Compliance with competition laws and anti-corruption principles
The Code of Conduct requires compliance with laws at all levels of the Group and follows a zero tolerance policy with regard to breaches of competition law. The Code of Conduct also includes guidelines regarding corruption. Kemira does not tolerate any corruption and is not involved with bribery. Kemira and its employees must never offer, solicit or accept a bribe in any form. As of January 1, 2013, Kemira has a new group-wide policy, the Kemira Group Gifts, Entertainment and Anti-bribery Policy, in place. The policy defines what kind of business gifts or hospitality Kemira employees can offer or receive, and helps to ensure that Kemira and its employees comply with the Code of Conduct and the relevant local anti-bribery and anti-corruption laws.
Furthermore, the Code of Conduct, as well as the Kemira Group Gifts, Entertainment and Anti-bribery Policy, prohibit financial support to politicians, political parties or political organizations. The main channels for Kemira to contribute to public policy development are contributing to the work of the relevant trade and industry associations.
At Kemira, there were no pending or completed legal actions initiated under national or international laws designed for regulating anti-competitive behavior, anti-trust, or monopoly practices in 2012. However, Kemira is a defendant in certain legal proceedings in which damages are sought for violations of competition law. Such proceedings are described in Kemira’s Financial Statements under the heading Litigation.
Competition Law Compliance Policy training
Kemira's global Competition Law Compliance Policy is approved by the Kemira Board of Directors and communicated to the senior management and key persons working in sales, marketing, sourcing, procurement and other similar functions through a comprehensive, ongoing, and regularly repeated training process. In 2012, 751 persons were trained (2011: 895). The annual variation in the number of training participants is due to the training cycle, which is slightly longer than one calendar year.
Audit and Internal Control
At Kemira, an internal audit plan is generated annually. The plan is based on relevant criteria and approved by the Board of Directors’ Audit Committee. Internal audits are conducted in the Kemira Group according to the approved audit plan.
The adequacy of internal control systems and commitment to the Code of Conduct in the Kemira Group companies and units is assessed annually by the Global Internal Control Survey. The survey is sent to managing directors, the chief financial officer, and as of 2012, to other managers in the Kemira Group companies. In 2012, the Internal Control Survey was sent to 193 employees (2011: 108).
The findings of the audits in the Kemira Group and the Internal Control Survey conducted by the Group Internal Audit during 2012 indicate no incidents of corruption within the Group in 2012.