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 2022, 22 Alert cases (reports of potential violations of the Code) were received by the DSM Alert Officer, four of which were reported by an external party. This is at a level comparable with previous years. There were three potential bribery and corruption cases, none of which were substantiated.

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, 53 employees were dismissed in 2022 on account of breaches of the Code, national legislation, or local company regulations. In addition, 150 employees received another form of consequence management. Compared to 2021, the number of dismissal cases slightly increased and the number of cases leading to other forms of consequence management significantly increased. The broadening of the bottom of the so-called ‘incident pyramid’ (significantly more minor incidents than major incidents) may be taken to indicate that the establishment of Compliance Councils in China, India and the APAC region improved our reporting process.

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 eight violations of the Code reported in the Planet dimension in 2022. Five cases, including the four dismissals, concerned violations of our quality procedures, and the other three cases concerned violations of standard operating procedures leading to the formation of production waste and financial losses.

Profit

Most of the cases in the Profit dimension relate to fraud and business integrity, such as unauthorized absence from work.