Brenntag has always attached great importance to responsible, prudent and sustainable corporate governance. Our top priority is adherence to statutory requirements as well as voluntary internal conduct policies (compliance).
To enable this, management uses various internal control and risk management systems and has established a compliance organization within the company. Every Brenntag employee is personally responsible for complying with all applicable laws, directives, policies and regulations.
„Each of our employees is personally responsible for avoiding unlawful and unethical behavior and complying with the Code of Conduct at all times without exception.”
Brenntag Code of Business Conduct and Ethics
As a central part of our compliance system, the Code of Business Conduct and Ethics encompasses the fundamental requirements for Brenntag’s overall business activities in fields such as:
- Health, safety and the environment
- Human rights and working conditions
- Relationships with business partners and public institutions
- Bribery and corruption
- Competition and antitrust law
- Avoidance of conflicts of interest Data privacy and information security
At the head of Brenntag’s compliance organization is the Board of Management and, within this body, its chairman. Brenntag AG’s Governance, Risk & Compliance (GRC) manager in the Corporate Internal Audit department regularly reports to the Board of Management on compliance issues and in urgent cases will do so immediately. The regular meetings of the Supervisory Board’s Audit Committee also include reporting on compliance and whistle-blowing as well as on the ongoing development of the Group-wide compliance management system.
The GRC manager is supported by the Compliance Committee as an internal advisory body. This includes representatives from the areas of Legal, Audit, Accounting, Information Security, HSE and Human Resources.
At a regional level, the Regional Executive Management is responsible for the issue of compliance. Regional compliance managers have been appointed in Brenntag’s regions. They receive, assess and report any compliance issues and/or questions referred to them, coordinate the compliance management system at a regional level and regularly pass on information and experience through dialogue with Brenntag AG’s GRC manager. This allows us to ensure close integration of compliance management with our business activities at a regional level.
Our Code of Conduct stipulates that Brenntag must in no way be involved, directly or indirectly, in bribery or corruption in order to obtain commercial advantages and that our employees should refrain from such conduct that could potentially be construed as inappropriate or unlawful. Any misconduct by its employees will not be tolerated by Brenntag (zero tolerance policy) and may lead to corresponding disciplinary consequences and sanctions under employment law.
Brenntag has also implemented an anti-corruption guideline. As a minimum standard for the Brenntag Group, it specifies the conduct expected of all employees with regard to anti-corruption and anti-bribery and is intended to help them ensure that their conduct is compliant in critical situations and that they avoid risks.
Within the scope of internal audits, the Brenntag companies are regularly reviewed in relation to corruption risks, etc.
Brenntag respects and supports the protection of internationally recognized human rights and attaches great importance to observing these within its sphere of influence. Brenntag aims to safeguard these rights through its commitment to uphold the principles of the UN Global Compact. The Brenntag Code of Business Conduct and Ethics stipulates that our company and all of our employees must not be involved in any violation of human rights. We reject any form of forced or child labour, advocate equal opportunities and fair working conditions and are against discrimination of any kind.
We are unaware of any business units at Brenntag where human rights are systematically jeopardized.
Brenntag has undergone the sustainability assessments of the EcoVadis rating agency for several years. EcoVadis assesses the sustainability performance of companies in the categories of environmental protection, labour practices, fair business practices and sustainable procurement. The review of aspects of human rights is a key element of this external assessment of Brenntag.
As part of its membership of the “Together for Sustainability” initiative, Brenntag has required its suppliers to also undergo EcoVadis sustainability assessments as at 2015, including a review that they observe human rights.
In our Supplier Code of Conduct, which we created in 2015, we also explicitly require our suppliers to support the protection of international human rights and to refrain from any involvement in violations of human rights.
Alongside organic growth, acquisitions are the second pillar of Brenntag’s long-term growth strategy. Every acquisition undergoes a thorough and comprehensive due diligence process. We hold a large number of face-to-face meetings and make many on-site visits in order to understand, analyze and assess the history, the current situation and the potential of the target business. Another element is an extensive analysis which covers, besides commercial issues such as the company’s structure and financing, tax and insurance arrangements, legal affairs and its information technology system, also the fields of HSE, corporate governance/compliance and human resources.
Alongside established processes in the area of environmental protection, the target company is also required to regularly disclose any contamination that may have occurred on its sites and any remediation measures implemented in response. In the area of occupational safety, topics such as on-site safety measures and employees’ personal safety equipment, among others, must be outlined. The company is likewise obliged to disclose its corporate governance structure and its compliance requirements. In the area of human resources, topics such as agreements on social benefits, retirement provision and company pension schemes as well as collective bargaining agreements must be covered.
In the event of the due diligence process revealing any shortcomings or if key issues remain unresolved, Brenntag will generally ask the target to permit a more in-depth review. We will then decide on a case-by-case basis how to proceed in case of insufficient clarification or even whether to terminate the negotiations outright.
Acquisitions are integrated into the Brenntag Group by way of a structured process which may unfold over a period of several years, depending on Brenntag’s strategy for the company, its size and the complexity of the business. If any discrepancies are identified in relation to Brenntag standards – e.g. in terms of the issues of safety, environmental protection, human resources and compliance – a key integration objective is their rapid elimination.
Contact for complaints
Tried-and-tested processes are in place at Brenntag for the orderly acceptance and processing of Group-wide internal and external complaints and compliance reports.
Our employees can report relevant information either to their direct line manager, to the regional compliance manager or alternatively via email to firstname.lastname@example.org . Third parties (customers, suppliers and the public) may also use the contact.