Building a compliance culture
Under the responsibility of the Audit Committee and the Board of Directors, in 2019 we continued to develop and stimulate a company culture in which ethical conduct and compliance with our policies, and applicable regulations, are at the core of how we do business.
Over the past few years, we have continually invested in building a company-wide compliance program. And as of April 2019, a full-time compliance manager was appointed to coordinate the development of standards and controls to enforce compliance and awareness in the organisation, a further step towards minimising risk of breach.
Following significant changes to the Management Committee during 2019 and as a further step in enforcing our compliance culture, we are currently working to fully define our vision and values. In January 2020, a survey was undertaken across all employees to identify alignment between personal and company values, as well as those values considered most important to the development of the company. Results have been presented to the extended Balta leadership team and are now being assessed for potential action. Part of this work includes the further development of our formal Code of Conduct and Ethics policies, in line with the overall vision and mission.
Raising awareness for our complete legal compliance program was a key priority during 2019. This included market abuse, anti-bribery and anti-corruption, gift and entertainment, antitrust, anti-money laundering, economic sanctions, privacy and data protection.
One of the core elements of this strategy was to increase accessibility of the program through the intranet. A system of ‘tips and tricks’ and ‘red flag’ overviews for various risks were added. Short summaries using simple, easy to understand language were developed to make the search for different topics easier. We also used the company blog to underline the Management Committee’s commitment to compliance. Policies are also now in different languages, with our Antitrust Policy available in English, French, Dutch and German to ensure native understanding in the key operational languages of our business.
Next to a scheduled training program focused on data protection and privacy, 2019 saw additional training sessions available on request for any of the business units. For example, the modulyss carpet tile division held its international sales and marketing event where competition law and anti-corruption training was given.
New starters at senior levels were given face-to-face training sessions on Balta’s Dealing and Disclosure Code and relevant market abuse regulations. At the end of 2019 we conducted a five-week communication campaign reiterating key compliance messages. All European employees in leadership positions signed off on their compliance with legal policies over the course of the year, as well as their commitment to continued compliance. Known as the Compliance Declaration, it concluded our 2019 awareness raising campaign.
Going forward, we will place more attention on compliance within our welcome packs and induction programs for new staff and this includes written confirmation of knowledge and acceptance of Balta policies. This project is at an early stage and will be extended in 2020.
We will continue to invest in the education of our people relating to ethical and lawful behaviour. A new anti-corruption and antitrust training campaign will be launched in this year, including a strategy for recurring courses in forthcoming years. There will also be the formalisation of a ‘speak up’ procedure and this will become a key performance indicator.
One of the main potential risks identified is the gap across various international locations and how that impacts compliance. We have taken initial steps to create a more centralised approach to negate this risk through the central intranet system and making policies available in multiple languages.
Providing an overview of policies and procedures across all domains, will we monitor the effectiveness of this delivery method throughout 2020 with the aim of making it a truly global program for all Balta business units. In the short term, we are working with our US colleagues to ensure a consistent level with Europe.
Supply of goods
In September, we received an official AEO (Authorised Economic Operator) certification from the Belgian customs authorities for all production sites in Belgium. The AEO is part of our plan to mitigate risks in post-Brexit export to the UK, and this AEO is applicable for exports to all non-EU countries and facilitates the smooth flow of goods. It will help to secure the continuation of a premium delivery service to our worldwide customers.
We also became a member of Custom Trade Partnership Against Terrorism (C-TPAT), a US Customs and Border Protection (CBP) voluntary private-public partnership program. C-TPAT ensures that goods in the supply chain are legitimate and legal from manufacturer to end-users. While it was originally set-up to protect supply chains in the USA from terrorist activity and illegal trade, it does minimise potential risk for Balta when trading internationally.
Responsible sourcing and supply chain
As a global organisation with the desire to embed sustainability at every point, our relationship with our suppliers is extremely important for the ongoing success of the Balta.
It is our goal to rigorously audit and assess suppliers in key areas including environmental concerns, health and safety, legal compliance, the use of hazardous materials, workforce well-being and financial stability, as well as compliance with recognised International standards on Human Rights and Child Labour.
Important existing suppliers are audited to ensure those standards are maintained and we have contracts in place to ensure this does not change. For some time, as part of our ISO 14001 compliance, we have had a balanced scorecard method of measurement for raw material suppliers. In 2019, we introduced a similar measurement for our transport suppliers. We are beginning to use the same principles for all purchasing at all locations and adhere to a coherent process and procedure for everything we buy.
To minimise waste, we consolidate purchasing contracts where possible and in 2019 have reduced the total number of suppliers across the Balta group whilst simultaneously increasing the number of supplier contracts we have.