In 2015, Clariant has continued the training throughout the entire organization in view of avoidance of possible violations against the Code of Conduct, both with e-learnings as with classroom-based (“face-to-face”) courses. Training is group specific, based on cases, and modern training tools are used (films, comics, etc.) It is mandatory for all employees of the target group and non-participation is sanctioned.

E-Learnings: The e-learning on data privacy which was initiated 2014 was further continued, and 5430 employees have completed the module in 2015, which represent 99% of the assigned training population of this year. The same accounts for the anti-corruption e-learning, which was successfully completed by 8’400 employees, which represent 98% of the assigned training population. Also more than 1400 employees have participated in regular e-learning on antitrust and competition law.

Face-to-face trainings: In addition to online-trainings, special target groups received further face-to-face trainings, for example about competition and anti-trust law; in 2015, such a training was given to more than 850 employees. in Brazil, Chile, China, Great Britain, India, Indonesia, Ireland, Italy, Mexico, Norway, Peru, Poland, Portugal, Spain, Sweden, Switzerland, Thailand, Turkey, and the USA. In addition, 333 employees were trained face-to-face in various other Code of Conduct topics, such as Compliance Induction, Compliance Policies, Business Partner Due Diligence, Gifts & Entertainment, Sponsorships, Anti-Bribery.

Integrity Line: In addition to the Group headquarters, the compliance officers at both regional and local levels are available for questions regarding ethically-correct and legally-compliant conduct of employees. A reporting and query portal for all employees, the so called »Clariant Integrity Line« allows for submitting questions pertaining to ethically correct business conduct in the local language – also anonymous, if possible by law –which the responsible Compliance Officer of the corresponding country answers or forwards to the Region or Group Compliance Officer.

In 2014, Clariant unified the process of reporting, compilation of information, investigation and disciplinary action of the violation to the Code of Conduct. In the relevant guidelines, the responsibilities are clearly delineated between the Service Units Group Compliance, Group HR and Group ESHA in regards to the investigation of Code of Conduct violations.