Compliance

For the success of the Gerresheimer Group it is essential that the enterprise is managed responsibly according to ethical business principles and in compliance with the laws and rules of fair competition.

The Gerresheimer Compliance Management System (CMS) was introduced in 2009 and has continuously been developed ever since. Right from the start, compliance efforts focused on combating corruption and adhering to the provisions of antitrust and capital market law. It is in these areas in particular that infringements can cause major damage or loss which must be avoided by all means. It goes without saying that Gerresheimer promotes conduct aligned with the rules of compliance in all other areas as well.

The core elements of the CMS include the Gerresheimer Compliance Program, on-site training, web-based e-learning programs, and a whistleblower system that allows reports to be made anonymously if desired. 

Performance of the management function in the area of compliance is the duty of the entire Management Board of Gerresheimer AG. On the Management Board, the Chief Executive Officer holds a special responsibility for compliance.

In particular, his responsibility comprises preparing Management Board resolutions relating to compliance issues, deciding on measures to investigate and punish compliance-related infringements, reporting on compliance cases and measures taken and further development of compliance guidelines to the Management Board and the Supervisory Board’s Audit Committee as well as supervising the Compliance Officer.

The role of the Compliance Officer as appointed by the Management Board is held by the General Counsel. The Compliance Officer holds organizational responsibility for implementing and updating the guidelines issued by the Management Board as well as for organizing trainings. The Compliance Officer further acts as contact person for all questions and suggestions about the Gerresheimer Compliance Program and for information about possible infringements of compliance regulations. In the event of infringements the Compliance Officer executes investigations and disciplinary measures on the instruction of the Chief Executive Officer.

Each Gerresheimer Group company has a nominated person who is responsible for compliance issues within that company. Such person is responsible for monitoring compliance and, in consultation with the Compliance Officer, for organizing compliance training in the respective company.

The Gerresheimer Compliance Program is designed to help our employees to apply the law and company guidelines correctly and to safeguard them against committing any infringements in this regard. All three main areas of focus selected for the Gerresheimer Compliance Program (combating corruption, antitrust law, capital market law) are covered by binding guidelines substantiated and supplemented by instructions. An infringement in any of these areas will not be tolerated.

Specifically, the Gerresheimer Compliance Program comprises the following elements:

• Mission Statement
• Group Guideline Compliance Organization
• Group Guideline on Combating Corruption
• Group Guideline on the Employment of Consultants and Agents
• Group Guideline on Compliance with Antitrust Regulations
• Group Guideline on Insider Law
• Instructions on the Group Guideline on Combating Corruption
• Instructions on Compliance with Antitrust Regulations
• Instructions on Conduct in the Case of Official Searches
• Instructions on Managers’ Transactions (Insider Guideline)
• Instructions on Consequences of Compliance Infringements
   

The entire Gerresheimer Compliance Program is available to all employees on the relevant Intranet page.

All Gerresheimer Group companies run on-site training courses to introduce the Gerresheimer Compliance Program. Attendance is mandatory for all managing directors, senior staff, sales and purchasing employees, and – in consultation with the local managing directors – any other employees who could potentially become involved in corruption or antitrust matters. This ensures that employees are able to take notice of the guidelines issued by the Management Board and apply them in their day-to-day work.

In Germany, the on-site training is led by the Compliance Officer or one of his colleagues; in other countries, it is led by local attorneys.

The electronic training programs are intended to supplement the on-site sessions in order to refresh employees’ memories about the content of the Gerresheimer Compliance Program at irregular intervals. Our staff are required to complete these training programs and can do so at work as part of their working day. There are currently training programs on the main focus areas of combating corruption and antitrust law.

These programs are available in several languages for the same employees that attend the on-site sessions. 

Another important component of the CMS is our procedure for receiving and processing hints and complaints and for protecting whistleblowers.

We have set out the details of the procedure (e.g. your options for submitting information (reporting channels), how we process it, and how we protect whistleblowers) in respective rules of procedure. The rules of procedure can be downloaded in numerous languages.

Our procedures for receiving reports include the electronic whistleblower system. It enables direct dialog with the compliance officer around the clock and around the world via the internet. Whistleblowers can decide for themselves whether they wish to remain anonymous. To make access as simple as possible, the whistleblower system can be used in all languages relevant to the Gerresheimer Group.