DNVGL.in

Compliance & Anti-corruption

Why is this material?


We have the policy to be at all times compliant with all applicable laws, including anti-corruption and privacy legislation to meet DNV GL’s long-term objectives, to mitigate identified business risks, to improve business performance and to build trust amongst our employees, customers and other key stakeholders. 

We have defined compliance as legally and ethically impeccable conduct by all employees in their daily work because the way they carry out their duties affects the company’s reputation. We do not tolerate any violation of applicable laws, our Code of Conduct or internal regulations.

A clear tone from the top coupled with tangible ownership of compliance at all management levels is essential. To help our managers meet this responsibility, a compliance programme has been set up, focusing on integrity in business dealings, anti-corruption, commitment to fair competition, upholding of foreign trade laws and privacy law. The effectiveness of compliance is based on the global governance of our compliance organization and clear-cut reporting lines, and close cooperation between the Group Compliance Officer and our business areas.

Compliance programme: Prevent


Risk assessment

The core of a successful compliance programme lies in a reliable risk management process, based on risk analyses in conjunction with the early detection of risks and the provision of measures. The risk management process was evaluated in 2014 with focus on fraud and corruption risks to ensure that these two aspects of risk management were sufficiently covered by the programme. All operational business has assessed their risks, including corruption risks such as those related to subcontractors, sponsors but also very general in relation to the understanding of governing documents. Proposed improvements have been implemented.

Our company’s current assessment process was amended to achieve a higher transparency on fraud and corruption risks. An extra effort has been taken to define countries that we consider as high risk countries for DNV GL. For these countries we will define and implement additional preventive measures on fraud and corruption.

Our Code of Conduct

Following the merger between DNV and GL, a new joint Code of Conduct was prepared with the involvement of relevant internal stakeholders and adopted in September 2013. The Code of Conduct was presented to the Audit Committee in December 2013 and was approved by the Board of Directors in February 2014. Every employee received a printed copy of the Code of Conduct. In addition an e-Learning module on the Code of Conduct was prepared requiring the trained to confirm understanding of the contents. In 2015, the e-Learning module will be rolled-out as mandatory training for all employees. Further training initiatives on the Code of Conduct will follow regularly. 


Our Code of Conduct is at the heart of our compliance programme and contains rules that apply throughout the company. Our CEO strongly maintains that all employees have to observe all laws and regulations and emphasizes the importance of the Code. 


Wherever we go, our behaviour as representatives of DNV GL will be remembered. Of course, we must comply with the local laws and regulations of the places in which we operate, but we believe that doing the right thing goes beyond that. This is why we have a Code of Conduct – to outline principles for what we in DNV GL consider to be ethical behaviour, for both the conduct of our business and our personal conduct.


The section on the conduct of business addresses several topics, such as quality, conflict of interest, the competition conduct, corruption and gifts, working environment, environmental stewardship, confidentiality and risk management. The personal conduct addresses the expectation to conduct ourselves and our business with respect and sensitivity. It covers aspects such as independence, impartiality and integrity and communication. Furthermore, the code contains a chapter on how to report violations or concerns of a violation of the Code of Conduct.


Read our Code of Conduct


Instructions

Instructions on anti-corruption and on gifts and hospitality set the framework for all managers and employees and provide clear internal guidance for everything we do.

The instruction on subcontractors, agents and other intermediaries was implemented to ensure a proper selection and contracting process before we start working with them. This includes the assurance of an appropriate integrity level.

Communication

We believe that communication and training are key elements in establishing a successful compliance programme which is endorsed by all our personnel. Communication has to be channelled through the top management and line management in order to show their commitment to our programme in close cooperation with the Group Compliance Officer. The Compliance Officer has presented and discussed the compliance programme with the Board of Directors and the Board Audit Committee, the Executive Committee and the Executive Leadership Teams.

We have established worldwide compliance networks, consisting of all Country Chairs and business nominated employees. Their role is to actively raise awareness for compliance issues in their respective countries across the business areas and to facilitate the communication in relation to compliance matters.
In 2014, all Country Chairs have been addressed and informed about the compliance programme.

Group Compliance offers to all employees around the world the opportunity to ask questions about the compliance programme and how its policies and instructions should be understood and practically applied including local requirements. The team ensures that questions are answered accurately and with the help of experts, if necessary. Through this we help our employees in clarifying compliance relevant issues in advance, but at the same time questions on compliance matters are important indicators of topics that are currently of particular importance to our employees in this respect.


Training 

In recent years, all our employees have carried out mandatory e-Learning trainings on anti-corruption. In 2014, new web-based training modules were implemented on the new Code of Conduct and on anti-corruption and anti-trust measures.

The training module related to the Code of Conduct was created to enable our employees to carry out their duties in an ethical and responsible manner. Going through this training, they will recognize the importance of the topics addressed in the Code and acknowledge their personal responsibility to follow the Code. They are trained to make the right decisions in ethical and compliance matters.

The second training module provides insight into the definition of corruption and anti-trust in order to make our employees aware of possible risks, of how to identify critical situations, and of how to deal with them.

Both training modules include sections on the process of reporting misconduct and our employees also have to confirm that they have read and understood the Code of Conduct.
The new training modules were made mandatory for new employees and will become mandatory for all employees in the course of 2015. By the end of 2014 approximately 1200 employees completed the trainings, including those employees who did it voluntarily. For new employees, the trainings have to be completed within the first six months after entering DNV GL. The statistic in table 1 includes also those employees who started in the second half of 2014 and were therefore not obliged to finalize the training until the end of the year. 

New employees have to attend the classroom training “We in DNV GL” as part of their introduction programme. This course also includes an introduction to our compliance programme.

Furthermore, we conducted a number of workshops and classroom trainings in several locations throughout the world on all relevant topics, such as corruption and anti-trust.
In the course of the implementation of a new instruction on subcontractors, agents and other intermediaries in the beginning of 2015, measures with regards to the communication towards business partners and suppliers will be initiated. 

See table 1 for completion rates of module 1 and of module 2 per business area of all new employees in 2014.

Table 1

Business Area
Division
Code of Conduct course
Anti-Corruption & Anti-Trust Training
Business Area
New employees 2014 per business area
Division
 
Code of Conduct course
Completion rate
Anti-Corruption & Anti-Trust Training
Completion rate
Business Area
Business Assurance
Division
Division Americas
Code of Conduct course
48%
Anti-Corruption & Anti-Trust Training
43%
Business Area
 
Division
Division Asia & Australia
Code of Conduct course
56%
Anti-Corruption & Anti-Trust Training
56%
Business Area
 
Division
Division Central South Europe & Middle East
Code of Conduct course
37%
Anti-Corruption & Anti-Trust Training
36%
Business Area
 
Division
Division North & West Europe
Code of Conduct course
50%
Anti-Corruption & Anti-Trust Training
48%
Business Area
Business Assurance Total
Division
 
Code of Conduct course
48%
Anti-Corruption & Anti-Trust Training
46%
Business Area
Energy
Division
Division Energy Advisory
Code of Conduct course
74%
Anti-Corruption & Anti-Trust Training
71%
Business Area
 
Division
Division Power TIC
Code of Conduct course
70%
Anti-Corruption & Anti-Trust Training
70%
Business Area
 
Division
Division Renewables Advisory
Code of Conduct course
83%
Anti-Corruption & Anti-Trust Training
74%
Business Area
 
Division
Division Renewables Certification
Code of Conduct course
50%
Anti-Corruption & Anti-Trust Training
75%
Business Area
 
Division
DNV GL Energy Staff
Code of Conduct course
0%
Anti-Corruption & Anti-Trust Training
0%
Business Area
Energy Total
Division
Code of Conduct course
76%
Anti-Corruption & Anti-Trust Training
72%
Business Area
Global Shared Services
Division
GSS Finance
Code of Conduct course
42%
Anti-Corruption & Anti-Trust Training
35%
Business Area
 
Division
GSS HR & HSE
Code of Conduct course
71%
Anti-Corruption & Anti-Trust Training
68%
Business Area
 
Division
GSS IT
Code of Conduct course
82%
Anti-Corruption & Anti-Trust Training
82%
Business Area
Global Shared Services Total
Division
 
Code of Conduct course
57%
Anti-Corruption & Anti-Trust Training
53%
Business Area
Group
Division
Group Staff
Code of Conduct course
67%
Anti-Corruption & Anti-Trust Training
56%
Business Area
Group Total
Division
 
Code of Conduct course
67%
Anti-Corruption & Anti-Trust Training
56%
Business Area
DNV GL - Software
Division
DNV GL - Software
Code of Conduct course
77%
Anti-Corruption & Anti-Trust Training
73%
Business Area
DNV GL - Software Total
Division
Code of Conduct course
77%
Anti-Corruption & Anti-Trust Training
73%
Business Area
Maritime
Division
Advisory Services
Code of Conduct course
60%
Anti-Corruption & Anti-Trust Training
60%
Business Area
 
Division
Division Classification
Code of Conduct course
94%
Anti-Corruption & Anti-Trust Training
94%
Business Area
 
Division
Division Europe, Africa and Americas
Code of Conduct course
87%
Anti-Corruption & Anti-Trust Training
88%
Business Area
 
Division
Division Germany, Middle East and Asia
Code of Conduct course
81%
Anti-Corruption & Anti-Trust Training
83%
Business Area
 
Division
Division Technology and R&D
Code of Conduct course
50%
Anti-Corruption & Anti-Trust Training
50%
Business Area
 
Division
DNV GL Maritime Staff
Code of Conduct course
38%
Anti-Corruption & Anti-Trust Training
38%
Business Area
 
Division
Offshore Classification
Code of Conduct course
75%
Anti-Corruption & Anti-Trust Training
75%
Business Area
Maritime Total
Division
 
Code of Conduct course
82%
Anti-Corruption & Anti-Trust Training
83%
Business Area
Oil & Gas
Division
Division Americas
Code of Conduct course
69%
Anti-Corruption & Anti-Trust Training
71&
Business Area
 
Division
Division Asia Pacific & Middle East
Code of Conduct course
78%
Anti-Corruption & Anti-Trust Training
70%
Business Area
 
Division
Division Europe & Africa
Code of Conduct course
82%
Anti-Corruption & Anti-Trust Training
79%
Business Area
 
Division
Divisision Inspection
Code of Conduct course
31%
Anti-Corruption & Anti-Trust Training
31%
Business Area
 
Division
DNV GL Oil & Gas Staff
Code of Conduct course
33%
Anti-Corruption & Anti-Trust Training
33%
Business Area
Oil & Gas Total
Division
 
Code of Conduct course
70%
Anti-Corruption & Anti-Trust Training
67%
Business Area
Grand Total
Division
 
Code of Conduct course
70%
Anti-Corruption & Anti-Trust Training
67%

Compliance Programme: Detect


Seeking advice on ethical and lawful behaviour and reporting of misconduct

Our instruction on reporting of misconduct covers the process of seeking advice as well as the reporting of issues concerning all matters addressed in the Code of Conduct. An overview of designated channels is presented, but in general such issues should be handled through the normal route of line management. If this is not feasible, the contact person may use our ethical helpline liaising with the Compliance Officer directly or through the Ombudsmen. 

Our employees and customers are encouraged to report actual or suspected misconduct, such as, but not limited to, concerns related to bribery, fraud or labour grievances by colleagues, suppliers, subcontractors or agents working on behalf of our company. For customers no reporting mechanism is in place yet.
There are a number of channels for reporting misconduct. These are set out in our instruction on reporting of misconduct, which is published on our intranet. 

In general issues should be handled through the normal route of line management, in case this is not feasible, the contact person may notify the incident to the Compliance Officer directly or to the Ombudsmen. Therefore, the Compliance Officer and Ombudsmen act as a safety valve as they bypass the normal route of line management when necessary due to the character of the misconduct or lack of appropriate follow-up of reported misconduct. Through the internal and external Ombudsman and their hotline we can ensure anonymous reporting of incidents or concerns for our employees and our customers. 

The Compliance Officer evaluates the incident and hands the responsibility over to the line management. If there is a conflict with the line manager, the case has to be reported to his/her superior. The line management decides with the support of the Compliance Officer if further support of internal or external sources is needed. It is the line manager’s responsibility to organize a fact finding process and to issue a report on facts and measures taken by the end of the process. 

If a business partner is involved in an incident a decision has to be taken whether the contract needs to be terminated. In 2014, no statistics are available with regards to the termination of contracts with business partners. 

Compliance Audits

Internal Audit is carrying out regular audits including topics on the compliance programme. In 2015 more detailed questions will be developed related to the compliance programme. We will also develop risk based internal audit programmes in countries which are considered high-risk countries.

Internal Ombudsman: 
Sven Mollekleiv
Senior Vice President
Manage services and discipline
Group Sustainability
Sven.Mollekleiv@dnvgl.com
Tel. +47 67 57 82 99

External Ombudsman:
Ombudsman Dr. Jur. Felix Dörr
Dr. Günter Dörr & Partner (Gbr)
Goethestr. 34
60313 Frankfurt am Main
ombudsman@doerr-frankfurt.de
Tel. +49 69 138 13 33
Fax: +49 69 28 44 99

Compliance programme: React


Consequences of misconduct

As stated in the Code of Conduct proper responses play an important role in preventing violations from happening in the first place. On this action level we react to specific compliance violations and employ lessons from past cases to continuously improve our compliance programme.

Violations of the code will not be tolerated and will lead to internal disciplinary actions, dismissal or even criminal prosecution.

Cases are being filed in a transparent and accurate manner in a case register administered by Group Compliance and reported quarterly to the Board of Directors (Audit Committee) and the Group CEO.