Strategy and measures

Our overriding goal is to behave in a compliant manner at all times and to prevent violations of legal and internal requirements – both in our business units and in our supply chain. In particular, this includes the avoidance of corruption and bribery.

We have established a variety of processes and measures to achieve this overriding goal. The various compliance elements are currently being optimized, expanded, and merged into a Group-wide compliance management system under the leadership of Corporate LCA (Legal, Compliance & Audit).

The Melitta Code of Conduct is a central component of compliance in our company: it is binding for all our employees and forms the basis of our day-to-day business activities. Its content is based on key international and national conventions and principles for compliance with laws and directives, sustainable development, and respect for human rights. Our Melitta Code of Conduct is communicated throughout the Group and its principles and compliance are exchanged within teams via our managers. We demand that our suppliers and business partners act with integrity by means of our Supplier Code of Conduct and under certain conditions require that it is included in the supplier contracts. The Supplier Code of Conduct defines minimum requirements for working conditions and environmental standards, which are also based on the relevant international conventions.

Review

Our compliance processes are continuously adapted to changing requirements and needs. To this end, regulatory and market requirements are continuously analyzed – also with the aid of external consultants – and implemented in the management system by means of appropriate structures and processes where necessary. Corporate LCA is responsible for central coordination and management.

Our guidelines are also an important component of our compliance. Any violation of these guidelines will be prosecuted under labor law. Moreover, the corporate division LCA collaborates with all business units, their Management Boards, and the relevant mandated employees to ensure compliance with all statutory, regulatory, and internally defined requirements. In the fiscal year 2022, no significant fines or non-monetary sanctions were issued or initiated against the Melitta Group. The introduction and launch of a Group-wide whistleblower management system is being prepared for 2023. Furthermore, the establishment of a Group-wide compliance management system is planned, which will be coordinated by a central Compliance Office and a corresponding cross-divisional committee for the entire Group.

Responsibility and sensitization

Corporate LCA is responsible for central coordination and control. It defines the Group-wide compliance requirements – where necessary in cooperation with other corporate divisions. Corporate LCA helps the operating divisions establish and implement the corresponding structures and processes, also with regard to clarifying the national legal situation in the respective country. The Managing Director of Corporate LCA reports directly to Chief Corporate Management, both via regular reporting formats and where needed on an ad hoc basis.

Managers and employees are sensitized and trained by means of target group-specific information on the Intranet and in our staff newsletter etc., as well as via targeted and mandatory internal training.

Target achievement

The further development of the existing legally compliant structures and processes into a more mature, and more comprehensive Group-wide compliance management system is slated for 2023/2024. A key element of this is the introduction of a Group-wide whistleblower system for external and internal notifications, which is set to be released in 2023.

Internal Audit’s targets regarding its review of the existing processes in accordance with the Audit Plan were achieved in 2022.

Risks

With regard to our own business activities, we have identified potential risks with regard to the combating of corruption and bribery and have mitigated these as far as possible with the aid of existing compliance measures. Moreover, the risks will be reduced even further by the Group-wide compliance management system that is currently being established. The risk portfolio is currently being expanded beyond our own production processes. The aim is to have integrated the corresponding due diligence processes in our supply chains by the end of 2023 in accordance with the requirements of the German Supply Chain Due Diligence Act (“Lieferkettensorgfaltspflichtengesetz” – LkSG).

Significant risks arising from our business activities, our business relationships, our products and services in the value chains which are very likely to have a serious negative impact on combating corruption and bribery may arise in the further process. However, we currently have no relevant indication of such issues.