We have set up a global compliance organisation to ensure that legal regulations and voluntary commitments are upheld. Our aim is to prevent any violations. If they do occur, we want to identify them as quickly as possible and take appropriate action.
The Chief Compliance Officer is responsible for the implementation of the compliance programme with the support of compliance officers in the divisions and regions. The Executive Board and the Audit Committee of the Supervisory Board are provided with regular updates on compliance activities.
The core guidelines that govern the way we do business are set out in our Code of Ethics, which is binding for all employees worldwide. The Code of Ethics is supplemented by further guidelines on specific areas. Our Group-wide compliance activities focus on anti-trust law, corruption prevention, sanction and export control law, and data protection. When further enhancing our compliance programme, we also follow the recommendations of the United Nations Global Compact, as well as Transparency International’s Business Principles for Countering Bribery.
Linde provides employees with information on the legal regulations and guidelines that apply to their specific activities. New staff members receive a copy of our Code of Ethics when they join the company, and they have to confirm that they have read and understood it. We also train employees on the contents of the Code of Ethics and other compliance guidelines in face-to-face training sessions as well as in our Group-wide e-learning programme.
Employees who wish to report any suspected violations of legal regulations, our Code of Ethics or other guidelines, or who have questions regarding their implementation, can approach their direct line manager or department head. They can also contact a representative from the Internal Audit, Human Resources or Legal & Compliance departments.
Another key pillar of our compliance programme is the Linde Integrity Line, a global whistleblowing system. It enables employees and external stakeholders to report doubts and suspected violations by e-mail, telephone or post, anonymously if they wish. Every report is investigated and, where appropriate, forwarded to the Linde Integrity Committee. The committee comprises members of the Internal Audit, Legal & Compliance, Corporate Responsibility and Human Resources departments. The Integrity Committee examines the reports and determines further courses of action. Our Integrity Line policy outlines the exact procedure to be followed, and ensures that reports remain confidential and that any data is protected.
If our internal investigation reveals that a report is substantiated, we subsequently explore the measures that have already been implemented – following a set process and timeframe. The responsible line managers are involved and they provide their input in every case. If our compliance systems uncover any incidents that appear to breach criminal or anti-trust law, we also cooperate closely with the responsible authorities.