Governance
Anti-corruption
We reject all forms of corruption and shape a business environment based on trust and integrity.
Bribery and corruption are one of the largest compliance risks in KAEFER’s business model. Our dealings with third parties, their decision makers and employees, must be characterised by competence, reliability and trust.
Our motivation
Everyone at KAEFER influences and shapes the company on a local as well as global scale. Our diversity implies a variety of cultures, legal forms and moral norms. At the same time, a shared commitment to our values is essential to transcend the borders of the individual KAEFER countries, based on trust and a common set of norms. We are convinced that corruption jeopardises business relations, distorts competition and endangers our existence.
As a result, KAEFER is strongly committed to risk management and compliance, which we define as a set of guidelines, rules, and procedures that are designed to prevent, monitor, and resolve conducts or practices that go against legal, ethical, and business standards. This not only protects our clients, employees and society as a whole, but also contributes to the security of our company against white collar crime.
Actions
Sustainability commitment To maintain our annual risk assessment process for corruption risks and continue improving our prevention and mitigation measures for elevated risks
We operate an appropriate and effective Compliance Management System (CMS) based on the pillars “Prevent, Detect, Respond”. First and foremost, we want to prevent misconduct or violations. Where misconduct occurs, it needs to be detected as quickly as possible, so that we can respond.
We continually review and improve our CMS to ensure it remains fit for purpose. In 2022, we initiated several improvements following an analysis of the results of our global compliance survey a year earlier, including taking measures to increase awareness of KAEFER’s Compliance Helpline.
Annual group-wide compliance risk assessments targeting all entities allow us to focus resources more effectively to counter material risks, with the result that KAEFER’s overall exposure to compliance risks in 2022 was significantly lower than in 2021. Based on the findings, measures were defined and implemented for each entity. These individual assessments add up to an overall compliance risk profile for KAEFER.
2022 results indicate that risks, for example on corruption and fraud, are handled appropriately under the system as it currently operates. New group-wide measures have been defined to improve our processes around the disclosure of business / confidential information and the risks posed by unethical or illegal behaviour among our suppliers and/or subcontractors.
Outlook
With increasing globalisation, a more connected world, ongoing digitalisation and the current global political challenges, we are constantly faced with a growing number of new regulations and laws to comply with. Therefore, the design and appropriateness of KAEFER‘s CMS according to IDW Ass 980 in connection with ISO19600 will be audited by an external party at the beginning of 2023.
In addition, an internal and external communication campaign will focus on KAEFER’s Compliance Helpline and its recent updates (e.g. its use as a grievance mechanism for the Supplier Code of Conduct).
Performance disclosure
Code of Business Conduct (e-learning)
thereof senior management level
Code of Business Conduct (offline)
Anti-Corruption
thereof senior management level
Anti-Trust
Conflicts of Interest
thereof senior management level
Fraud Prevention
We understand training measures as part of the overall communication on the topics mentioned above. Trainings for relevant employees (target group) are to be refreshed every two years at minimum, each entity has own rhythm for trainings, based on local needs and circumstances. Therefore, the figures may vary in some countries as some trainings started at the end of the year thus resulting in lower participation rates at the effective reporting date.
Compliance training was established at KAEFER in 2018 and has been regularly expanded and supplemented ever since. Refresher sessions on the Code of Business Conduct took place in all entities in 2022. In addition, a new e-learning module dealing specifically with fraud prevention, was introduced and rolled out in all entities.
These training modules are carried out at KAEFER via e-learning or in person. This e-learning was developed by KAEFER and tailored to the needs of the learners. It is available in thirteen languages. For employees without a company e-mail account, compliance training takes place in person, e.g. during Toolbox Meetings (pre-start or regularly scheduled meetings for the workforce on site), making use of compliance booklets and training material produced for this purpose.
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