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ePaper created 2015-05-06, 08:22:31 | version 1.38.0
40 Compliance report The content and structure of the Heraeus Compliance System has been continually developed since the intro- duction of a global Code of Conduct for the Heraeus Group on January 1, 2007. Whereas in 2013 efforts were made to implement the new compliance guidelines regarding antitrust law, the focus in 2014 will be on further improving processes for performing due diligence on business partners. A standardized global process was introduced for the recording of data from due diligence checks on business partners in the precious metal trading and recycling business. This was coupled with a standardized IT-based workflow for approval. The new workflow is being used to move the existing due diligence procedure toward a more risk-based decision-making approach. The risks of purchasing materials that are tainted by conflict and of unwillingly participating in money laundering activities are more clearly separated, while predefined criteria allow targeted checks to be made. Each new business partner is risk-checked against these criteria and must be approved by the anti-money laundering officer (Heraeus Metals Germany GmbH & Co. KG) or by Compliance (Heraeus Precious Metals GmbH & Co. KG). A risk-oriented approach means that the checks are regularly repeated. Increasing importance is being attached to the selection and monitoring of suppliers. In this process Heraeus not only ensures strict compliance with the provisions of its own sourcing guideline but also takes account of the requirements of customers. This is verified by external reviews. In 2013, Heraeus instructed the auditing firm PricewaterhouseCoopers (PwC) to audit Heraeus Precious Metals GmbH & Co. KG and Heraeus Deutschland GmbH & Co. KG (formerly Heraeus Materials Technology GmbH & Co. KG) for compliance with the requirements of the LBMA (London Bullion Market Association). PwC con- firmed that the established structures and processes of both companies fulfill the requirements of the LBMA Responsible Gold Guidance as of January 18, 2013, and not just for gold but also for the ‘conflict metals’ tin, tan- talum, and tungsten. For Heraeus Precious Metals GmbH & Co. KG the audit for 2014 has begun, with the results to follow. Heraeus Deutschland GmbH & Co. KG (previously Heraeus Materials Technology GmbH & Co. KG) will not undergo a new audit because of the restructuring that was announced in the autumn. Training to ensure that all relevant employees know and understand the rules of the Heraeus Compliance System is organized around the world by the Heraeus Compliance Officer, by the compliance officers and senior managers of the business groups, and by the compliance officers and senior managers of the foreign subsidiaries. A Compliance Board, which meets twice a year, brings together the elements of compliance management, risk management, Group Internal Audit, and the audit of the annual financial statements. Represented on the Compliance Board are Group management, the head of Group Internal Audit, the Heraeus Compliance Officer, the General Counsel, the Heraeus Risk Officer, the International Tax Manager, the IT Security Manager, and the external auditor. The members of the Compliance Board share information about risks with the Group and agree action plans.