Ethics and Compliance

Ethics and compliance are critical pillars of Comet’s success and integrity. While ethical standards define the moral behavior of a company, compliance refers to adherence to legal regulations. Meeting ethical and compliance standards is not only a necessity, but also a key element in maintaining the trust and loyalty of all stakeholders. Failure to comply with these standards can have serious legal and financial consequences, such as the loss of business opportunities or lengthy and expensive legal disputes, but also long-term reputational damage and therefore a loss of trust among customers, investors and other stakeholders.

Ethical behavior and compliance with laws and internal policies and specifications are non-negotiable. Our Code of Conduct therefore obliges all employees to comply with all laws and ethical standards. By using a reporting system called “Integrity Line”, our employees can quickly and easily report concerns about actual or suspected misconduct that can affect our company or the wellbeing of people.

As part of the risk management process, for which the Board of Directors is responsible, the Group’s risks are assessed twice a year by the Audit Committee. The most important points are 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 ensure the highest level of ethics and compliance awareness among the workforce. Comet currently 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 respective country general manager, while responsibility for it 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 General Manager of the division to which the site is assigned.

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

Trade compliance is crucial in international business. It refers to compliance with all relevant laws and regulations governing trade between different countries. This includes customs regulations, export controls, sanctions and anti-corruption laws.

When selling our products worldwide, we comply with a wide range of laws and regulations. Under no circumstances may exports, brokering, transit or transfer by persons acting on behalf of our company violate these laws and regulations. It is of utmost importance that Comet and its products comply with all standards and requirements related to business, ethics, quality, and supplier and consumer protection. Failure to comply with these rules and regulations may result in delays in shipments to our customers, severe financial losses through fines, and other penalties imposed by international regulatory authorities. Non-compliance with trade regulations can also be perceived as a lack of integrity or as irresponsibility and affect the trust of customers, investors and business partners.

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 serves not only to promote and protect personal and corporate interests, but also to ensure compliance in 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. 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 courses for the appropriate employees.

Trade compliance is crucial for the long-term success and sustainability of a company. It not only protects against legal and financial risks, but also strengthens trust and credibility among stakeholders. In an increasingly complex and regulated global economy, it is important that companies take proactive measures to ensure their business practices comply with trade regulations. By complying with these regulations, companies can minimize risks, protect their reputation and place their business activities on a solid and sustainable footing.

In 2023, we were not defendants in any legal proceedings nor were issued any significant fines for non-compliance with trade-related laws and regulations.