Disclosure 205-1 Operations assessed for risks related to corruption

Corruption risks are investigated as part of the ongoing internal auditing of Clariant. If corruption is suspected, Compliance Department and possibly other service units will carry out an investigation, with the help of specialized third parties, if necessary. The regional and Group-wide compliance committees assess the findings of the investigation and order disciplinary or other measures against culpable employees, which may also lead to the termination of employment and/or the termination of contracts with business partners, or to such contracts not being extended or changed for precautionary reasons. To prevent corruption riks, we started to do business reviews of high risk business in high-risk enviroments with high-risk customers.

Disclosure 205-2 Communication and training about anti-corruption policies and procedures

In 2017, 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
In 2017, Clariant did not conduct a specific anti-corruption e-learning module.

Face-to-face trainings
Special target groups received further face-to-face trainings in various topics, for example about competition and anti-trust law. In 2017, such a training was given to many colleagues in all regions. New joiners are also familiarized with our Code of Conduct and ABC Policy.
An important awareness campaign was launched to demonstrate the right attitude and tone from the top.

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.

A new format called “Ethical Journal” communicates about cases in the IL and how they were handled to foster trust with the employees and encourage speaking up

Disclosure 205-3 Confirmed incidents of corruption and actions taken

In 2017 there were eight allegations around bribery, corruption, and kickbacks brought forward. Three cases are still under investigation. In the three cases, disciplinary actions were taken but there were no dismissals.

There were no legal proceedings against Clariant or its employees for alleged corruption. In addition, Clariant issued a warning letter against one supplier and terminated five suppliers and one business partner (agent, distributor, or consultant).