Compliance

Corporate governance

Good corporate governance is an essential prerequisite of our long term business success. Our corporate governance is based on the current version of the German Corporate Governance Code promulgated by the Government Commission. We comply to a great extent with the requirements of the Code and explain any deviations from the Code in our Annual Report. Corporate governance also means ensuring that all our employees comply with laws, regulations and voluntary commitments. The core guidelines governing the way we do business are set out in our Code of Ethics, which describes the principles we expect all Linde employees to adopt when dealing with business partners, officials, colleagues and society. Issues covered in the Code of Ethics include not only corruption, antitrust law and protecting company secrets, but also human rights, safety standards, work standards and social standards. Our Group-wide compliance organisation helps us to fulfil our commitments in our day-to-day business.

Compliance organisation

Linde’s compliance organisation is led by the Chief Compliance Officer. He is supported by our Head of Compliance and compliance officers in the divisions, regions and business areas, whose job is to advise employees, provide training and handle compliance cases. The Executive Board and the Audit Committee of the Supervisory Board are regularly informed about activities of the compliance organisation and about progress achieved.

Prevention is key

Our objective is to prevent violations of laws and voluntary commitments. In our global compliance programme, we therefore especially rely on providing information, training and personal advice in the first place.

Information

We use various means of communication to ensure that our employees are always kept up to date. Our global intranet portal provides information about compliance and compliance guidelines in up to 29 languages. Regular intranet news items, e-mail bulletins and features in employee magazines keep our employees updated on recent compliance topics. We also involve the Executive Board in our communication measures relating to compliance.

As one of the signatories of the UN Call to Action: Anti-Corruption and the Global Development Agenda, Linde has joined other companies in demonstrating its commitment to the ongoing development of efficient anti-corruption measures.

Training

We offer training on compliance topics to our employees. New Linde employees get to know our compliance guidelines already during their induction process. Regular refresher courses complement our programme. Also, we provide targeted training on special topics to selected employees in relevant areas of the Group: for example, in 2015 around 10,000 staff took part in e-learning sessions on antitrust law. We also introduced a new e-learning programme in the reporting year for all executives and employees who award contracts for consultancy and other services on Linde’s behalf. More than 22,000 members of staff across the globe were provided with classroom-based training between 2009 and 2015. During the same period, employees completed more than 138,000 compliance training sessions.

Advice

We operate compliance hotlines where our compliance officers provide support to all our employees, regardless of their role or seniority. In 2015, our compliance officers received more than 6,700 requests for legal advice. Most of the queries related to the prevention of corruption (27 percent) and to antitrust law (25 percent). We also received queries about export control (24 percent) and data protection (14 percent).

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Compliance

 

 

 

 

 

 

 

 

 

 

 

2015

 

2014

 

2013

 

2012

Contacts Integrity Line

 

301

 

734

 

393

 

309

Investigations as a result of reports to the Integrity Line

 

141

 

127

 

88

 

77

of which referring to personnel topics (in %)

 

26.2

 

26.8

 

36.4

 

42.9

of which referring to potential offences against property (in %)

 

26.2

 

32.3

 

33.0

 

24.7

of which referring to potential discrimination (in %)

 

2.8

 

1.6

 

2.3

 

2.6

of which referring to potential conflicts of interest (in %)

 

13.5

 

9.4

 

12.5

 

15.6

Handling misconduct

We actively encourage our employees to ask for advice early if they have any concerns or doubts and to report any violations of our Code of Ethics, other Group guidelines or legal requirements. Staff members can approach their direct line manager or department head, or they can contact a representative from Internal Audit, Human Resources or Legal Services. We also have a global reporting system, the Linde Integrity Line, which enables employees and external stakeholders such as customers and suppliers to report suspected violations. We ensure that each case is examined and processed within a short period of time. In accordance with our internal guideline, we ensure that reports remain confidential and that data is protected.

In 2015, the Integrity Line was contacted 301 times in total. Most of the concerns expressed related to personnel issues (26 percent) or to offences against property (26 percent). There were also reports of potential conflicts of interest (14 percent) and of discrimination (3 percent). During the reporting year, the Internal Audit department, Human Resources, Legal Services and the department for Safety, Health, Environment and Quality conducted investigations of 141 cases involving suspected misconduct (2014: 127).

As part of our global compliance programme, we have processes in place to identify and deal swiftly with any misconduct. If Linde employees violate laws or regulations or fail to comply with the Group’s voluntary commitments, they must be prepared to face sanctions, which may include termination of employment. Violations may also give rise to criminal or civil proceedings. All the cases which have been reported via the Integrity Line and prove to be justified once they have been investigated entail consequences. In 2015, these consequences included training, warnings and dismissals. We apply the knowledge we gain from dealing with these cases to make further improvements to our compliance programme.