Sustainability Report 2016

Ethics and Compliance


Compliance with all legal, regulatory and internal regulations as well as the observance of common standards and rules of professional conduct is essential to our business. We are convinced that a comprehensive ethics and compliance programme relies upon our leaders. They are in charge with setting the priorities and personally drive the Kuehne + Nagel culture. Kuehne + Nagel expects its leaders to integrate the compliance culture within their businesses.



Ethics and Compliance Programme

All our business activities must be based upon the highest ethical and legal standards. Only by considering integrity as a key element of our business behavior we are able to foster a sense of trust with all of our stakeholders and meet our responsibility of being a reliable and successful business partner.



Kuehne + Nagel’s Ethics and Compliance Programme is of utmost importance to our business environment that provides guidance and measures to all Kuehne + Nagel members and business partners throughout the entire group, independent of function, geography or business area.


We are convinced that our Ethics and Compliance Programme is an instrument of risk prevention to protect us from negative consequences such as sanctions or reputational damages and a unique opportunity to make the difference in the competitive and global market place. It is essential for our business success to at all times pay highest attention to this programme at every level of our organisation with the best possible support from Kuehne + Nagel's senior executives and all managers around the globe.



Code of Conduct

Kuehne + Nagel’s Code of Conduct released by the Chairman of the Board of Directors and the Chief Executive Officer, forms the basis on which the Ethics and Compliance Programme is built upon. The Code of Conduct establishes the general principles of Kuehne + Nagel’s business conduct within the entire group. It determines the basic requirements regarding the behaviour of every Kuehne + Nagel member. These principles also clarify prohibited conduct and provide behavioural guidance. The Code of Conduct must be applied consistently and continuously. It extends beyond the legal regulations and builds a standardised cornerstone for integrity.


The Code of Conduct applies to all Kuehne + Nagel members, irrespective of department, country, entity or business unit, each expected to understand the principles and be aware of the meaning and significance of the Code of Conduct and guidelines. Therefore, consistent trainings are being performed to all of the aforesaid persons.


All Kuehne + Nagel members are also expected to propagate the principles of the Kuehne + Nagel Code of Conduct to everyone in their sphere of influence. On a yearly basis, all Kuehne + Nagel members are asked to confirm having received, read and understood the Kuehne + Nagel Code of Conduct.


The Code of Conduct is complemented by additional internal policies and guidelines. These supplementary materials address specific compliance topics and provide guidance to every Kuehne + Nagel member on standards and procedures that are specific to particular compliance risks, including Anti-Trust, Anti-Bribery, Conflict of Interest or Gift and Entertainment.



Integrity due diligence

A significant number of Kuehne + Nagel’s business transactions and activities are performed by business partners, including suppliers or subcontractors that work with or on behalf of Kuehne + Nagel. To protect Kuehne + Nagel from any harm caused by such third parties, we expect all our business partners and sub-contractors to operate within the limits of our Ethics and Compliance standards.


For that reason amongst others, such as agreeing with the Kuehne + Nagel Supplier Code of Conduct, we have implemented a risk-based Integrity Due Diligence procedure for both new and existing third parties to minimise our compliance related risk exposure. Kuehne + Nagel regularly assesses the integrity of existing or potential business partners following some pre-agreed procedures that address compliance risks or other concerns related to the involvement of such third parties. A key emphasis is to focus Integrity Due Diligence procedures where customs clearance activities are subcontracted to a third party.


In case of doubtful findings we either support the business partner to improve its compliance environment by introducing reasonable safeguards or else consider rejecting collaboration for avoiding harm to our own business environment including our customers.




Confidential Reporting and Allegation Management

All Kuehne + Nagel members are encouraged to raise concerns about potential violations of the Code of Conduct to any person of trust within Kuehne + Nagel. Further, a global Confidential Reporting Line has been implemented in Kuehne + Nagel countries. This line allows for reports on potential violations in a safe, confident and, if desired, anonymous manner. The Confidential Reporting Line can be reached 24 hours a day, seven days a week and is operated by an external service provider enabling reporting in native language; either by phone, e-mail or a dedicated web based reporting tool. Kuehne + Nagel members are using all means of respective reporting. The Kuehne + Nagel Independent Allegation Management Committee oversees the handling and follow-up of reported allegations received through any channel. The Committee ensures consistent standards and procedures and considers thorough independent investigations as needed. Subject matter experts are involved to ensure competent and adequate assessments, appropriate decision taking, and related follow-up activities are ensured.


Complaints or allegations made in good faith will not expose the submitter to retaliation. However, knowingly providing false or misleading information may result into sanctions.



Compliance Governance

The President of the Board of Directors entrusts the “Risk and Compliance Committee” of the Kuehne + Nagel Group to support the Board of Directors and the Management Board when adhering to the standards of good corporate management, in particular by evaluating the risks of the Kuehne + Nagel Group and taking decisions regarding adequate measures to minimise risks and to safeguard the adherence to external and internal regulations. The Risk and Compliance Committee consists of the Chief Executive Officer, the Chief Financial Officer, the Head of Internal Audit, the Group General Counsel and the Chief Compliance Officer. The functional responsibility for the design and implementation of the Ethics and Compliance Program is delegated to the Chief Compliance Officer who has the expertise, independence and authority to implement the program in all business areas and subsidiaries. This is accomplished in close cooperation and with the support of the Kuehne + Nagel management and other qualified resources and functions. In recognition of the crucial importance of the Ethics and Compliance Program the Chief Compliance Officer reports directly to the Chief Executive Officer. Further reporting exists to the Audit Committee Chairman of the Board of Directors and the Group General Counsel. The Chief Compliance Officer is supported by corporate, regional and local compliance representatives and also involves other internal functions, such as Internal Audit, Legal or Human Resources.