To PALFINGER, human rights violations and corruption are intolerable from a moral point of view. They are in contradiction to the corporate values and harmful to the economy, and consequently also to PALFINGER. Whenever any irregularities are suspected, action is taken immediately. PALFINGER has implemented a multi-layered process to prevent or, if necessary, reveal any violations.
GROUP GUIDELINES AND CODE OF CONDUCT
PALFINGER’s Code of Conduct supplements the group guidelines, which define the essential business processes along the value creation chain. This Code covers various issues, including the observance and monitoring of human rights aspects and the prevention of child labour, forced labour and compulsory labour, also in the supply chain. Furthermore, an internal guideline on “Rules of Conduct for the Prevention of Corruption and Anti-Competitive Behaviour” is in place.
Since 2010, agreements with employees, dealers, suppliers and cooperation partners have contained binding references to the PALFINGER Code of Conduct. The Code can be found on the Company’s website, which also presents a video in support of communication. Based on the current findings, no child labour, forced labour or compulsory labour was used at any PALFINGER sites in 2017 and no young employees are exposed to any dangerous labour. Even at risky sites, for example in Asia, compliance with the Code of Conduct is mandatory.
In the event of any severe violations of the Code of Conduct, the rules of behaviour or other group guidelines, the internal auditing department consults with the Management Board on the procedure for analysing these violations. If necessary, external experts are consulted. Depending on the result of this analysis, a decision is made on the further steps to be taken.
FOUR-EYES PRINCIPLE AND SEPARATION OF FUNCTIONS
The four-eyes principle applies with respect to authorized signatures within the scope of business activities with third parties and for internal approvals, whenever such signatures have the effect of constituting rights and/or obligations. This means that pursuant to the applicable group guideline, two signatures of competent authorized persons of the respective local unit are required. Detailed signing regulations, taking into account local processes and reasonable value limits, are regularly reviewed, adjusted and, whenever necessary, continuously specified and updated.
PALFINGER attaches great importance to the separation of functions, even in smaller units, meaning that one person may not hold several critical functions at the same time. This principle is designed to reduce errors as well as the probability of corruption, but first and foremost to protect employees. It is not possible, for example, for one and the same employee to be authorized to create an order and also be able to post an invoice.
INFORMATION ON THE GUIDELINES AND CORPORATE ETHICS
The Group’s risk management department regularly publishes a risk management newsletter, reporting to PALFINGER’s management any relevant news, in particular recommendations on how to avoid or reveal corruption by third parties. The group guidelines are communicated to the entire management team and then to the local management concerned via standardized processes.
New employees receive a welcome package and attend an on-boarding seminar, both of which emphasize PALFINGER’s values and its anti-corruption policy. The legal department provides all employees in the finance and HR departments as well as all management teams with information material regarding compliance at PALFINGER. In the reporting period, workshops on anti-trust compliance were held in the sales units.
INTERNAL AUDITS AND RISK MANAGEMENT
The corporate risk management department regularly carries out audits of the companies of the PALFINGER Group and engages employees in discussions on ethics and corruption in the workshops held. In 2017, three audits were performed and concluded in Austria, Norway and the USA.
Via the Company’s Integrity Line, possible violations of laws and guidelines that concern companies of the PALFINGER Group may be reported anonymously. The Integrity Line can be reached via the Company’s website; reports are received by the corporate risk management department. In the period under review, one internal substantiated, albeit insignificant, allegation was reported, following which the issue was settled without delay through appropriate measures.
Any compliance violations are reported to the central legal department. In 2017, as in previous years, no major cases of corruption were reported at PALFINGER. Three internal substantiated, albeit insignificant, cases were investigated, following which appropriate measures were taken. Two employees were dismissed. There were no incidents involving business partners.
No public corruption charges were filed against the organization or its employees. Similarly, no major penalties were imposed for any violations of legal provisions. No lawsuits are pending on grounds of anti-competitive conduct. Environmental laws and regulations as well as social and economic laws and regulations were complied with. In addition, there were no violations in connection with any health and safety implications of products or services, with product and service information, labelling, or with marketing and communication.