Combating corruption and bribery
In the course of its activities, HHLA is constantly in contact with business partners and officials at different levels – especially in Germany, Central and Eastern Europe, and Asia. Based on the business model, geographical presence and the results of ongoing risk analysis, corruption was identified as one of the material risk areas, which is why it was incorporated into the compliance guideline. HHLA has observed an increased risk of corruption-related incidents in procurement and sales. Corruption has the potential to seriously damage the standing of the company and its employees and can have serious consequences, such as criminal proceedings, financial loss and loss of reputation.
To prevent corruption, HHLA has set out its own requirements in its Code of Conduct and anti-corruption guidelines.
The anti-corruption guidelines provide staff with the necessary knowledge about granting or accepting benefits to or from business partners and public officials. Practical examples are used by way of illustration.
During the reporting period, online training in anti-corruption topics was provided to employees in regular contact with business partners and public officials. The plan is to continue this in coming years.
The Group Compliance Department and the local Compliance Officers in the international units conduct independent, objective investigations into any circumstances that could constitute a compliance violation. The Group Compliance Officer reports at least quarterly to the Executive Board member responsible for compliance and the Supervisory Board’s audit committee on corruption and bribery cases that have occurred in the HHLA Group (as is the case for all other compliance violations), on the actions taken against such violations and on other ongoing actions. The Group Compliance Officer can also report directly to the Supervisory Board if need be.
The number of corruption incidents is constantly documented and monitored as part of the CMS using an internal reporting system. This enables the company to adjust its risk assessment or add more risk scenarios if there is an increase, for example, and to initiate appropriate action, such as improving communication and adapting processes in its internal control system. During the reporting period, there were no convictions for violations of corruption and bribery regulations and no violations of procedures aimed at combating corruption and bribery.
Reports relating to corruption and bribery can be submitted via the digital whistleblower system operated by HHLA and its subsidiaries at any time. Furthermore, an annual risk inventory, which includes corruption risks, is taken within the Compliance Department with guidelines and processes reviewed on an ongoing basis.