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 2021, 23 Alert cases (reports of potential violations of the Code) were received by the DSM Alert Officer, three of which were reported by an external party. This is at a level comparable with previous years. Four of these were potential bribery and corruption cases. After investigation, one of these four 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 the People, Planet and Profit dimensions and region. Proven violations result in dismissal or other forms of consequence management. In line with this policy, 45 employees were dismissed in 2021 because of breaches of the Code, legal or local company regulations. In addition, 89 employees received another form of consequence management. Over the years, the number of violations has remained about the same. In 2021, a slight increase in the reporting of dismissal cases and a slight decrease in other kinds of consequence management cases was seen.

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 6 violations of the Code reported in the Planet dimension in 2021. All these cases concerned a failure to strictly observe our procedures.

Profit

Most of the cases in the Profit dimension relate to fraud and conflict of interest