Governance topics
We are committed to ethical and legally compliant behavior in everything we do. Every single point of our Code of Conduct is non-negotiable. The individual behavior of each of us – how we interact with colleagues, customers, suppliers, and all other stakeholders – determines our success as a company. The values and principles of the Code of Conduct developed in 2020 and updated in 2024 form the foundation of our corporate culture and the basis for all our actions and decisions.
Strict and full compliance with laws, guidelines and regulatory standards at the local, national, and international level is not only the right thing to do, but also an important asset on which our reputation is based. Equally important is the ethical conduct of all individuals and partner organizations we collaborate with, which reinforces our commitment to integrity and trust. All internal and external stakeholders can rely on us to always treat them fairly and ethically. Practicing and upholding proper business ethics is an integral part of our relationships with each other, with our customers, with our suppliers, with our investors and even with our competitors. Ethical behavior is a crucial basis for building trust and ensuring the success of our company. We require all Comet employees to adhere to our Code of Conduct. To ensure that every employee understands the content of our Code of Conduct, we introduced mandatory compliance training some time ago, which every Comet employee must complete on a regular basis.
Ethics and compliance
Ethics and compliance are foundational to our success and integrity. Ethical standards guide moral behavior, while compliance ensures adherence to legal regulations. These principles are critical for maintaining stakeholder trust and loyalty. Our Code of Conduct mandates compliance with laws and ethical standards for all employees. A key component of this policy is the Integrity Line, a reporting system that enables employees to report concerns about actual or suspected misconduct confidentially and securely.
Our risk and compliance management is structured to ensure accountability and alignment across all levels of the organization, from local sites to the Group level. The Board of Directors plays an overarching role, overseeing the risk management process and ensuring that the organization proactively addresses key challenges. The Audit Committee, a specialized body within the Board, conducts biannual risk assessments and reports significant findings, ensuring transparency and strategic oversight.
In February 2024, the Audit Committee appointed an in-house Group Head of Audit, Risk, and Compliance. This role is responsible for overseeing the Internal Audit function, managing the enterprise risk management (ERM) process across the Comet Group, developing and maintaining a Group-level compliance management system (CMS), and operating our global integrity hotline. In 2024, Comet’s Internal Audit function conducted eight audits, focusing on corporate governance, compliance with internal and external regulations, risk management, and the design and effectiveness of internal control frameworks.
At the operational level, country general managers are responsible for implementing compliance requirements and issuing policies on critical areas such as health protection and occupational safety. They ensure alignment with local regulations, safeguarding the welfare of employees and adherence to legal standards. Compliance officers, reporting to the country general managers, provide on-the-ground support to divisions and sites. Their role includes monitoring compliance obligations, assisting in policy implementation, and ensuring that local practices meet both regulatory and corporate standards.
We have implemented policies, processes, training, and monitoring measures at the Group level to promote ethics and compliance awareness among employees. The Integrity Line reporting system allows employees to report concerns about actual or suspected misconduct easily and anonymously. Adjustments to compliance measures are made as needed to meet evolving legal requirements.
As part of our risk management process, material risks are systematically identified and recorded in a risk matrix. Key risks are discussed by the Board of Directors in the context of general business risks. The Group also continuously enhances compliance through policies, training, and improvement measures.
In the year under review, we were not involved in any legal proceedings, nor were fines imposed due to violations of laws or regulations or due to corruption. These outcomes reflect the company’s strong commitment to maintaining high ethical and compliance standards.
Technical compliance
Technical compliance refers to the adherence to regulations, standards, and requirements related to both materials and products throughout their lifecycle. It ensures that a company’s operations and products meet legal and industry-specific guidelines.
Materials compliance means compliance with certain standards and specifications in the selection and use of materials in products and processes. These standards can relate to various aspects, such as quality, safety, environmental sustainability, and health risks. For Comet as a manufacturer of industrial products, an indispensable requirement for doing business worldwide is compliance with regulations relevant to the environment and to market access – such as Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), Restriction of Hazardous Substances (RoHS), and the Toxic Substances Control Act (TSCA) – as well as with legislation driven by international law and ethics, including conflict minerals legislation, the Dodd-Frank Act and Regulation (EU) 2017/821.
Product compliance pertains to the final product meeting all legal and industry requirements for safety, functionality, and environmental performance. This includes certifications, labeling, and documentation proving that the product aligns with relevant standards, such as CE marking, FDA approval, or ISO standards. Product compliance guarantees that products are safe for use and meet the quality expectations of markets and regulatory bodies.
Together, materials and product compliance ensure that the entire process from sourcing to final delivery adheres to rigorous legal and quality standards, supporting a company’s commitment to sustainable and responsible business practices.
Report on conflict minerals
In accordance with the “Ordinance on Due Diligence and Transparency with regard to Minerals and Metals from Conflict-Affected Areas and Child Labor (DDTrO) of 3 December 2021 (status as of 1 January 2024)”
Comet is dedicated to maintaining a high-quality, compliant supply chain that meets product standards and ethical expectations. As described in detail in Comets Quality Management System, our purchasing department evaluates new and existing suppliers, emphasizing sustainable practices and adherence to our Supplier Code of Conduct. As part of our due diligence process, we partner with Assent Compliance Inc. to collect data for REACH, RoHS, Conflict Minerals, and TSCA compliance. Non-compliant suppliers are contacted for corrective action and may face termination if necessary.
Comet imports raw materials and semi-finished products into Switzerland for use in various industrial processes in the semiconductor and non-destructive testing industries. In 2024, we imported 908 kg of tungsten classified under customs tariff number 8101 99 00, exceeding the exemption limit of 350 kg, and thus subject to due diligence requirements per Swiss DDTrO, annex 1, part B. Tungsten and its alloys are mainly used by the Industrial X-ray Modules division as anodes and cathodes in x-ray tubes, added in small amounts to create alloys for electronic components and machining tools.
Comet complies with due diligence under:
- Regulation (EU) 2017/821 and Delegated Regulation (EU) 2019/429
- Dodd-Frank Act Section 1502 on Conflict Minerals
Although Comet is therefore exempt from due diligence obligations under DDTrO, article 9, the company implements a structured five-step workflow to monitor suppliers for conflict minerals. This process commences with an annual supply chain campaign conducted by Assent. Comet subsequently reviews the Conflict Minerals Smelters Report, identifies high-risk smelters, and documents follow-up actions within its management system. The purchasing team engages suppliers to request corrective measures and verify conflict-free sourcing. Updated Conflict Minerals Reporting Templates are uploaded, and ongoing compliance is maintained through regular follow-ups, including annual reviews prior to reporting deadlines. Persistent non-compliance is escalated, and suppliers are reassessed as needed.
During the reporting period, all three current tungsten suppliers signed the Comet Supplier Code of Conduct. At the time of writing of this report, one of the suppliers that was added to Comet’s supplier list during the reporting year had not yet submitted the Conflict Minerals Reporting Template. However, this was being monitored by the quality manager responsible. We confirm that, in 2024, the due diligence process was conducted as described, and no complaints were reported through our publicly available whistleblower system.
Our commitment to technical compliance reduces risks such as health hazards, environmental damage, and potential legal or financial consequences due to non-compliance. Regular training is provided to employees involved in technical compliance to ensure understanding of regulations and the impact of non-compliance.
Compliance responsibilities are outlined in the Comet Group’s management system. The Vice President of Global Operational Excellence (VP GOE), who reports directly to the CEO, sets compliance regulations with input from Group legal experts. The divisions are responsible for implementation, with oversight by the country general managers. Global coordination of materials compliance activities is managed by the Quality & Excellence Board.
This comprehensive structure ensures consistent practices and adherence to regulatory requirements, thus supporting product quality and minimizing risk.
Trade compliance
Trade compliance ensures adherence to laws and regulations governing international trade, including customs regulations, export controls, sanctions, and anti-corruption laws. Comet’s Trade Compliance Policy, integrated into the Comet quality management system (CQMS), outlines essential requirements and defines roles and responsibilities. This policy ensures that Comet’s operations meet global standards for business, ethics, quality, and supplier and consumer protection. Non-compliance can lead to shipment delays, financial losses, regulatory penalties, and damage to Comet’s reputation.
At Comet, trade compliance is managed through a structured approach that ensures clear accountability and authority across all regions. Country general managers are responsible for implementing the Trade Compliance Policy and ensuring adherence to trade regulations within their regions. They are supported by trade compliance officers, appointed for each country, who oversee compliance activities and collaborate closely with trade specialists. Trade specialists are empowered to halt transactions that do not meet regulatory standards. This organizational framework ensures effective oversight and alignment with global trade compliance requirements.
We ensure robust oversight of trade compliance through a structured monitoring system. Country general managers oversee compliance within their regions, supported by trade compliance officers and specialists, who actively monitor transactions and are empowered to halt any non-compliant activities. This proactive approach mitigates risks and ensures adherence to international trade regulations.
In 2024, Comet reported no legal proceedings or fines related to non-compliance with trade laws. This outcome highlights the effectiveness of the Trade Compliance Policy and reaffirms our commitment to meeting global trade standards.