Ethics and Compliance

Our Code of Conduct requires all employees to comply with all applicable laws and ethical standards.

The Board of Directors is responsible for the risk management process. As part of this process, 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 policies 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.

The value of these structures and efforts is 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.

Trade Compliance

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. It is of utmost importance that both Comet as a company, and our products, comply with all standards and requirements related to business, ethics, quality, supplier and consumer protection. Failure to comply with these rules and regulations may result in delays in shipments to our customers, severe financial losses and other penalties imposed by international regulatory authorities. To ensure compliance, 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 2022, we were not defendants in legal proceedings nor were issued any significant fines for non-compliance with trade-related laws and regulations.