Integrity

We have applied an enhanced and consistent compliance policy since 2012. Our principles and ambitions remained unchanged and clear during the year under review.

Our ambition in this field is evidenced in the way in which we organize compliance internally. The key principle, of course, is that we comply with all applicable laws, regulations and ethical and social standards. We also operate a zero tolerance policy, which means we do not permit any breaches of integrity, whether our own employees or by third parties. Every report of major or small-scale potential breach is investigated. To qualify the zero tolerance policy, we have included a new KPI for integrity

Through this policy we aim to make the actions of our company and the actions in our company transparent. We also want to make our employees more aware of the importance of fair and ethical behaviour. We see compliance as part of our culture and of our dealings with each other. This applies to all parts of the company and this approach is promoted actively by all layers of our management.

Within our company the central control of compliance is assigned to the Chief Compliance Officer, who reports directly to the Board of Management and the Supervisory Board. On a decentralized basis the compliance officers in our business units and in our projects are actively engaged in the practical fulfilment and application of our policy.

Under the leadership of the Chief Compliance Officer we are continuing to develop and expand our compliance policy. This involves actively propagating our framework of standards and values, as set out in the code of conduct. After all, alertness requires regular attention. For this purpose the compliance officers will give presentations to employees in their units. By discussing cases and dilemmas with each other we ensure that compliance remains a live subject and one that is more tangible for all employees.

For more information, we refer to our integrated annual report.