Ethics and Compliance
Compliance with legal, regulatory and internal regulations, as well as the observance of common standards and rules of professional conduct, is essential to Kuehne + Nagel’s business.
A comprehensive Ethics and Compliance Programme begins with leaders. Our leaders are in charge of setting the priorities and driving our culture. Therefore, Kuehne + Nagel expects its leaders to integrate a culture of compliance within their respective areas of the business. By considering integrity to be a key element of our business behaviour we are able to foster a sense of trust with our stakeholders and meet our responsibility of being a reliable and successful business partner. Independent of function, geography or business area, Kuehne + Nagel’s Ethics and Compliance Programme provides guidance and suggests measures to our members and business partners throughout the entire Group.
We are convinced that our Ethics and Compliance Programme – as a way of risk prevention – protects us from negative consequences such as sanctions or reputational damage. This programme is a unique opportunity for making a difference in a competitive global market place. It is essential for our business success to pay attention to this programme at each organisational level and to be supported by Kuehne + Nagel's senior executives and managers around the globe.
languages available for the
Code of Conduct
Code of Conduct 2018
Kuehne + Nagel’s Code of Conduct forms the basis of the Ethics and Compliance Programme. The Code of Conduct states the general principles of the Group’s business conduct and behavioural requirements that Kuehne + Nagel members have to comply with. The Code of Conduct does not explicitly comment but refers under “employment practices” to "Kuehne + Nagel Values", and "Core Principles", in addition the Supplier Code of Conduct explicitly covers the topic “freely chosen employment”. As a basic principle, all suppliers are expected to sign the Kuehne + Nagel Supplier Code of Conduct.
The Code of Conduct also addresses respected and fostered principles such as employment conditions, as well as remuneration, aim to stimulate high performance and to consistently reward excellent results. Employment must never be illegal and unfair. GRI 202–1
In 2018, Kuehne + Nagel established an enhanced version of the Code of Conduct, its implementation and dissemination started in January 2019. The new Code of Conduct is structured in three different sections: Employment Practices, Safeguarding People and Assets and Business Ethics. The new Code of Conduct is now available in 43 languages (previously: 39 languages). The English version is available on our website www.kn-portal.com/about_us/corporate_social_responsibility/compliance/
The Code of Conduct is complemented by internal policies and guidelines. These supplementary materials address specific compliance topics and provide guidance to every Kuehne + Nagel member on standards and procedures that are specific to particular compliance risks; including Anti-Trust, Anti-Bribery, Conflict of Interest or Gift and Entertainment.
All members are required to acknowledge the Code of Conduct when starting employment with Kuehne + Nagel. In addition, a comprehensive educational programme ensures continuous awareness and a monitored level of consistent training. Members are trained on the Code of Conduct through live and computer-based training as well as on-demand training following risk-based considerations. On a yearly basis, all Kuehne + Nagel members are asked to confirm having received, read and understood the Code of Conduct. Kuehne + Nagel monitors the Code of Conduct live and computer-based training as well as the annual confirmation for ensuring constant participation rates of at least 95%. Failure to follow the Code of Conduct may result in disciplinary action. GRI 102–16
ABC Live Training
top and senior managers participated
in ABC Live Training in over 150 sessions
members participated in Antitrust
Live Training in over 80 sessions
For dedicated and risk-based selected target audiences live training has been delivered in the areas of anti-bribery/corruption (“ABC”) and antitrust (“AT”). This is launched in annual regular waves, and is scheduled to continue.
Selected audiences are continuously informed in order to maintain awareness or announce new or enhanced initiatives. Further, internal electronic information platforms grant access to Compliance-related information.
Kuehne + Nagel members are encouraged to raise concerns about potential violations of the Code of Conduct to persons of trust within Kuehne + Nagel. Further, a global confidential reporting line has been implemented in all countries with Kuehne + Nagel facilities. This line allows for reports on potential violations in a safe, confident, and, if desired, anonymous manner. The confidential reporting line can be reached 24 hours a day, seven days a week and is operated by an external service provider enabling reporting in more than 100 native languages; either by telephone, e-mail or a dedicated web-based reporting tool.
One third of the reported allegations are non-HR related matters and two thirds HR-related matters. Following independent investigations, almost half of all allegations were substantiated and remediated accordingly; including measures such as improvements in processes and controls to prevent reoccurrence and also sanctions such as warnings and terminations.
The Kuehne + Nagel Independent Allegation Management Committee oversees the handling and follow-up of reported allegations received through any channel. The Committee ensures consistent professional standards and procedures for enabling thorough independent investigations where needed. Subject matter experts are involved to ensure competent and adequate assessments, appropriate decision making, and related follow-up activities.
Complaints or allegations made in good faith will not expose the submitter to counter-measure. However, knowingly providing false or misleading information may result in sanctions.
At Kuehne + Nagel, we respect the privacy of all individuals that have entrusted us with their personal data. Anyone concerned can raise suggestions, inquiries and complaints in a safe, confident and, if desired, anonymous manner.
As a globally operating company, Kuehne + Nagel is required to comply with a wide range of data protection laws and regulations. Therefore, our Global Data Protection Framework sets a worldwide data protection standard. Within the Kuehne + Nagel Group, it stipulates rules for the processing of personal data of internal and external stakeholders. On this basis all Kuehne + Nagel companies are enabled to comply with national and international data protection and privacy laws, including the EU General Data Protection Regulation.
The Kuehne + Nagel Data Protection Framework supports the management under the Data Protection Programme and provides subject matter expertise, guidance and training to the business and functional units, management and employees. Internal audits complement our endeavours to foster the effective operationalisation of the standards.