The objective of the Villeroy & Boch Compliance Management System is to determine rules of conduct, to establish processes and to train employees to avoid violations of the law (preventive approach), to clarify violations of the law (detective approach) and to sanction such violations (reactive approach).
Essentially, our compliance programme currently covers business ethics, competition law, the fight against corruption, fraud, the prevention of money laundering and the reviewing of sanctions lists. Other relevant areas, such as the environment, occupational health and safety, data protection and capital market legislation are handled by specialist officers or specialist departments.
CEO Frank Göring, is ultimately responsible for compliance on the level of the management board. The General Counsel and the Chief Compliance Officer of the Villeroy & Boch group report to him. The Chief Compliance Officer is supported by functional Compliance Officers belonging to the company headquarters as well as by local staff in the group companies commissioned with compliance tasks (Local Compliance Responsibles, LCR).
Our group-wide ethical principles and compliance policies are binding for all members of staff. They provide them with orientation in terms of responsible conduct in their daily work, offer protection against incorrect decisions, and thus form the very foundations of our success.
Employees are kept constantly informed of issues relating to compliance, and are provided with continuing training in this domain. The comprehensive training programme provides both face to face and web-based training facilities. A certificate for the latter is awarded to participants who pass the relevant test. We offer guidance on compliance issues for all members of the group’s workforce. Villeroy & Boch has implemented internal approval procedures to protect against violations of compliance regulations, and these apply in particular to corruption, fraud and competition legislation.
With the Villeroy & Boch Group's Code of Conduct, we set standards with regard to responsible and ethical conduct at all levels and value-added stages of our company. The guiding theme of our Code of Conduct is business integrity. For us, integrity is a central prerequisite for trusting cooperation and the successful development of our business relationships.
All employees are expected to act in accordance with this Code of Conduct and the laws, guidelines and instructions applicable to their area of work. At the same time, the Code of Conduct also defines the principles and requirements we set for our business partners.
Our compliance activities are risk-oriented, i.e. we evaluate and prioritize compliance issues on the basis of a risk analysis. Compliance risks are also identified as part of an ongoing process of compliance risk reporting and are fed into the compliance management system. We have also established a whistleblowing system.
The attached statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 for the financial year ending on 31 December 2016.
We attach great importance to receiving reports on possible violations of compliance regulations (e.g. code of conduct, antitrust law, corruption, money laundering, fraud). After all, they help us to counteract any violations at an early stage and thus to avoid any damage to our company and our staff. Employees of Villeroy & Boch AG and the group companies can use various channels to report compliance violations to us. Our business partners, suppliers, customers and other third parties can also notify us of compliance violations. You can submit such reports direct to whistleblowing(at)villeroy-boch.com or Villeroy & Boch AG, Compliance department, Saaruferstraße 1-3, 66693 Mettlach.
You can also contact the Villeroy & Boch AG ombudsman, the lawyer Mr Christoph Clanget, Haldystraße 8, D – 66123 Saarbrücken, Tel. +49 (0)681 / 9508930 (in German, English or French). The ombudsman works on behalf of Villeroy & Boch AG and thus represents the interests of Villeroy & Boch. However, he is also authorized to forward reports in an anonymous form upon request. Incoming reports are reviewed and processed by the Villeroy & Boch AG compliance department. We treat incoming reports in confidence and take all reasonable measures to protect whistleblowers who are acting in all conscience from any disadvantages that may arise from the fact that they have submitted a report.
All violations reported are evaluated immediately by the staff responsible for compliance and are pursued where appropriate. In examining and pursuing such violations, we observe the principle of legality.
All violations identified are sanctioned in a consistent and appropriate manner. In the event of state investigations, Villeroy & Boch provides comprehensive support.
We ensure that our compliance management system is constantly improved. We are pleased to receive all information and suggestions that might assist us in this process. This also means that we subject our compliance management system, either in part or in its entirety, to both internal and external audits. The latest audit of our compliance management system was conducted in the first quarter of 2016 in accordance with the principles of the audit standard (Prüfungsstandard) 980 issued by the Institute of Public Auditors in Germany Institut der Wirtschaftsprüfer e.V. . The subject of the external audit was the effectiveness of the compliance management system in terms of the sub-areas of competition law and the fight against corruption in Germany. BAX GmbH Wirtschaftsprüfungsgesellschaft Rechtsanwaltsgesellschaft (auditors and lawyers) confirmed that the principles and measures contained in our compliance management system are suitable to enable us, with an acceptable level of certainty, to identify risks relating to violations of legal provisions at an early stage, and to act to prevent such violations.