Compliance and privacy at Brenntag

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We have always attached great importance to responsible, ethical, and sustainable corporate governance. Our top priority is adherence to statutory requirements as well as to voluntary internal policies that further promote our business conduct and underlying values.

To enable this, we have established a compliance organization within the company while implementing internal control and risk management systems. Each employee is personally responsible for complying with all applicable laws, directives, policies, and regulations.

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“In order to maintain our position as respected global market leader within the business community and the general public, Brenntag is strictly committed to the highest standards of legal and ethical compliance as well as socially responsible behavior. We trust our employees to have ownership of their actions and to always adhere to these principles as well as Brenntag’s corporate values without exception.”

Our Code of Business Conduct and Ethics

As a central aspect of our compliance system, our Code of Business Conduct and Ethics encompasses the fundamental requirements for Brenntag’s overall business activities in fields such as:

  • anti-corruption
  • anti-money laundering
  • books, records, and financial reporting
  • competition and antitrust law
  • conflicts of interest
  • Confidentiality
  • data protection and information security
  • foreign trade compliance
  • fraud prevention
  • insider trading
  • handling and safeguarding of Brenntag property
  • health, safety, and environmental protection
  • human rights and labor practices

Our supplier Code of Conduct

We are committed to always conducting our business in line with the law and business ethics whilst keeping our social and environmental responsibility in mind.

As part of this commitment as outlined in Brenntag’s Supplier Code of Conduct, we expect our suppliers as well to comply with

  • all applicable laws and regulations,
  • principles related to good governance business practices,
  • human rights and appropriate working conditions, and
  • environmental responsibility.

Further information

The Board of Management is at the head of our compliance organization. The Senior Vice President (SVP) Compliance & Privacy Brenntag Group regularly reports to the CEO, Board of Management, and the Supervisory Board on compliance topics.

The regular meetings of the Supervisory Board’s Audit Committee also include a check on possible whistleblowing cases as well as on the ongoing development of the group-wide compliance management system. Within the global regions Regional Compliance Managers ensure a close link with our business activities by coordinating the compliance management system at a regional level.

These managers review and report all compliance issues and any compliance-related questions that they have received. They participate in a regular exchange of information and experiences together with the SVP Compliance & Privacy Brenntag Group. The Local Compliance Contacts support the Regional Compliance Manager in their work. This ensures that our compliance management is closely interlinked with our business activities at regional and local level.

Preventing corruption is an essential element of our compliance management system. Group-wide requirements relating to anti-corruption are specified in internal policies and guidelines. These regulations apply to all employees equally and compliance with them is monitored.

We have a zero-tolerance policy towards employee misconduct, and any misconduct can lead to corresponding disciplinary measures or have consequences under labor law. In addition to the Code of Business Conduct and Ethics, we provide a groupwide anti-corruption guideline which specifies what type of conduct is expected of all employees to protect themselves and Brenntag from corrupt behaviour.

The internal control guideline contains further requirements and measures to counteract corruption, such as:

  • ensuring the separation of functions
  • complying with the double-check principle
  • adhering to the requirement to obtain comparative bids from suppliers and service providers

Internal audits are regularly conducted at our entities to ensure compliance with these guidelines. Further elements of the compliance management system relating to the prevention of corruption at Brenntag are target-group-oriented training courses for employees and a whistleblowing system, which can be used to provide anonymous information.

As the global market leader in chemical distribution, Brenntag must comply with all foreign trade and customs laws applicable in other countries, such as restrictions on exports or imports of particular goods, services, and technologies to or from countries subject to sanctions or embargoes.

The same applies to deliveries to or from companies or persons on sanction lists. In addition, Brenntag employees must comply with all applicable trade restrictions resulting from international embargoes, which typically restrict or prohibit payment and capital transactions with particular countries.

We fulfil this obligation in part through the support of IT-based screening. With the help of this software application, we regularly check customers and suppliers against the sanction lists issued by the United Nations, the European Union, the USA, and various other countries in which Brenntag operates. If suspicions are raised, a careful check is carried out on the basis of all the information available. Should a suspicion be substantiated, no delivery takes place and, if necessary, further measures are initiated in coordination with the authorities.

To meet the increasing requirements of global data protection, the Board of Management appointed a Group Data Protection Officer (GDPO) in 2018. As head of the Global Data Protection department, the GDPO reports independently and directly to the Board of Management.

The Global Data Protection department is responsible for developing, implementing, and managing the data protection management system for the Group. Data protection coordinators in the various regions support the Global Data Protection department and report to the central unit.

Our SpeakUp® channel

The success of our company is based on integrity and compliance lived by every single one of our employees and business partners, with not only legal requirements, but Brenntag’s principles as outlined by our Code of Conduct. It is a top priority for us to ensure that everyone working at, or with our company, is comfortable speaking up, raising questions, concerns about ethical issues or cases of non-compliance, without fear of retaliation.

To enable our employees and business partners to raise concerns, we have put a SpeakUp® channel in place that ensures anonymous reporting of any concerns regarding ethical issues or non-compliance with the law by a Brenntag employee.

The channel is managed by a third-party provider, ensuring that all information received by the Brenntag employees responsible for reviewing the concerns is anonymous. We are committed to protecting individuals that raise concerns in good faith and all persons who contribute to the review or investigation of any potential misconduct. Discrimination, adverse employment action or retaliation of any kind against such persons is not tolerated.

Likewise, we are committed to the presumption of innocence to those affected by any concerns raised until the violation is proven. All reviews of conduct are conducted with the utmost confidentiality. The information will be processed in line with applicable data protection laws.

How to report a compliance concern?

Submit your concern via a webform Speak up channel or call a toll-free number to leave a message.

You will not need to submit any personal contact information as you will receive an individual case number and passcode that allows you to check back (via the webform) for any communication sent to you by Brenntag via this weblink. If you use the toll-free number, please note that your message will be recorded and transcribed by the third-party provider.

Brenntag will not receive that message, but the written transcript instead. You will also receive an individual case number and passcode to check back (via the webform) for any communication sent to you by Brenntag via this weblink.

Start a report

In order for your message to be processed and reviewed, it is important that the report is as specific as possible (who, what, when, how) and that it includes supporting information, e.g., copies of documents or names of individuals who have witnessed the same incident.

Please note that general assertions or vague statements cannot be investigated. Once you’ve submitted your report, you will receive an individual case number. Keep this number safe. You will need this number to check for any communication sent to you by Brenntag via this weblink. We take all concerns raised via this channel seriously and will carry out the appropriate action in each instance.

We will keep you informed on our progress. Certified to the highest data protection and security standards, SpeakUp® is fully ISAE3000 Type II certified on a quarterly basis.