Compliance – the cornerstone of ethical business behaviour

“We are convinced that the legal framework we are given always pursues important protection goals, even if this may not always be directly recognisable to everyone when looking at the individual legal obligations. That is why it is so important to know the legal framework in detail. We work on this as a team on the basis of our compliance management system, which is based on ISO 37301 and IDW PS 980. We attach great importance to interdisciplinary dialogue with various departments such as HR, Quality and Legal and to close cooperation with the Works Council. We pursue the goal of ensuring the long-term successful continuation of our company. Compliance, i.e. acting in accordance with all applicable legal provisions, is a basic prerequisite for this.”

“The fact that we as a company are constantly having to deal with new and comprehensive requirements at European and national level makes compliance work increasingly challenging. Without support, it is almost impossible for our company’s specialist departments to maintain an overview of the increasing regulation and implement this in day-to-day operations. They must therefore be able to rely on the expertise and support of the Compliance department. In this respect, compliance is indispensable – and at the same time one of the few areas of the company that operates largely independently of hierarchies in order to ensure objectivity. To summarise, we therefore bear a great deal of responsibility.”

“Let me put it this way: the GDPR, like the BDSG, pursues important goals with the protection of personal rights. However, some of the regulations and their interpretation by the authorities are not particularly helpful or easy to understand – even for experts. This makes it all the more important that we constantly update our knowledge of this throughout the Group and work closely with our external data protection officer. This enables us to find practical solutions that still fulfil the strict legal requirements.”

“Both are very sensitive and important areas. Of course, we at dalli must and want to adhere strictly to the antitrust regulations that ultimately also protect end consumers, both in our relationships with competitors and in our dealings with customers and suppliers; we impart the necessary knowledge in regular training courses and by providing individual advice to employees in the relevant areas of the company. On the other hand, we are a supplier to powerful trading companies and a customer of some very strong suppliers. In this respect, we may find ourselves in the role of the injured party in the event of unlawful price fixing and similar behaviour that violates antitrust law. This is why antitrust law is one of our main areas of specialisation.

For us as a company, the Supply Chain Due Diligence Act (LkSG) is ultimately about making a contribution to improving human rights and environmental conditions throughout the entire supply chain. Of course, we fully support this goal and have implemented a corresponding risk management system. However, some of the requirements set out in the law are very high and not always easy to implement in practice. However, the law is subject to the proviso of appropriateness and, in accordance with the LkSG, we pursue a risk-based, proportionate approach with regard to the duties of care imposed on us. It is hardly possible for us to monitor our suppliers one hundred per cent, especially those who supply us with raw materials from other continents. However, within the framework of our actions, we help to ensure that there are no violations of human rights and environmental damage both in our own business area and at our suppliers. Last but not least, this is also expected by our business customers, who are themselves subject to the LkSG and, among other things, require us to behave ethically through their sometimes very comprehensive supplier codes – just as we oblige our suppliers to comply with human rights and environmental protection through our own supplier code.”

“Our internal compliance guidelines are all available in German and Dutch and accessible to all employees. We visit all locations regularly and organise compliance training courses there. In addition, colleagues who are familiar with the relevant topics work at each location. We have established a well-functioning network with them in which we regularly exchange information. Our positive experiences show that we can rely on each other.”

“Of course, all of this also falls under the concept of compliance. After all, there are also numerous EU and national laws and regulations in these areas that need to be implemented and complied with. Just think of the Act on the Promotion of Pay Transparency between Women and Men (Pay Transparency Act) or the General Equal Treatment Act, to name just two examples. In these areas in particular, we work closely with the HR department and the works council, as there are naturally overlapping topics when it comes to implementation.”

“If you declare risk minimisation through forward planning, adherence to principles and the constant acquisition of knowledge to be principles of life, I think that’s a sensible approach to life.”