Interview with Dirk-Stephan Koedijk, Member of the Henkel Sustainability Council for Compliance

Why is it important to have a compliance department? Can’t the employees be trusted to act in an ethically and legally appropriate manner?

Dirk-Stephan Koedijk: This is not a question of not trusting our employees! Rather, we consider it important to provide them with support and advice when they are faced with conflicts of interest, for example, in their day-to-day work. Compliance with laws and regulations is essential, to prevent damage to the company and to employees. Since we operate on a global scale, our employees are confronted with a variety of legal and value systems. It is not always easy to know how one should behave in a specific situation, as laws and cultural customs differ.

How can employees find out how they should behave?

Dirk-Stephan Koedijk: We have formulated rules on correct behavior that apply worldwide and that have been set down in writing in our Code of Conduct. Our codes and standards are binding for all employees at all sites, as well as for our suppliers and other business partners. We oppose any infringement of our standards, for infringements involve risks. A number of companies have suffered enormous damage because they did not adhere to law and order. We are convinced that only honest business is good business. Furthermore, unethical behavior such as bribery or horizontal agreements would virtually undermine our business model. Investing in marketing or research would then be of little use.

What options do you have to firmly anchor awareness of the importance of compliance?

Dirk-Stephan Koedijk: It is very clear that the best compliance organizations cannot be effective if employees do not develop a feeling for correct behavior. This is why we provide training for our employees all over the world on compliance topics. In 2010, 23,550 training sessions for employees were held, either online or in person, and lasting between two hours and two days. When such company-supported training programs are carried out, the rate of unintentional infringements drops. These infringements often result from conflicts of interest. In regard to gifts, for example, appropriate sensitivity is necessary to recognize bribery. We know, of course, that the interpretation of events and their subjective perception can differ greatly. For this reason, we offer training especially to employees going to specific countries, so that they are able to protect themselves and our company.

How can you ensure that compliance will be lived?

Dirk-Stephan Koedijk: We carry out regular audits and include our suppliers in our compliance checks. Our principle is zero tolerance, and this is not an empty phrase. Our corporate audit program also schools our top managers through regular training in our corporate standards and makes them aware that their behavior has a great influence on the employees. We should not forget that our managers have a special role. They must serve as an example and are obliged to act in an ethically and legally impeccable manner. Only then will compliance become a guide for the day-to-day actions of all employees.

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