The core of a successful compliance programme lies in a reliable risk management process, based on risk analyses in conjunction with the early detection of risks and the provision of measures. The risk management process was evaluated in 2014 with focus on fraud and corruption risks to ensure that these two aspects of risk management were sufficiently covered by the programme. All operational business has assessed their risks, including corruption risks such as those related to subcontractors, sponsors but also very general in relation to the understanding of governing documents. Proposed improvements have been implemented.
Our company’s current assessment process was amended to achieve a higher transparency on fraud and corruption risks. An extra effort has been taken to define countries that we consider as high risk countries for DNV GL. For these countries we will define and implement additional preventive measures on fraud and corruption.
Our Code of Conduct
Following the merger between DNV and GL, a new joint Code of Conduct was prepared with the involvement of relevant internal stakeholders and adopted in September 2013. The Code of Conduct was presented to the Audit Committee in December 2013 and was approved by the Board of Directors in February 2014. Every employee received a printed copy of the Code of Conduct. In addition an e-Learning module on the Code of Conduct was prepared requiring the trained to confirm understanding of the contents. In 2015, the e-Learning module will be rolled-out as mandatory training for all employees. Further training initiatives on the Code of Conduct will follow regularly.
Our Code of Conduct is at the heart of our compliance programme and contains rules that apply throughout the company. Our CEO strongly maintains that all employees have to observe all laws and regulations and emphasizes the importance of the Code.
Wherever we go, our behaviour as representatives of DNV GL will be remembered. Of course, we must comply with the local laws and regulations of the places in which we operate, but we believe that doing the right thing goes beyond that. This is why we have a Code of Conduct – to outline principles for what we in DNV GL consider to be ethical behaviour, for both the conduct of our business and our personal conduct.
Read our Code of Conduct
The section on the conduct of business addresses several topics, such as quality, conflict of interest, the competition conduct, corruption and gifts, working environment, environmental stewardship, confidentiality and risk management. The personal conduct addresses the expectation to conduct ourselves and our business with respect and sensitivity. It covers aspects such as independence, impartiality and integrity and communication. Furthermore, the code contains a chapter on how to report violations or concerns of a violation of the Code of Conduct.
Instructions on anti-corruption and on gifts and hospitality set the framework for all managers and employees and provide clear internal guidance for everything we do.
The instruction on subcontractors, agents and other intermediaries was implemented to ensure a proper selection and contracting process before we start working with them. This includes the assurance of an appropriate integrity level.
We believe that communication and training are key elements in establishing a successful compliance programme which is endorsed by all our personnel. Communication has to be channelled through the top management and line management in order to show their commitment to our programme in close cooperation with the Group Compliance Officer. The Compliance Officer has presented and discussed the compliance programme with the Board of Directors and the Board Audit Committee, the Executive Committee and the Executive Leadership Teams.
We have established worldwide compliance networks, consisting of all Country Chairs and business nominated employees. Their role is to actively raise awareness for compliance issues in their respective countries across the business areas and to facilitate the communication in relation to compliance matters.
In 2014, all Country Chairs have been addressed and informed about the compliance programme.
Group Compliance offers to all employees around the world the opportunity to ask questions about the compliance programme and how its policies and instructions should be understood and practically applied including local requirements. The team ensures that questions are answered accurately and with the help of experts, if necessary. Through this we help our employees in clarifying compliance relevant issues in advance, but at the same time questions on compliance matters are important indicators of topics that are currently of particular importance to our employees in this respect.
In recent years, all our employees have carried out mandatory e-Learning trainings on anti-corruption. In 2014, new web-based training modules were implemented on the new Code of Conduct and on anti-corruption and anti-trust measures.
The training module related to the Code of Conduct was created to enable our employees to carry out their duties in an ethical and responsible manner. Going through this training, they will recognize the importance of the topics addressed in the Code and acknowledge their personal responsibility to follow the Code. They are trained to make the right decisions in ethical and compliance matters.
The second training module provides insight into the definition of corruption and anti-trust in order to make our employees aware of possible risks, of how to identify critical situations, and of how to deal with them.
Both training modules include sections on the process of reporting misconduct and our employees also have to confirm that they have read and understood the Code of Conduct.
The new training modules were made mandatory for new employees and will become mandatory for all employees in the course of 2015. By the end of 2014 approximately 1200 employees completed the trainings, including those employees who did it voluntarily. For new employees, the trainings have to be completed within the first six months after entering DNV GL. The statistic in table 1 includes also those employees who started in the second half of 2014 and were therefore not obliged to finalize the training until the end of the year.
New employees have to attend the classroom training “We in DNV GL” as part of their introduction programme. This course also includes an introduction to our compliance programme.
Furthermore, we conducted a number of workshops and classroom trainings in several locations throughout the world on all relevant topics, such as corruption and anti-trust.
In the course of the implementation of a new instruction on subcontractors, agents and other intermediaries in the beginning of 2015, measures with regards to the communication towards business partners and suppliers will be initiated.
See table 1 for completion rates of module 1 and of module 2 per business area of all new employees in 2014.