We promote good corporate governance and respect our stakeholders. We consider good governance practices, including efficient risk management processes, the foundation for conducting business.
Our climate ambition work helps us and our customers to become more sustainable.
Our governance structure and practices are the foundation for conducting business.
Cargotec does business on a global scale and our industry is exposed to compliance risks for example relating to doing business in remote locations, bidding for large projects for customers which are governmentally owned as well as the use of sales intermediaries in countries where we do not have our own sales offices.
The purpose of the Compliance Programme is to support Cargotec, the CEO and Board of Directors in ensuring that compliance risks are managed effectively and consistently throughout the organisation. This section describes Cargotec’s Compliance Programme and its key elements and focus areas.
The Code of Conduct is the foundation of our corporate culture and sets out high standards of integrity on how we do business everywhere in the world. The Code of Conduct supports us in handling business matters in conformance with laws, regulations, key policy requirements and principles for ethical business conduct. Ethical behaviour is the responsibility of every employee in Cargotec, and it is management’s responsibility to set a clear tone from the top and implement structures to ensure that compliance risks are effectively assessed, controlled and mitigated.
Our Code of Conduct, the Cargotec Anti-Corruption policy, Gift and Hospitality Instruction, Instruction for Speak-Up and Non-Retaliation, as well as the new Third Party Policy guide provide the policy foundation against possible unethical or corrupt business practices. The practical implementation of these policies, and related instructions, is guided by our Ethics and Compliance framework, which is based on the main principles to prevent, detect and respond to potential misconduct. The Ethics and Compliance organisation supports the business by providing proactive advice and trainings and by conducting internal investigations. We have an externally hosted Speak-Up line to enable confidential and, if needed, anonymous reporting of concerns.
The Ethics & Compliance organization promotes a speak-up culture and awareness of the reporting channels, including the Speak-Up line, through a variety of means, including, but not limited to: mandatory annual Code of Conduct e-learning; employee communications; training and education sessions and talks by E&C team members to SBU leadership teams and high-risk personnel; and Code of Conduct briefings to sales third parties.
Code of Conduct concerns and potential misconduct can be reported through a variety of channels, including to line management, HR, our organizational Heads of Compliance within the Ethics and Compliance team or through the Speak-Up line. The Speak-Up line is operated by an external provider and managed by the Ethics and Compliance function. Each Business area in Cargotec has an assigned Head of Compliance who is responsible for building and promoting the compliance program, including the reporting channels, with the SBU.
During 2020, 65 reports of alleged misconduct were made to the Ethics and Compliance (E&C) team. E&C decided to open an investigation in 32 cases (2019: 40). The reports and investigation cases were referred to the monthly Code of Conduct Panel of the Cargotec Leadership Team, which is chaired by the CEO. The Code of Conduct Panel decides upon case closure, remediation and disciplinary action. Six (2019: 3) cases during 2020 concerned HR issues and 4 (9) cases related to possible conflict of interest. Other cases were related to unethical business conduct such as fraud, corruption or policy violations. There were no cases related to environmental grievances, health and safety or privacy matters. One report related to a potential human rights issue was received. During the year, in total 43 cases were closed and improvement actions were initiated. In 84 % of the closed cases the allegations were substantiated at least partly, and some cases resulted in disciplinary actions such as warnings and personnel dismissals.
The Code of Conduct cases were reported to the Board of Directors’ Audit and Risk Management Committee on a quarterly basis, and the Chief Compliance Officer provided an annual update to the full Board of Directors. As part of the investigation process, the Ethics and Compliance team agrees with relevant business area management team members on remedial actions, such as improved controls, training, disciplinary actions or termination of third party relationships. The final decision on disciplinary actions is made by the Code of Conduct Panel.
As of 2020, the Code of Conduct e-learning is an annual mandatory training for all Cargotec employees. The e-learning consists of exercises that help employees with their day-to-day dilemmas around ethics and compliance. The Code of Conduct e-learning has been completed by 82% of Cargotec employees (2019: 68%). The target group of the e-learning course includes employees with an individual company email address and access to the intranet. Onsite training workshops have been arranged for employees without an email address or access to intranet.