Global Compliance Organization
A global compliance matrix organization enables synergies on trainings and investigations under the leadership of the Head Human Resources, Legal & Compliance. The Corporate Compliance team consists of dedicated resources, who coordinate the Group-wide compliance initiatives.
Depending on the compliance topic concerned, the Corporate Compliance team is supported by the Regional HR Heads, Legal, or Controlling employees who act as part-time Compliance Officers. Together they represent Sika’s cross-functional Global Compliance Organization, which aims inter alia at preventing incidents of wrongdoings (fraud, bribery, and unfair competition etc.) by means of implementing targeted policies, trainings, audits, investigations, as well as disciplinary and improvement measures. A separate team ensures compliance with data protection and privacy regulations. Where required by local law, they are supported by a designated local Data Protection Manager.
Compliance Audit Program
Sika’s Compliance Management System rests on a life cycle of three closely interrelated core activities: Prevent – Detect – Respond & Adjust. To strengthen the “Detect” pillar, Corporate Compliance will continue the Compliance audit program in 2024. To assure proper records management and follow-up, a Group-wide audit tool will be used in coordination with other assurance functions.
Compliance audits focus on four specific risk areas:
- Ethical leadership and human rights
- Anti-bribery & corruption
- Anti-trust & fair competition
- Third party risks, including sanctions
The program enhanced compliance-related risks awareness, collaboration between the Regions and Corporate Compliance functions as well as the collaboration between Compliance and other insurance functions, such as Internal Audit, Legal, etc.
Communication of Critical Concerns, Open Door Policy, and Sika Trust Line
Sika promotes transparency and a speak-up culture around the world. The company encourages everyone to speak up openly about potential concerns or wrongdoings. Sika also grants every employee who speaks up in good faith protection against retaliation.
Concerns that can be reported include any violation of the Sika CoC and cover various aspects such as bribery; unfair competition; fraud (including theft, embezzlement, conflict of interests, etc.); environment, health and safety, quality or trade law violations; abusive labor or employment practices (including violations of human and labor rights, sexual harassment, discrimination, harassment, retaliation, etc.); or breach/misuse of confidential information (including violation of privacy protection laws) as well as conflict minerals.
Sika has established various channels for raising concerns:
Open door policy: the company promotes a speak-up culture that allows every employee to report any wrongdoing to his or her superior at local level, a local legal and/or compliance team member or to management on corporate level.
Sika Trust Line: this is an externally hosted web-based platform system that ensures safe and confidential reporting, with the option for anonymity. This platform is available globally for all employees and was opened to third parties (customers, suppliers, distributors, and other stakeholders) in November 2023 (testing phase), to go live in January 2024.
Alternative channels: concerns may also be sent by e-mail to Corporate Compliance ([email protected]), alter-natively via post. In selected geographic locations, and often based on local requirements, there may be additional independent points of contact to liaise on compliance concerns; this may include workers council representatives, or third parties such as professional ombudspeople or external legal counsel.
Third Party Due Diligence and Monitoring
In 2023, Sika tightened its Third-Party Due Diligence and Monitoring on a global level. On one hand, Procurement continued to implement Sika’s Supplier Code of Conduct across its supply base. The Supplier Code of Conduct prohibits any act of bribery or corruption, and states that such acts, if identified, will lead to the immediate termination of cooperation.
Every supplier is required to commit to this prohibition or demonstrate that it has similar internal rules reflecting a zero-tolerance policy to bribery or corruption. Suppliers are further required to have systems in place that ensure the proper communication training and auditing of their personnel and subcontractors to comply with Sika’s ESG requirements concerning human rights, labor standards and EHSQ across their own supply chain.
On the other hand, Procurement reviews supplier performance on a regular basis, thus monitoring whether Sika’s business partners indeed comply with the Group’s strict ESG requirements. Further, suppliers are obliged to immediately inform Sika of any known violation of its Supplier Code of Conduct.