Training and awareness
The DSM values training program contains several e-learning courses to explain the Code and a number of its business principles in more detail. These courses are aimed at raising awareness of ethical business behavior and are assigned to all employees or, in the case of certain subjects, to specific target audiences. All courses are available in at least six languages, unless indicated otherwise. When we acquire a business, integration and compliance plans are rolled out to make sure new employees are trained accordingly.
A review team, chaired by the Vice President Risk Management & Internal Control, monitors the internal and external developments around corporate ethics to promote and safeguard the company’s values and reputation. The review team also monitors implementation of the DSM values training program (see table Implementation of the DSM values). At year-end, most employees had completed or refreshed their training (excluding employees of some recently acquired businesses). Our learning management system also has an external portal to enable relevant contractors and other third parties to follow courses of the DSM values training program.
The DSM values training program covers the three dimensions of People, Planet and Profit. An overview of the courses and the changes in 2021 is listed below, as well as a number of important implementation measures.
People
The Life Saving Rules specify the 12 most important rules that must be followed by all our employees to prevent incidents.
The Respectful Behavior e-learning emphasizes the importance of inclusion and diversity, and promotes respectful behavior as well as active bystander behavior. It is meant to foster effective employee relations, communications, and non-discriminatory practices, and to prevent inappropriate behavior, including sexual harassment.
The DSM Binding Corporate Rules for Data Privacy prescribe mandatory Data Privacy training for employees who regularly work with personal data from employees and business partners. This is provided by the General Data Protection Regulation (GDPR) overview e-learning, which is rolled out to a large target audience including all employees working in the functions People & Organization, Marketing & Sales and Purchasing. In addition to this, concise e-learnings are in place to train all our employees on the consequences of the GDPR and the importance of prompt data breach notification.
Planet
The Basic Course Responsible Care addresses the elements of the Responsible Care Program: Safety, Health, and Environment; Product stewardship; Security; and Sustainability.
Profit
The e-learning course Global Competition Law Principles and Practices addresses the main principles of anti-trust legislation. Relevant employees annually confirm their compliance with the rules via a Competition Law Compliance Statement. In this statement, they confirm that they are not aware of any violation of competition laws by DSM. For a smaller group of employees, mandatory Competition Law classroom trainings on specific topics are organized. Alleged breaches, if any, are reported to, and discussed with, Group Legal Affairs. In 2021, no breaches were reported.
The course for Global Trade Controls (available in English) explains the most important aspects of international trade legislation. Compliance with trade controls is embedded in our systems and processes. Company master data is screened to check customers and suppliers against embargoes and lists of sanctioned parties.
The Anti-Bribery & Corruption (ABC) e-learning provides training on the most important features of bribery and corrupt behavior. In addition, the DSM ABC Policy and Compliance Manual (available in English and Chinese) is shared with selected employees in commercial and business roles, who must also follow ABC classroom training (integrated into the Competition Law classroom program).
The DSM Security e-learning covers our seven Key Security Behaviors. To complete this e-learning, employees are required to read and sign off on the DSM Code of Conduct for Information Security. The Cyber Fraud Awareness e-learning is an additional training to increase awareness among all employees regarding prevalent types of cybercrime. Furthermore, global as well as targeted phishing tests are regularly carried out to ensure that our people stay alert.
We also have rules to prevent misuse of inside information on the holding of or trading in DSM financial instruments, such as shares and other securities, and where applicable the holding of or trading in financial instruments of other companies. These rules apply to all relevant employees, including the Executive Committee, the Managing Board, and the Supervisory Board.
