Ethics and Compliance
Our Code of Conduct requires all employees to comply with all laws and ethical standards.
As part of the risk management process for which the Board of Directors is responsible, Group risks are assessed twice a year in the Audit Committee. The most important points are then also reported to the Board of Directors and discussed as part of the general business risks. Material risks are systematically identified and recorded in a risk matrix.
At Group level, policies, processes, training, monitoring and continuous improvement measures are in place to maintain the highest level of ethics and compliance awareness among the workforce. Currently, Comet focuses on the following areas: (i) data protection, (ii) code of conduct, (iii) anti-corruption, and (iv) anti-trust.
Accountability for the implementation of these topics lies with the country general managers, while responsibility for it rests with the divisions. Compliance officers report to the country general manager and support the divisions and sites in implementing the compliance requirements. Where necessary, adjustments are made in accordance with legal requirements. The responsibility for issuing rules and guidelines for other compliance topics such as health protection and occupational safety lies with the respective country general manager, and these are implemented by the country GM of the division to which the site is assigned.
These structures and efforts are reflected in the fact that, in the year under review, we were not involved in legal proceedings nor were issued significant fines resulting from non-compliance with any laws or regulations.
When selling our products worldwide, we comply with a wide range of foreign trade laws and regulations. Under no circumstances may exports, brokering, transit or transfer by persons acting on behalf of the Company violate those trade laws and regulations. To ensure this, Comet has set up and implemented a Trade Compliance Policy which is integrated in the company’s management system, lists the essential requirements and defines the roles and responsibilities within the global organization. In addition, it is intended not only to promote and protect personal and corporate interests, but also to ensure compliance with regard to the various supply chains.
Under our management system, the country general manager is responsible for ensuring that trade in his or her country or region is conducted in accordance with Comet’s Trade Compliance Policy and applicable regulations. The organizational design and implementation are the responsibility of the country general manager. In order to meet the specific trade compliance requirements, a trade compliance officer is appointed for each country. This officer is responsible for trade compliance and is supported by trade specialists. The trade specialists and the trade compliance officer have the authority to stop transactions. We reinforce trade compliance through annual training for the appropriate employees.
In 2021, we were not defendants in legal proceedings nor were issued any significant fines for non-compliance with trade-related laws and regulations.