Compliance

Being a good corporate citizen means maintaining consistently high legal and ethical standards in all our relationships. Preserving Autoneum’s credibility and good reputation is essential for our business success. It is Autoneum’s strategic commitment to further strengthen its compliance framework, thereby deepening the integration of compliance principles in the Company’s culture.

Vision 2025: Good Corporate Citizenship

Strategic Target

Establish and maintain a robust and company-wide Governance, Risk & Compliance (GRC) Framework

Operational Targets

  • Implement and maintain company-wide Compliance Management System based on ISO 19600
  • Strengthen and expand company-wide compliance risk assessment and audit framework
  • Continuously develop the training & awareness framework and maintain completion rate at 95%

Compliance Approach
Act with Responsibility

It is important to identify, assess and control the legal risks. At Autoneum, we do this by using a comprehensive Compliance program that is based on three pillars. The aim of this is to avoid, detect early and, if necessary, react to any infringements of the law and the Code of Conduct so that we can uphold our responsibility and prevent any damage to Autoneum and third parties.

Our Compliance Program is based on an annual risk analysis. The results of this facilitate precise and efficient management of compliance activities. Our Code of Conduct as well as directives, training courses, e-learning programs and the provision of individual advice aim to support our employees in specific dilemma situations.

In addition to internal communication channels, the “Speak Up Line” reporting system is also available for identifying any potential misconduct. Reports are followed up with fair investigations. Clear responses and consequences serve to punish any misconduct and eliminate weaknesses.

Code of Conduct
Core Component of the Compliance Program

As a global market and technology leader, Autoneum aims to act in an exemplary manner at all levels and in particular in its business relations. Our stakeholders, be they customers, investors, suppliers, business partners or employees, expect Autoneum always to gear its actions towards the highest ethical standards. The assumption of our ethical and legal responsibility – be this towards external stakeholders or employees – is reflected in our strict compliance with laws, provisions, regulations and internal guidelines.

The Code of Conduct is based on the corporate values of Autoneum and specifies in detail the expectations and standards applicable within the scope of our business activities and their concrete implementation. The principles set out in the Code of Conduct are binding for all employees at all locations in all countries. Management employees are expected to set an example for others through their own behavior and in doing so to create an open working environment based on trust.

All employees of Autoneum must be aware of their personal responsibility and at all times display ethically unimpeachable conduct in accordance with the Code of Conduct. Compliance with the standards set out in the Code of Conduct is of core importance for the long-term success of Autoneum. Infringements of the Code of Conduct are therefore not tolerated.

Speak Up Line

We wish to encourage our employees and business partners to contact and notify us of any potential misconduct or if they have any further questions. Reliable reporting channels and protection against sanctions for internal whistleblowers help to ensure that any potential misconduct can be reported, thoroughly investigated and resolved. Various reporting channels are available for gaining knowledge of any compliance infringements.

If, as an employee, you become aware of any infringement of the law or our Code of Conduct, or if you have any questions concerning compliance, you should initially contact your supervisor, HR representative or the Legal & Compliance department.

Please send an email to the Legal & Compliance team at compliance@autoneum.com.

In addition, we offer our internal and external stakeholders the Speak Up Line as an early warning system to prevent any damage. The Speak Up Line reporting system comprises a secure reporting channel which can be used to make reports online around the clock, on request also anonymously, and in many languages: https://speakupline.autoneum.com

Please note that all reports, irrespective of the reporting channel used, will be treated confidentially and are ultimately dealt with by the Legal & Compliance department at Autoneum’s headquarter in Winterthur, Switzerland.

Organization

The Compliance Council has the following members: CEO, CFO, Head Audit, Head HR and the Group General Counsel & Head Compliance. The Compliance Officer serves as Secretary of the Compliance Council. The committee is dedicated to discussing compliance issues and defining appropriate measures.

Implementation of the measures adopted is carried out by the Legal & Compliance department.

Contact

Veronica Lierau
Group General Counsel & Head Compliance

Autoneum Management Ltd
Schlosstalstrasse 43 / P.O. Box
8406 Winterthur
Switzerland

T +41 52 244 84 83

veronica.lierau@autoneum.com

Information data processing

Based on article 13 of the General Data Protection Regulation of the European Union (GDPR), you are entitled to get informed about the processing of your personal data within Autoneum. Please find further details in the information sheet below.

Statement Modern Slavery Act

Within Autoneum, we do not tolerate any form of modern slavery and commit to act in an ethical manner and to safeguard against any form of modern slavery or human trafficking and child labour. Our code of conduct for suppliers shall ensure that our suppliers and contractors will respect and comply with the same ethical standards as we do within Autoneum.
This statement is made pursuant to section 54 of the British Modern Slavery Act. It sets out the steps that Autoneum Great Britain Ltd. (UK), Borgers Ltd. (UK) and its affiliates (“Autoneum”) have taken, and are continuing to take, to ensure that modern slavery, human trafficking and child labour are not taking place within our business or supply chain.

Gender Pay Gap Information (UK)

Within Autoneum, we wish to offer a workplace free from harassment and discrimination, offering equal opportunities for all employees regardless of gender and other personal criteria. Amongst others, this includes the elimination of any gender pay gap.

Based on the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 in the UK, Autoneum Great Britain Ltd. (UK) has to carry out several calculations that show the difference between the average earnings of men and women without disclosing individual employee’s data. The results will be published on our own website and a British government website.

Information execution of tax strategy (PL)

Based on article 27c of the Polish Corporate Income Tax Act of 15 February 1992, Autoneum Poland Sp. z o.o. (PL) is required to provide an annual information update on the execution of its tax strategy. Please find all necessary information in the document below.

Healthcare Machine-Readable Files (North America)

Pursuant to Centers for Medicare & Medicaid Services (CMS) regulations, the following link leads to Autoneum North America’s machine-readable JSON files. These files are made available in response to the federal Transparency in Coverage Rule and include negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to access and analyze data more easily.