Integrity

 Integrity and responsibility in our actions is one of AkzoNobel’s core values, embedded in our business principles and the Code of Conduct.

Code of Conduct
Our Code of Conduct, which was updated in 2007, incorporates fundamental principles on issues such as business integrity, labor relations, health, safety and environment, and community involvement. It provides strict rules for doing business in a fair and open way, while forbidding anti-competitive behavior and bribery. During 2008 our Anti-bribery and Competition Law compliance manuals were updated.

These documents are available in the nine corporate languages and have associated on-line and face-to-face material to support employee training and future induction training in each business. 18,500 employees have already completed the on-line Code of Conduct training: our target is to train all employees by mid 2009.

Managing compliance
The AkzoNobel Compliance Committee, comprising the General Counsel and Corporate Directors of  Internal Audit, Compliance, Human Resources and Corporate Control was set up to foster awareness of and control compliance with the AkzoNobel Code of Conduct. Each Business Unit has appointed a member of the management team to act as the Compliance Focal Point, to manage the roll out of compliance projects and monitor compliance with the Code of Conduct. 

During 2008 the Compliance Committee and Focal Points have developed a compliance risk profile for each business unit, using a standard risk identification process. The profile identifies the compliance risks which require special focus: it will be subject to periodic reviews and updates.

Monitoring Compliance
AkzoNobel has a number of important tools to monitor compliance.

• A Speak Up! Procedure which allows employees to express their concerns on (alleged) breaches of the Code of Conduct. Both AkzoNobel and the former ICI operated global complaints procedures which encouraged employees to report potential violations of the Code of Conduct to their supervisor, to the office of the Legal Council or via an independent whistle blowing process. During 2008 we have amalgamated the different procedures into a single process: the Speak Up! Procedure. A global supplier has been appointed to operate a confidential telephone and web-based reporting system. All breaches of the Code of conduct are fully investigated under the supervision of the General Counsel.
• Non-financial letter of representation. Each Business Unit has processes in place to assure compliance with the Code of Conduct and other corporate requirements. At the end of the year each senior manager and finally the business unit manager signs the non-financial letter of representation to confirm compliance. The outcome is reviewed with the responsible Executive Committee member and General Counsel and the results are reported to the Executive Committee and the Audit Committee.
• Compliance audits are conducted within AkzoNobel; the outcome is shared with the Compliance Committee.