Corporate Governance and Compliance

Compliance organisation
  • Global Code of Ethics
  • Compliance policies
  • Guidance from international standards
  • E-learning
  • Face-to-face training
  • Advice by Compliance Officers
  • Follow up on reports of misconduct
  • Monitoring of actions taken (consequence management)
  • Cooperation with authorities

Good corporate governance is an essential prerequisite of our business success. Our corporate governance is based on the German Corporate Governance Code. 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 compliance with laws, regulations and voluntary commitments. The core guidelines governing the way we do business are set out in our Code of Ethics. This describes the principles we expect all Linde employees to adopt when dealing with business partners, officials, colleagues and other reference groups. Issues covered in the Code of Ethics include not only corruption, antitrust law and the protection of company secrets, but also human rights, safety standards, labour standards and social standards. Our global compliance organisation helps us fulfil our commitments in our day-to-day business.

Moreover, we are a signatory to the United Nations Call to Action: Anti-Corruption and the Global Development Agenda. This means that we have joined other companies in demonstrating a commitment to the ongoing development of efficient anti-corruption measures.

Compliance organisation

Our compliance organisation is led by the Head of Group Legal & Compliance. In the regions and business areas, the implementation of the compliance management system is supported by compliance officers. Their tasks include advising employees, providing training and conducting interviews with employees on compliance risks. The Head of Group Legal & Compliance provides regular reports to the Executive Board and the Audit Committee of the Supervisory Board on the activities of the compliance organisation.

Prevention is key

Our objective is to prevent violations of the law or of internal guidelines. In our global compliance programme, we therefore rely especially on providing information, training and personal advice.

We use various communication channels to keep our employees up to date. Our intranet is our basic form of communication. Here, our employees worldwide are able to access information about compliance and about our compliance guidelines in up to 29 languages.

Our range of training opportunities includes classroom-based training and e-learning courses. We provided classroom-based training to around 28,000 members of staff across the globe between 2009 and 2017. Of these, around 4,000 received this type of training during the reporting year. Between 2009 and 2017, employees completed some 195,000 e-learning training sessions. Around 38,000 of these were in 2017. Subjects covered by the training included the Code of Ethics and the guideline on business partners. We also conduct training updates at regular intervals. In the reporting year, for example, we provided our employees with specific information about dealing with antitrust law in order to raise awareness of the subject.

We operate compliance hotlines where our compliance officers provide support to all our employees, regardless of their role or seniority. In 2017, our compliance officers received around 8,500 requests for legal advice. Most of the queries related to the prevention of corruption (21 percent) and to antitrust law (23 percent). We also received queries about export control (33 percent) and data protection (15 percent).

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In line with the information in the Financial Report 2017, the figures provided for the years 2015, 2016 and 2017 exclude the business of the logistics service provider Gist, as it has been reported as a discontinued operation.

Lagebericht 2014

Included in the audited Non-Financial Report

Contacts Integrity Line



Lagebericht 2014 351


Lagebericht 2014 348







Investigations as a result of reports to the Integrity Line



Lagebericht 2014 94


Lagebericht 2014 106







of which referring to personnel topics



Lagebericht 2014 32.1


Lagebericht 2014 30.1







of which referring to potential offences against property



Lagebericht 2014 24.1


Lagebericht 2014 30.7







of which referring to potential discrimination



Lagebericht 2014 1.2


Lagebericht 2014 1.3







of which referring to potential conflicts of interest



Lagebericht 2014 16.7


Lagebericht 2014 15.0







Dealing with misconduct

We want to identify and deal swiftly with any misconduct and we therefore have processes in place to do so. Moreover, we actively encourage our employees to ask for advice early if they have any concerns and to report any violations of our guidelines or of legal requirements via our global reporting system, the Linde Integrity Line. Employees and external third parties such as customers and suppliers can use the Integrity Line to report suspected violations, anonymously if they so wish. We ensure that each case is examined and generates a response. Our Integrity Line guideline governs the processes required.

In 2017, the Integrity Line was contacted 351 times in total (2016: 348). There were 94 cases (2016: 106) involving suspected misconduct. Most of these related to personnel issues (2017: 32 percent; 2016: 30 percent) or to offences against property (2017: 24 percent; 2016: 31 percent). We also investigated reports of conflicts of interest (2017: 17 percent; 2016: 15 percent) and of discrimination (2017: 1 percent; 2016: 1 percent).

Linde employees who violate our guidelines or legal regulations must be prepared to face sanctions. All the cases which have been reported via the Integrity Line and prove to be justified once they have been investigated entail consequences. In 2017, these consequences included training, warnings and dismissals.

UNGC Indicators

Sustainable Development Goals