against members of the Management and Supervisory
Boards while they are performing their activities. For Management
Board members, the insurance contract stipulates
a deductible of ten percent of the damages, but a maximum
of one-and-a-half times the amount of the fixed annual
compensation of the respective member of the Management
or Supervisory Board per insurance year. Further information
on the compensation of the Management and Supervisory
Boards can be found on page 76 f. of the complete
Consolidated Financial Statements.
Compliance
Compliance with laws is the basis for all of ALTANA’s actions.
In addition, we set ourselves certain rules as part of our
corporate social responsibility, which we adhere to like laws.
At ALTANA, compliance is an integral part of our corporate
social responsibility. The trust of our customers, business
partners, employees, and the public is the basis and
condition for our business success.
For this purpose, ALTANA established a Compliance
Management System in 2008. Its goal is to ensure that laws
and the rules we have set ourselves are observed through-
out the Group. To this end, the Compliance Management
System identifies significant risks that can arise from violations
of laws or regulations by ALTANA employees. The Compliance
Management System also ensures that employees
are aware of the content and significance of the laws and
regulations relevant to them and know how to behave
best in light of them. Furthermore, the Compliance Management
System is intended to ensure that the necessary con-
trol mechanisms are implemented so that violations of laws
and regulations can be detected and remedied. The Com-
pliance Management System encompasses eight compliance
areas: corruption, antitrust law, environmental protection
and safety, human resources, customs and foreign trade, data
protection, financial reporting, and taxes.
The ALTANA Compliance Management System follows the
ALTANA structure and is therefore decentralized. The local
management is primarily responsible for making sure that the
individual subsidiaries and their employees behave in accordance
with the rules. ALTANA AG lives up to its compliance
responsibility by providing a framework, making competencies
and instruments available, creating platforms and
forums for local authorities, and by taking concrete measures
to ensure compliance on the part of the management
of subsidiaries or to impose minimum requirements, especially
through guidelines that are binding Group-wide.
ALTANA’s Code of Conduct, which holds for the entire
company, contains binding rules regarding responsible, ethical,
and lawful behavior for all staff members. This applies in
particular to issues such as corruption, conflicts of interest,
antitrust law, environmental protection, and discrimination.
Together with the company’s Guiding Principles, the Code of
Conduct provides orientation for responsible corporate
action. The Code of Conduct and the Guiding Principles are
published on our website (www.altana.com). Since 2010,
ALTANA’s employees have been trained with the help of an
e-learning program regarding the content of the Code of
Conduct and further issues relevant to compliance such as
corruption and antitrust law.
Moreover, for each compliance area further specific
measures have been developed and implemented to ensure
that laws and internal regulations are adhered to. This
includes, for example, a system through which business partners
who support ALTANA’s holding company and its subsidiaries
in terms of sales or in their cooperation with authorities
are investigated for certain compliance risks with IT
support.
Another important element to guarantee the effectiveness
of the Compliance Management System is the work
of Internal Audit. For a few years now, compliance programs
have been carried out regularly at ALTANA and its subsidiaries.
72 Declaration on Corporate Governance