Global Compliance Organization
At Sika, a matrix organization is administering Sika’s Compliance Management System. The Head Corporate HR and Compliance leads both the HR as well as the Compliance function. Five full-time Compliance Managers help to coordinate the group-wide compliance initiatives.
Depending on the compliance topic concerned, the Corporate Compliance Team is supported by the Regional HR Heads, or by more than a dozen Legal or Controlling employees who act as part-time Compliance Officers. Together they represent Sika’s cross-functional Global Compliance Organization, which aims inter alia at preventing incidents of bribery and unfair competition by means of policy making, relevant trainings, periodic audits, ad hoc investigations, as well as targeted disciplinary and improvement measures.
Corporate Compliance, Internal Audit, and Audit Committee
Corporate Compliance and Internal Audit collaborate closely in their effort to detect bribery, unfair competition, or fraud. Corporate Compliance usually coordinates investigations concerning these matters.
All bribery, unfair competition or fraud reports must be escalated to the Group Compliance Officer, irrespective of who reports them or where they occurred. In addition, Internal Audit may identify fraudulent or corrupt practices while conducting a regular audit. If this is the case, Internal Audit also informs Corporate Compliance and the Group Compliance Officer, who in turn records IA-detected corruption, unfair competition or fraud incidents in the Group’s case recording system and issues sanctioning and improvement recommendations to the concerned line management.
Corporate Compliance, and more particularly the Group Compliance Officer, regularly reports substantiated corruption, unfair competition and fraud cases to the Audit Committee of the Board of Directors, the Group Management, and the external auditors, also informing them about identified root causes and the corrective measures that the concerned line management has implemented.
Compliance Audit Program
Sika’s Compliance Management System rests on a life cycle of three closely interrelated core activities: Prevent – Detect – Respond & Adjust. In the context of detecting compliance violations, Corporate HR & Compliance has developed the necessary cornerstones to build up a compliance audit program.
In close cooperation with other assurance functions at Group level, including Internal Audit, Legal, Finance, Operations, Quality, Environment, Health & Safety (O, Q&EHS), Procurement and Research & Development (R&D), Corporate HR & Compliance designed and launched a “Compliance Self-Assessment” questionnaire for General Managers (GMs). The questionnaire aimed at identifying “high risks” and “focus entities” for targeted compliance audits; monitoring the local implementation of compliance requirements at all Sika entities; and aligning closely with the above-mentioned assurance functions and their audit activities.
Third Party Due Diligence and Monitoring
In 2021, Sika tightened its Third-Party Due Diligence and Monitoring on a global level with the rollout of a revised Supplier Code of Conduct. Sika implements its strong anti-corruption stance across the entire supply chain. The Supplier Code of Conduct prohibits any act of bribery or corruption, while stating that such acts, if identified, will lead to the immediate termination of cooperation.
Every supplier is required to commit to Sika’s Supplier Code of Conduct or to demonstrate that it has implemented similar internal rules, reflecting a zero-tolerance policy regarding bribery or corruption. Suppliers are required to have systems in place that assure the proper instruction, training and auditing of their personnel and subcontractors to ensure compliance with Sika’s anti-corruption requirements across the entire supply chain. Corporate Procurement on a regular basis reviews supplier performance, thus monitoring whether Sika’s business partners indeed comply with the Group’s strict anti-corruption requirements. Further, suppliers are obliged to immediately inform Sika of any known violation of its Supplier Code of Conduct. Business contracts with suppliers accused of engaging in bribery or corruption are terminated with immediate effect, unless the supplier can demonstrate that it has in place a compliance management system that aims at effectively preventing acts of bribery or corruption.
Sika investigates reported cases of corruption based on a defined incident response process. Confirmed cases usually lead to sanctions against involved employees and other corrective measures as deemed necessary and suitable to strengthen Sika’s Compliance Management System. Corporate Compliance keeps track of all investigated cases and reports substantiated cases to Group Management, the Audit Committee of the Board of Directors and to the external auditors.