In 2018, we created our Corruption Vulnerability Atlas. This atlas depicts the results of the Corruption Vulnerability Analyses of all departments, areas of business, and locations of NPorts. From an organizational chart, you can see the degree of potential corruption for any of the organizational units at a glance. With it, we want to sensitize especially those employees in an area with an increased potential for corruption and put a focus on the safe design of and compliance with the process workflow. There are five potential criteria for an increased vulnerability for corruption:
- Possibility of granting undue advantages ≥ 10.000 €/year
- Regular invitation for offers
- Possibility of manipulation of evaluations, test results, access to confident information
- Concentration of competences: e.g., decision and execution
- Frequent external contacts to persons that may experi- ence advantages or disadvantages from the decisions of the employees
Whistleblower System
Since July of 2019, we have also introduced a whistleblower system. The system gives everyone the opportunity to give our external person of trust anonymous tips regarding corruption or for a misconduct via the Internet. There is also the option to clarify general questions with the person of trust.
The whistleblower message is relayed to our independent external person of trust via an IT system (ISO 27001) that is certified in a privacy law compliant manner (EuroPriSe Seal). This person will verify the tips and counsel us on the further steps. If requested by the whistleblower(s), the person of trust will stay in touch. This is a low-threshold system and may be used by employees, but also - and without restriction - by external persons. The system can be accessed through our compliance page.
With this large step, we intend to decrease the risks of a criminal act and facilitate the resolution of such cases. With it, we can also uncover actual flaws and loopholes within the system and keep people from being tempted to commit such acts. It is primarily our intent to protect whistleblowers with this system. Even going forward, they should be able to trust in the system and feel, like they can question things, without imperiling or losing their position or their reputation within the company.
We see reported tips as an opportunity: They show us key instances in our company that we can first internally investigate here. This allows us to address and resolve these problems internally, without them getting pointed out to us from external pressure, for instance through the media, which could needlessly damage our reputation.
Through both the existing IT safety standards, and in consideration of the collaboration with the external person of trust, who is obligated to keep confidentiality, our whistleblower system offers a very high protection standard and thus exemplary complies with the protec- tion demands of the EU Whistleblower Directive off 10/23/2019; Directive (EU) 2019/1937 for the provision of internal reporting channels.
Sensitization
In order to inform our employees about this, we have introduced the system via the intranet, in the expert presentations of the external person of trust, and through our e-Learning. We inform any of our business partners about the whistleblower system and our compliance pages as part of our automated e-mail signatures. Since the introduction of the system, we have not registered any tips regarding corruption incidents or legal proceedings due to anti-competitive conduct, the formation of cartels or monopolies or other misconduct. To us, this is a great sign and we are proud of it.
Beyond this specific information, we perform a general sensitization around the topic “Corruption and Bribery”. There is continuous reporting to all members about important developments at the supervisory board meet- ings. In addition, the employees are informed in writing each year about the internal policies.