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You Can’t Buy Compliance<br />

In business, compliance means conforming to relevant laws, rules, specifi cations or policies – both internal and<br />

external. Compliance is not an invention of smart lawyers but a basic principle of applicable law; a company’s longterm<br />

business success depends on following the rules. Now, what does compliance mean for <strong>HAVI</strong> <strong>Logistics</strong> and<br />

how do we ensure a holistic approach to compliance?<br />

With ever more regulations and the<br />

need for operational transparency, organizations<br />

are increasingly adopting consolidated<br />

and harmonized compliance<br />

measures. This ensures that all necessary<br />

governance requirements can be met<br />

without duplicating work unnecessarily.<br />

100% compliance –<br />

no exceptions!<br />

<strong>HAVI</strong> <strong>Logistics</strong> has implemented many<br />

compliance tools, the most important of<br />

which is our strong compliance culture.<br />

Ever since the company was established in<br />

1981, we have abided by our statements<br />

that “we uphold the laws of the land” and<br />

“law and order are social values we hold<br />

in the highest esteem” in our corporate<br />

culture and have always expected all our<br />

employees to be role models concerning<br />

these principles.<br />

In 2008, we stated that violations of these<br />

principles would not be tolerated, in our<br />

“Code of Ethical Business Conduct.” As<br />

a consequence, we established a whistleblower<br />

hotline and the Compliance Committee,<br />

which investigates potential violations<br />

of the applicable rules and initiates<br />

appropriate action. Throughout our corporate<br />

history, we have also issued a variety<br />

of guidelines and internal controls to guide<br />

our employees.<br />

Of course, this may seem like a lot. Yet our<br />

continuous growth brings new challenges.<br />

Different countries have different legal requirements,<br />

new customers have new<br />

needs regarding food quality and safety,<br />

and new employees might not always be<br />

aware of our cultural heritage. Given this<br />

development, it is apparent that we need<br />

to do more to ensure that we know what<br />

compliance means and can act compliantly.<br />

In particular, we need a more holistic<br />

and structured approach to compliance<br />

management.<br />

The <strong>HAVI</strong> <strong>Logistics</strong> Compliance Committee<br />

has assigned the task of successively<br />

optimizing our existing compliance management<br />

system to Petra Luzar, Director<br />

Corporate Legal Department. The international<br />

consultancy fi rm KPMG has helped<br />

us hold several workshops. We would now<br />

like to familiarize you with the status of the<br />

task and the next planned steps.<br />

First of all, the Compliance Committee reaffi<br />

rmed that compliance is recognized as<br />

a key success factor at <strong>HAVI</strong> <strong>Logistics</strong>.<br />

Petra Luzar, Director Corporate Legal Department<br />

“We formulated the misson statement:<br />

Compliance Management at <strong>HAVI</strong><br />

<strong>Logistics</strong> should foster the established<br />

culture of complete (100%) adherence<br />

to legal requirements and internal policies<br />

and standards while proactively addressing<br />

corporate risks in light of continuous<br />

growth.”<br />

In several reiterations, many of our internal<br />

specialists from different areas of expertise<br />

including Operations, Finance, HR and IT<br />

then helped identify our biggest compliance<br />

risks. They identifi ed worst case scenarios,<br />

supposing that we had not even<br />

implemented the existing mitigating measures<br />

(e.g. guidelines, internal controls) and<br />

evaluated which of these would harm <strong>HAVI</strong><br />

<strong>Logistics</strong> most – either fi nancially, or indirectly<br />

as a result of harming our customers.<br />

The gross risks will now form the basis<br />

for a thorough gap analysis, i.e. we will<br />

again apply our internal expertise to identify<br />

which mitigating measures we have<br />

implemented in relation to which risk, and<br />

whether these measures are appropriate<br />

and suffi cient to reduce said risk – preferably<br />

until it vanishes. The results of the gap<br />

analysis will be used to determine the optimum<br />

measures to close the gaps. These<br />

will probably include revising existing<br />

guidelines to increase their comprehensibility,<br />

and providing appropriate training for<br />

people expected to follow the guidelines.<br />

This will enable us, over the mid-term, to<br />

ensure that we have a structured and holistic<br />

compliance management system that<br />

enables people within our organization to<br />

access and understand the relevant rules<br />

easily and also enables <strong>HAVI</strong> <strong>Logistics</strong> to<br />

check and document for audit purposes<br />

that these rules have been followed.<br />

Yet the fact that we are optimizing our existing<br />

compliance management system<br />

does not mean we can now relax and wait<br />

for implementation. All of us must be aware<br />

that we are in charge of compliance and<br />

can be held responsible. We all need to<br />

be role models and to live our values and<br />

our culture. We need to know and apply all<br />

the relevant rules and should always ask<br />

ourselves whether what we’re doing is correct.<br />

Furthermore, we should seize the opportunity<br />

to address any questions we may<br />

have about compliance to the Compliance<br />

Committee, which will be able to provide<br />

guidance on all compliance matters.<br />

Any questions can be addressed<br />

to the Compliance Committee<br />

compliance@havilog.com,<br />

or call Petra Luzar at +49 2065 695695.<br />

alphabet I AUGUST 2012<br />

7

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