Compliance and fair business practices

Integrity and honesty are paramount

Management approach: Zehnder Group’s Code of Conduct is an integral part of our culture and serves as a guideline for ethically, socially, and legally responsible behaviour. It is a core element in everyday interactions with our colleagues, customers, suppliers and partners. It helps us to do the right thing and guides our vision. Together with Zehnder’s values, they form the cornerstones of our compliance activities. The Code of Conduct and the company values are available in ten languages and their contents have been communicated and made accessible to employees throughout Zehnder Group. They represent the foundation values of the Zehnder culture.

The Group has a legal and compliance policy that defines responsibilities, duties and processes and also ensures they are monitored. They cover the following main topics:

Integrity, ethics and compliance
Conflicts of interest and insider trading
Safeguarding corporate assets
Communication
Environment, health and safety
Fairness, respect and anti-discrimination
Diversity, equity and inclusion
Confidentiality and data privacy
Competition and global trade
Corruption and gifts
Quality

The compliance system consists of a variety of elements such as guidelines, regular training, onboarding of new employees, newsletters, integration into internal audits, internal reporting on legal and compliance issues and a central integrity line for employees, external partners and other stakeholders.

Internal Audit & Compliance is responsible for implementing compliance issues in close cooperation with Group Legal.

Should an incident be reported, there is an obligation to report it to the Group. To this end, each Zehnder company has appointed a contact person who is responsible for incidents involving Legal and Compliance. At least once a quarter, the responsible individuals in the areas mentioned above come together to exchange information throughout the Group.

Implementation: In 2022, we also revised and expanded the Zehnder Group Code of Conduct. The main points included in the revised Code of Conduct relate to adjustments that allow employees and other stakeholders to report violations of the Code of Conduct through the new integrity line. The revised version also contains a selection of clarifications and additions – e.g., on the important topics of corruption, competition law, the environment and employees. The Code of Conduct is supplemented by the implementing guideline, which contains practical instructions for employees.

If employees observe any irregularities or violations and do not wish to report them to their supervisors, their local HR contact, the Group Legal Counsel, the Head of Group Internal Audit & Compliance, the Director of Group Human Resources or a Management member, they can report this potential misconduct via our online integrity line. The integrity line is accessible in every country, where we have material operations. This channel allows all stakeholders to report incidents anonymously in their respective local language. All concerns regarding compliance with the Code of Conduct will be investigated and appropriate action will be taken if necessary. Zehnder is committed to discretion, ensuring that informants remain anonymous, and that information is kept confidential to the greatest possible extent. Any employee who reports any potential misconduct, provides information, or assists in any other way with a review or investigation of potential misconduct will be protected from any retaliation.

In addition, and in order to facilitate training in compliance or the Code of Conduct on a wider scale, we have started developing e-learning programmes. The following is planned in 2023:

rollout of a general module for all employees that covers every topic in the Code of Conduct, and
offering one in-depth module per year for a specific target group on a particular focus topic.

During the reporting year, the senior management received training as usual with the aim of raising awareness regarding fair business practices, including the prevention of corruption and bribery. The management helps to make employees more mindful of the need to report grievances in accordance with the Code of Conduct.

Due to recent political events and in compliance with our Code of Conduct, Zehnder Group made the decision to discontinue its business operations in Russia in the 2022 financial year.

We conduct five to eight internal audits annually at our local business units and Group functions to monitor business processes for legal compliance, uncover any potential cases of corruption or bribery, identify weaknesses in controls, and identify potential process improvements.

Outlook: The revised Code of Conduct has been rolled out since the beginning of 2023. It is mandatory for all employees, and we are planning further targeted steps over the next few years to reach as many employees as possible. We will be expanding all related e-learning programmes. One focus area in 2023 will be anti-corruption. We are also planning to draft a more comprehensive anti-corruption policy in 2023.