Ethics & Integrity

Ethics & Integrity
GRI 103-1,2,3; GRI 102-16, 17; GRI 205-1,2

We have established Group-wide procedures to ensure Oerlikon’s compliance with legal and regulatory statutes as well as internal standards, including the company’s Code of Conduct. This oversight encompasses training, communication and consulting activities designed to provide the Group’s divisions, business units and individuals with the information and resources necessary to fulfill their responsibilities and understand their roles in ensuring ethical compliance and behavior.

Oerlikon’s robust compliance and integrity platform that began in 2009 has evolved year over year. In 2020, we updated our Code of Conduct and raised our commitment to conduct mandatory electronic compliance training for employees annually (instead of every two years). For operational employees without digital access, the Face2Face (F2F) training program will be organized regularly. We have continued to build on such initiatives and to refine our approach to promoting ethical behavior and integrity, both within our organization and in the entities with which we conduct business. These developments include enhancing our business partner integrity screening process and communicating our antitrust compliance program to both internal and external stakeholders.

The framework of the Compliance Program has three pillars:
1. Prevention: policies, directives, training, the Code of Conduct, risk assessment, maturity assessment, compliance councils, internal controls and metrics, examples and Q&A in all employee meetings.
2. Early detection: 24/7 reporting hotline; continuous compliance reviews, controls and internal audits, allegation management process.
3.Response: disciplinary action on compliance breaches, process adaptation, resolution plans, remediation of internal control systems, fine-tuning of policies.

Through allegations left on our reporting hotline by concerned colleagues, we have been able to act swiftly to prevent wrongdoing or to deal with it promptly. Cases pertaining to the misdirection of funds or to physical bullying have led to dismissals with cause of those individuals who failed to live Oerlikon’s values. Thus, Oerlikon’s Code of Conduct ensures that every member of staff has a resource to help guide responsible decision-making in line with our standards of ethics, our culture and values, and our commitment to compliance in all our business practices. Furthermore, Oerlikon has broadened the scope of its governance framework by integrating ethics within its leadership development initiatives, with a focus on:
1.Providing substantive support to high-performing teams.
2.Reinforcing awareness of our commitment to sustainable practices.
3.Measuring successes against the triple bottom-line parameters.

Above all, the Code of Conduct prioritizes Oerlikon’s most significant distinction: its extraordinary reservoir of talented people. By promoting company-wide understanding and appreciation of the core values encapsulated in the Code of Conduct, our leadership team ensures that our employees not only comply with these standards, but that they also take pride in them. This creates our strongest foundation for pursuing the continued evolution of a comprehensive sustainable ethics and compliance governance framework. 

Since 2017, Oerlikon has provided annually mandatory electronic compliance training in the Code of Conduct and data privacy to employees. The participation of the e-training has improved steadily over the past years. In 2017, only 60% of registered users completed the e-training. In 2019, the completion rate was at 90%, while in 2020, it was 91%. 

In 2021, employees with digital access, excluding those from the acquisitions and in Germany, were asked to register for the e-training on the new Code of Conduct and data privacy. Around 4 100 of the registered users completed the training, representing 97% of total registered users.

In 2020, it was decided to offer colleagues without digital access at work to receive F2F training regularly. The first F2F pilot training will be rolled out in phases at all Oerlikon sites globally, and expected to be completed in late 2023. Based on the results from the pilot, the F2F training will be adapted to ensure that this training is conducted on a regular basis. The objective is to have more than 95% of all employees trained both digitally and F2F by 2030.

Moreover, to ensure best practices as both an ethical and sustainable organization, Oerlikon updated its Whistle Blowing Policy and introduced new Group policies in 2021, including the Anti-Harassment and Anti-Discrimination Policy; Policy Against the Use of Child Labor; and Policy Against Human Trafficking in Persons and Slavery. At the beginning of 2022, Oerlikon published its new Sustainability and Health, Safety & Environment Policy. The policies were approved by the Executive Committee and the Oerlikon Board of Directors, and oversight and responsibility for the implementation of these policies rests with a cross-functional team that includes members from the Sustainability Management team, HR, Compliance, Legal and Procurement.

Child labor
GRI 408-1

Oerlikon does not participate in and does not accept child labor. Oerlikon supports all international conventions pertaining to the nonuse of child labor. Oerlikon’s Supplier Code of Conduct condemns child labor. 

The Against the Use of Child Labor Policy is endorsed by Oerlikon’s Board of Directors and was issued in 2021. It includes Oerlikon’s directives on reporting suspected incidences of child labor, investigating those allegations promptly and taking all appropriate actions against the practice of child labor, including, as warranted, sanctions against or termination of relationships with partners or suppliers engaged in those practices.

Oerlikon strongly urges the reporting of any incident of child labor. Employees or representatives are encouraged to report complaints to their immediate supervisor, their department head, any senior manager of their business unit, their local human resources representative, their local procurement representative, or over the Oerlikon 24/7 Compliance Hotline (SpeakUp). 

Any reported allegations of child labor will be promptly investigated. If the usage of child labor is found in the supply chains of Oerlikon, the company will take all appropriate measures to mitigate any risks by developing a responsible solution, which may include the work in partnership with the supplier and or a termination

The adherence to the nonuse of child labor is clearly defined in our Policy and Code of Conduct but managed locally and by suppliers themselves. We currently do not have a system in place that gathers the data of which operations and suppliers are considered to have significant risks of such incidents.

Forced Compulsory Labor & Human rights assessment
GRI 412-1,2,3

Oerlikon is committed to a safe work environment that is free from and provides for protection against human trafficking and slavery, including forced labor and unlawful child labor. Oerlikon does not tolerate or condone human trafficking or slavery in any part of its global organization. Oerlikon prohibits human trafficking and slavery. Employees, contractors, subcontractors, vendors, suppliers, partners and others through whom Oerlikon conducts business must not engage, be involved or participate in any practice that constitutes human trafficking or slavery. 

The Policy Against Human Trafficking and Slavery is endorsed by Oerlikon’s Board of Directors and was issued in 2021. It includes Oerlikon’s directives on reporting suspected incidences of human trafficking or slavery, investigating those allegations promptly and taking all appropriate actions against the practices of human trafficking or slavery, including, as warranted, sanctions against or termination of relationships with partners or suppliers engaged in those practices.

Similar to the process defined for child labor, Oerlikon strongly urges the reporting of any incident of human trafficking. Employees or representatives are encouraged to report complaints to their immediate supervisor, their department head, any senior manager of the business unit, their local human resources representative, their local procurement representative or over the Oerlikon 24/7 Compliance Hotline (SpeakUp).

Any reported allegations of human trafficking will be promptly investigated and Oerlikon will take appropriate disciplinary action for the violation of this policy, which may include the discharge of employees, subcontractors and agents. 

Our operations and suppliers must adhere to nonuse of forced or compulsory labor, which is clearly stipulated in our policy and Code of Conduct. Presently, the management, tracking and actions taken are done locally and by suppliers themselves. We currently do not have a system in place that gathers the data of which operations and suppliers are considered to have significant risks of such incidents.

Although Oerlikon does not undertake specific human rights reviews or impact assessments, we do carry out frequent employee and labor relations/rights risk assessments of our own operations in various countries across the world as well as thorough compliance audits of our policies, including human resources, with applicable legislation and corporate policies and instructions.

Over the longer term, we will continue to monitor our business and the industries and markets we serve to identify additional areas of compliance focus through 2030 and beyond.

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