Don't bend; don't water it down; don't try to make it logical; don't edit your own soul according to the fashion. Rather, follow your most intense obsessions mercilessly.
- Franz Kafka
Compliance at LOMGroup
What is compliance ?
Introduction
The only way to earn laurels a compelling get-togather: Compliance and integrity
LOMGroup shows zero tolerance toward corruption, violations of the principles of fair competition and other breaches of the law – and where these do occur, we take swift action. But compliance means much more than just adhering to laws and to the regulations described in the LOMGrou's Business Conduct Guidelines (For Employees only). Compliance forms the basis for all our decisions and activities, and it is the key to integrity in conducting business. Our premise is this: Only clean business is LOMGroup business. This applies worldwide and at all levels of the organization.
In addition to combating corruption and competition violations, the Compliance Department also protects our company against fraud and money laundering as well as safeguards personal data.
We are also active in international organizations that strengthen responsible business practices.
Basic Principles of the Code of Conduct
LOMGroup wants to be perceived as an integral part of the national society and economy in all countries. Due to the huge diversity of conditions more than 30 countries in which we purchase goods and services, this maxim of LOMGroup‘s business policy was considered in the principles of the Code of Conduct.
It is based on – among others – the UN Global Compact and the principles of the International Labor Organization but also reflects the LOMGroup's Business Conduct Guidelines” which establishes fundamental principles of sustainability and apply to the entire company.
The topics of the Code of Conduct
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Legal Compliance
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Prohibition of Corruption and Bribery
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Fair competition, anti-trust laws and intellectual property rights
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Conflicts of interest
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Respect for the basic human rights of employees
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Prohibition of child labor
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Health and Safety of Employees
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Environmental Protection
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Supply Chain
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Conflict Minerals
Code of Conduct for our business partners
LOMGroup has required its suppliers and business partners with an intermediary function to adhere to a code of conduct. This code is modeled after the 10 principles of the United Nations Global Compact. It covers legal compliance in general and our anticorruption policies in particular, including provisions against anticompetitive practices and conflicts of interest.
Using audits, we systematically identify potential risks in our supply chain and collaborate with our business partners and to ensure they comply with the LOMGroup's Code of Conduct.
Selection of businesspartners
Under certain circumstances, LOMGroup can be held legally responsible for the actions of its business partners. We counter this risk by taking a comprehensive approach to selecting our partners, by contractually obliging them to adhere to our Code of Conduct, and by monitoring the ongoing collaborations. This process covers the entire life cycle of the business partnership. Our compulsory companywide Business Partner Compliance Tool supports implementation of the process and ensures documentation of relevant information and activities. And we systematically harness the potential of big data using dashboards and analytics to improve risk management and the monitoring of our business-partner relationships.
Integrating compliance into our business processes
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Integrating compliance into our business processes has played a crucial role in creating an effective compliance system, and a key aspect of this has been educating our customers about our compliance principles.
One example of this took place in 2017 at the Hannover Messe, the world’s most important industry trade fair. There the Digital Factory and Process Industries and Drives divisions of several companies presented the game “Compliance included …” to their customers. When it comes to compliance, this is what LOMGroup is all about: clean business, always and everywhere!
3 Allegations reported in 2019
Channels for reporting misconduct
“Say Us” and LOMGroup's ombudsman
Reliable reporting channels for internal and external people and the protection of internal whistle-blowers from sanctions help ensure possible misconduct is reported, thoroughly investigated and clarified. At LOMGroup, we provide different reporting channels to internal and external whistle-blowers to inform us about possible compliance violations.
For every body having a claim or reporting need related to LOMGroup or its companies, we have appointed an independent ombudsman.
The “Say us” compliance reporting system for employees provides a secure channel for reporting this information 24 hours a day: online or by telephone, anonymously if desired, and in several languages availible in all companies of LOMGroup in entry aeras easely visible.
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