BASF is committed to upholding a high standard of legal compliance and business ethics. Our group-wide Compliance Program aims to ensure adherence to legal regulations, the company’s internal guidelines, and ethical business practices. Our Code of Conduct firmly embeds these mandatory standards into the day-to-day operations of our employees.
BASF’s Compliance Program is based on our corporate values and voluntary commitments, as well as international standards. It describes our commitment to responsible conduct and our expectations of how all BASF employees will interact with business partners, officials, co-workers and the community. At the core of our Compliance Program is the global, standardized Code of Conduct. All employees and managers are obligated to adhere to its guidelines, which cover topics ranging from corruption and antitrust laws to human rights, labor and social standards, conflicts of interest and trade control, and data privacy protection.
Abiding by compliance standards is the foundation of responsible leadership. This has also been embedded in our values. We are convinced that adhering to these standards will be critical in ensuring our company's long-term success. Our efforts are principally aimed at preventing violations from the outset.
One key element in the prevention of compliance violations is compulsory training and workshops held offline like in classrooms or online courses. All employees in Greater China are required, within a prescribed time frame, to take part in basic compliance training, refresher courses and special tutorials dealing with, for example, antitrust legislation, taxes or trade control regulations. In 2021, more than 2,200 participants in Mainland China received approximately 30 sessions of compliance training.
We firmly believe that for corporate responsibility to be successful, there must be an active culture within the company that lives by these guidelines. We expect all employees to follow these compliance principles as stipulated in our current global Code of Conduct (revised in June 2020). Managers play an important role here – they serve as examples and communicate our values and culture both internally and externally.
At the global level, BASF’s Chief Compliance Officer (CCO) reports directly to the Chairman of the Board of Executive Directors and oversees the further development of our global compliance organization and our Compliance Management System. The CCO is supported in this task by the Corporate Compliance unit and more than 100 compliance officers worldwide in the divisions, regions, and countries, including Greater China.
We encourage our employees to seek guidance actively if in doubt by consulting their managers, specialist departments, such as the legal department, and company compliance officers. In addition, we have set up more than 50 external hotlines worldwide that our employees can use – including anonymously – to report potential violations of laws or company guidelines. We improved and standardized these hotlines in 2021. All hotlines and the website can be accessed by the public. Each concern is documented according to specific criteria, properly investigated in line with standard internal procedures and answered as quickly as possible. The outcome of the investigation, as well as any measures taken, is documented accordingly, and included in internal reports.
In 2021, our external hotlines and other channels in Mainland China received a few calls and emails. The information received related to all categories of our Code of Conduct. We carefully investigated all cases of suspected misconduct that came to our attention and, when necessary, took countermeasures on a case-by-case basis. These included, for example, improved control mechanisms, additional information and training measures, clarification, and expansion of the relevant internal regulations, as well as disciplinary measures as appropriate.
In 2021, our compliance team, along with various other teams and stakeholders, paid close attention to China’s Corporate Social Credit System (CSCS). To best safeguard BASF’s compliance performance and rating level under CSCS, the company has established an internal risk assessment mechanism and a monthly monitoring process, and offered timely regulatory updates, numerous compliance training, and one-on-one systematic dialogues with the relevant key stakeholders.