Sound business ethics and competition
The Group’s Code of Conduct stipulates that corruption and bribery are unacceptable. The objective of Trelleborg’s mandatory Code of Conduct training is that all employees must be familiar with its contents, and a large section deals clearly with bribery/corruption. Trelleborg’s Code of Conduct and related training for all employees also contains specific sections on competition.
According to the review of Trelleborg’s total risk scenario, which led to a vision for Trelleborg’s risk management, combating corruption is a prioritized area. A procedure has been implemented whereby the relevant employees sign an “Acceptance Letter” from the President on an annual basis.
An international survey conducted in 2007 by Transparency International claims that the countries listed below, and where Trelleborg is active, hold the greatest potential risks for corruption, with an emphasis on bribery.
Romania, India, Indonesia and Lithuania.
The Group also has a specific program that addresses competition (Trelleborg Competition Law Compliance Program) which communicates the Group’s clearly formulated policies, training, e-learning on the intranet and a newsletter. The company also has a general Whistleblower Policy, which can be used by all employees if they suspect irregularities.
The Group’s General Counsel also functions as Compliance Officer, responsible for implementing, supporting and developing the Group’s action program in the area of competition. The program, which is monitored and reported back to the Board, includes a review of agreements in particularly vulnerable environments, legal reviews of subsidiaries and a review of trade organizations. Procedures for approving membership in organizations are also established.
In addition, the program focuses on ensuring that everyone in the organization understands how competition law works, what is legal/illegal and that cartel behavior is entirely unacceptable in the Trelleborg Group.
- The Group’s senior executives (about 150) have received a separate presentation of these regulations.
- All relevant employees shall confirm in writing that they have read and understood the company’s policy.
- All managers must participate in competition seminars and individual certificates will be issued.
- Since 2006, more than 60 training seminars with more than 1,200 managers in the primary target group have been held, of which more than a dozen took place in 2011.
- All new managers must participate within six months of employment.
In 2010, as part of an agreement with the United States Department of the Navy, Trelleborg held the Trelleborg Corporation Enhanced Compliance and Training Program to further enhance knowledge of competition law among the Group’s employees in the US. For more information about measures for combating corruption see Competition investigations and Risks in the Corporate Responsibility area.