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Our compliance system is designed to prevent, detect, and respond to potential violations of existing anticorruption and antitrust provisions based on internal guidelines and trainings (Prevent–Detect–Respond).
The OSRAM Business Conduct Guidelines define group wide rules of conduct, specifically on efforts to combat corruption and on proper conduct when engaging in competition. In addition, we address compliance-related risks through various IT tools. For example, we classify our business partners based on certain risk indicators, such as the level of corruption in the country in which the relevant business partner operates. We have also introduced country-specific tools addressing issues relating to giving and receiving gifts and hospitalities, sponsorships, donations, and memberships. All compliance regulations are continuously evaluated with regard to their practicability and adjusted or further developed if necessary. To ensure the implementation of our compliance system, multiple face-to-face and web-based trainings have been conducted.
Principles and rules for all employee behavior
In order to detect and respond to compliance violations, we rely on the whistleblower hotline “Tell OSRAM”. Furthermore, all employees have the option to report violations to our compliance organization. We follow up on any indication of a violation. An internal compliance investigation is launched if justified by concrete evidence. Upon completion of an investigation, we propose remedies for the identified deficits and supervise their implementation. We also respond to detected misconduct with employment-law disciplinary sanctions. We monitor, evaluate and improve the OSRAM compliance system on a continuous basis.
"Tell OSRAM" is a protected reporting channel by which all our employees and third parties can report possible compliance violations.
In fiscal year 2015, the compliance organization received a total of 64 notifications of potential compliance violations. 11 compliance investigations were finalized as a result of which disciplinary steps were taken against 19 employees. An additional 60 existing matters were closed following detailed assessment.