Anti-corruption

We buy large volumes, operate with large projects and we are active in sectors where there have been incidences of cartels and corruption. Furthermore, we are a global company with presence in parts of the world where corruption has been and still is more widespread.

Internal compliance concept
NKT is a strong advocate for fair competition. We consider it to be an important asset to our customers that we are not party to unlawful, anti-competitive practices. We want to ensure that our policies on this issue are in focus and complied with. Therefore, an anti-corruption review is part of the aforementioned Statement of Representation signed by all NKT unit managers once a year. The document is affirming, among other things, that management action has been taken to ensure that employees with extensive interface with suppliers or customers are aware of NKT’s anti-corruption policy and the consequences of non-compliance. In addition, we register and will report all filed incidences of corruption, cartels and money laundering. During this reporting period we have not registered cases of corruptive behaviour or money laundering.

Statement of Objection
After the closing of this reporting period NKT Cables and NKT Holding received a Statement of Objection from the European Commission in connection with an investigation of the submarine and underground high voltage cable markets in the period 1999-2008. NKT is now providing its observations to the European Commission. The investigation could take one or two years before being settled.

Facilitation payments
Until now we have reluctantly accepted that facilitation payment may to some extent be necessary to ensure that agreed services can be offered or supplied, or that the reasonable safety or rights of employees can be provided. A system to record and track facilitation payments has been established and has been very helpful in creating awareness of the proportion of this matter. A few cases have been recorded in this reporting period.

The increased awareness has led many of our businesses to work with setting up internal awareness campaigns and/or introducing codes of conduct to support the approach of a revised standpoint of non-acceptance of facilitation payments.

Moving forward we intend to focus also on people out of our own ranks, including agents. We will start by taking measures to ensure that our business partners are contractually obliged to act in accordance with our policies.

Whistleblower system
A whistleblower system is in place to improve our ability of discovering irrigularities. It allows employees to report serious concerns about a number of irrigularities or inappropriate behaviour. Reports can be made anonymously in any chosen language, and in writing or orally. Two of the registered reports for 2010-2011 have lead to material adjustments in business procedures. None of these were of a corruptive nature.