Sika is pursuing a holistic approach to compliance, and its compliance management system involves the whole organization throughout hierarchies, functions, and geographical areas. The Sika compliance management system aims to ensure that governance, risk management, and other structures and processes within the Group are not only compliant with regulatory requirements, but also as effective as possible within the organization to mitigate risks and prevent financial losses.

 

STRENGTHENING OF THE SIKA COMPLIANCE ORGANIZATION

During 2018, Sika further strengthened the Compliance organization. The Compliance Officer held the annual Compliance Circle at Sika’s headquarter, in August. Purpose of this meeting was to align the team, exchange experiences and develop shared knowledge with the aim to implement a consistent program throughout the Group.

As of January 1, 2019 a new Head of Legal & Compliance for the Global Business was appointed and joined the Compliance team. Complementary to the regional and area level, Local Compliance Officers support compliance initiatives and give guidance to business in compliance-related matters on local level. The Compliance Team provides guidance to the Group on compliance matters, develops new tools and procedures, addresses compliance cases with the support of other corporate functions having compliance responsibilities (HR, Controlling, EHS, Quality, Procurement, etc.) and always in close cooperation with line management. Regional Compliance Officers and Local Compliance Ambassadors operate in close cooperation with the Regional Managers, Area Managers and GMs.

 

GLOBAL AWARENESS RAISING CAMPAIGN

In 2018, as part of the internal Global Awareness Raising Campaign on Compliance, Sika progressed in the roll-out internal Global Awareness Raising Campaign on Compliance, covering additional 24 countries and training more than 7,000 employees in the different regions. The Global Awareness Campaign focusses on a Code of Conduct e-learning program, and the Sika Trust Line, an internal web-based platform for reporting serious misconducts.

 

AWARDS FOR BEST COMPLIANCE TRAINING

In 2018, the e-learning program on the Code of Conduct earned the “Silver” Brandon Hall Award in the “Best Compliance Training” category. It was a great way to benchmark the effectiveness of Sika’s compliance training against peers through an independent jury. This confirms Sika is doing the right thing, focussing its investment on its employees through high quality compliance training to preserve Sika’s strong ethical culture.

 

COMPLIANCE CASES

For the first time, Sika has consolidated an overview of all compliance cases addressed in 2018, at any level, throughout the organization. The total number of compliance cases in 2018 is in total 30 (3 are still under investigation), which is a very low number, considering the size of the Group. Our employees are the most effective channel to detect violation, which proves that transparency is a key value at Sika and needs to be preserved. Dismissals (and two resignations) confirm a zero tolerance culture and consistency in remediation. Conflict of interest and internal fraud are most recurrent types and (local) management being the most exposed Group. Out of five alleged misconduct cases submitted through the Sika Trust Linein 2018, two were not substantiated. There has been no case of abuse or misuse of the new reporting platform.  

 

CODE OF CONDUCT

In the year under review, Sika has increased the number of languages in which the Code of Conduct is available from 32 to 36.  All 36 official translations of the Code of Conduct are available and accessible internally on the Corporate Policies and Manuals page on SikaConnect (internal collaboration platform) and SikaWorld (intranet).

 

COMPLIANCE CONFIRMATION, COMMITMENT, AND CHECKLIST 2018 (COMPLIANCE AUDITS)

Each fiscal year General Managers of all Sika companies confirm compliance of the corresponding Sika Company with the Code of Conduct principles, including information to and training of all staff. This annual confirmation allows Sika to receive assurance that the business had been conducted throughout the organization in compliance with the Code of Conduct principles, with particular focus on the following specific topics: environment, anti-corruption, anti-trust, and human rights assessments. New General Managers and new Sika Senior Managers have confirmed their pledge to lead with integrity by signing the “Compliance Commitment 2019”. All GMs and Sika Senior Managers have renewed their Compliance Commitment every two years.

 

TRAININGS

More than 300 managers have been trained by the Group Compliance Officer. With regard to compliance trainings, Sika continues to align the content of the Sika Business School to enhance ethical leadership. In 2018, several cross-functional trainings initiatives at regional and local level informed about the importance of the Code of Conduct, an introduction on the new compliance organization, and the main tools available to support management in mitigating risks were part of the program. To enhance the post-acquisition integration on Compliance of two major big acquisitions closed in 2018, around 1,000 employees of the FAIST Group and Index in Italy were aligned with Sika’s compliance policy framework and trained on compliance risk and available tools.

 

COMPLIANCE AUDIT PROGRAM

A proposal to introduce a Compliance Audit Program covering anti-corruption, antitrust, third parties screening and ethical leadership in under review. During 2019, the Compliance function will define the most effective plan, tailored to the organization’s needs, in close cooperation with Group Management and subject to the approval of the Audit Committee.

Inspections and audits

Inspections and audits are core elements of Sika’s comprehensive management system. They provide management at Group, regional, and local company level with a regular, independent assessment on whether activities in scope comply with official requirements, as well as with Sika’s own internal guidelines, principles, and risk management specifications. The inspections and audits thereby ensure the effectiveness of the relevant processes and controls at Sika.

Audits are performed by various assurance functions across the group covering quality, environment, safety, health, risk, technology, application, legal and compliance, branding, IT security, suppliers, and products. The results and subsequent corrective actions of these audits are regularly presented to the Group Management. Besides those assurance functions, an independent Corporate Internal Audit function, reporting to the Audit Committee of the Board of Directors, validates the effectiveness of internal controls in both legal entity audits and reviews of group processes and functions. In total, Sika conducted 182 audits, including local supplier audits, and implemented associated improvements wherever necessary.

To ensure that suppliers also meet the official requirements and labor standards, they are asked to perform self-assessments. In addition, when needed, Sika performs supplier audits. In the year under review, all new suppliers were assessed according to the vendor evaluation process. Most of these audits are reviewed by safety, quality, or technology experts. This enhances continuous improvements in collaboration with suppliers, including sustainability aspects.

Being key customer supplier in automotive and industrial sectors, Sika is regularly subjected to external audits. These audits are designed to ensure compliance with international labor standards and quality, environment, safety, and health requirements.