the notes to the consolidated financial statements.

Due diligence on human rights

Covestro is committed to respect for human rights on the basis of the United Nations Guiding Principles on Business and Human Rights. In particular, we are committed to meeting the requirements of various country-specific action plans and laws with respect to due diligence on human rights. We acknowledge that companies are responsible for respecting human rights in their scope of business operations, at subsidiaries and throughout global supply chains and value chains as well as guarding against violations of human rights.

The principles of our due diligence on human rights are delineated in various corporate commitment documents, company policies, and our Supplier Code of Conduct. We revised our Corporate Commitment on Human Rights in 2018 and published it on our website. In this document, we have specified key international conventions and principles as the basis of our conduct. We expect our employees and business partners around the world to conduct themselves in accordance with these principles.

See section “Sustainability in Supplier Management”

A key component of our due diligence on human rights lies in zero tolerance of child labor, forced labor and human trafficking. We made a public statement on the latter last year in our document “Corporate Commitment against Slavery and Human Trafficking.”