Consequence management

We apply zero-tolerance consequence management to violations of the Code. Under our whistleblower procedure (DSM Alert), most (potential) violations are reported to and dealt with by local line management. Where this is not considered appropriate, complaints can directly be made to the DSM Alert Officer. In both cases, consequence management practices (such as official warning, temporary suspension, dismissal) are in place for substantiated violations to support compliance with the Code. The DSM Alert Officer reports to the Managing Board and also reports independently to the Audit Committee of the Supervisory Board twice a year. Any individual not employed by DSM who might wish to voice a concern regarding violations of the Code may also contact the DSM Alert Officer via the company website.

In 2020, 22 Alert cases (reports of potential violations of the Code) were received by the DSM Alert Officer, two of which were reported by an external party. This is at a level comparable with previous years. Three of these were potential bribery and corruption cases. After investigation, one of these three Alert cases was substantiated and consequence management was applied.

The table below gives an overview of all reported substantiated violations of the Code (including Alert cases), with a breakdown by Triple P dimension and region. Proven violations result in dismissal or other forms of consequence management. In line with this policy, 37 employees were dismissed in 2020 because of breaches of the Code, legal or local company regulations. In addition, 121 employees received another form of consequence management (official warning or suspension). Over the years, the number of dismissal cases has remained about the same. There has been an increase in the reporting of other kinds of consequence management cases, which may be attributable to increased awareness of the importance to the company of reporting these types of cases.

People

Most of the cases in the People dimension relate to violations of the Life Saving Rules. Inappropriate or disrespectful behavior that does not contribute to a psychologically safe and healthy working environment (discrimination, sexual and other kinds of harassment) is also reported in this dimension. Health and safety are priorities for the company and incident-reporting channels are well known.

Planet

There were five violations of the Code reported in the Planet dimension in 2020 due to irresponsible behavior on the part of an employee, of which two led to a minor environmental incident or product loss, three did not.

Profit

Most of the cases in the Profit dimension relate to fraudulent expense claims and incorrect registration of working hours.