Compliance*

The Executive Board and Supervisory Board of KION GROUP AG consider that adhering rigorously to broad-ranging compliance standards is essential to the Company’s sustained financial success. That is why a detailed compliance program that is framed with regard to the Company’s risk situation has been set up for KION GROUP AG and its Group companies worldwide. The program is centered around the KION Group Code of Compliance.

The KION Group’s compliance management system is closely integrated with the internal control system and risk management to ensure that compliance is, or will be, firmly embedded in every business process.

Responsibilities

The Executive Board of KION GROUP AG bears collective responsibility for the functioning of compliance management within the Group; departmental responsibility for compliance lies with the Chief Executive Officer of KION GROUP AG. The performance of compliance-related management duties has been delegated to the Chief Compliance Officer, who is responsible for the compliance organization that has been put in place. The presidents of the Operating Units are responsible for compliance within the operating business, while the functional managers are responsible for core administrative processes in the departments at the Group’s headquarters. The KION compliance department, the KION compliance team, and the KION compliance committee provide operational support to the aforementioned functions. The KION compliance department focuses mainly on preventing compliance violations by providing policies, information, advice, and training. It manages the KION compliance team, in which local and regional compliance officers of the Group are represented.

As part of its work, KION’s compliance department cooperates closely with the legal, internal audit, and human resources departments. The KION compliance committee, which is staffed by the heads of the legal and internal audit departments and chaired by the Chief Compliance Officer, operates as a cross-functional committee that primarily advises on and examines reported incidents of non-compliance and, if appropriate, imposes sanctions in the event of misconduct.

KION Group Code of Compliance

The KION Group Code of Compliance, which is available in all of the main languages relevant to the KION Group companies, and the more detailed internal policies provide all employees, managers, and executives with clear and practical guidance on how to conduct the KION Group’s business in accordance with sound values and ethics and in compliance with the law. The principles of conduct laid down in the KION Group Code of Compliance are binding for all employees, managers, and executives worldwide. They form the basis of the KION Group’s compliance program. The KION Group Code of Compliance can be found online at www.kiongroup.com/compliance.

In 2023, no violations of the KION Group Code of Compliance were found within the KION Group that revealed a relevant gap in the compliance management system.

Compliance program

KION’s compliance program is made up of systemic management and control measures, specifically:

  • The KION Group Code of Compliance
  • The KION anti-bribery and anti-corruption policy, supplemented by anti-bribery and anti-corruption rules in the KION donations and sponsorship policy, the KION procurement policies, and the KION policy on conflicts of interest
  • The KION policy on compliance with antitrust law
  • Instructions on conduct in specific circumstances (e.g. how to deal with invitations and gifts at Christmas, how to act in respect of current fraud cases)
  • Training plans and training courses prepared for specific risk groups, training courses for specific circumstances, on-demand training courses
  • E-learning courses on the content of the KION Group Code of Compliance and on anti-corruption, anti-discrimination, whistleblower protection, data protection, KION’s values, and compliance with antitrust law
  • Review of business partners
  • Compliance due diligence in connection with M&A activities
  • Request / help-desk management
  • Descriptions for the reporting and handling of suspected infringements of the KION Group Code of Compliance; sanctions in the event of violations in the rules of procedure for the KION compliance committee

Compliance training

The training courses provide employees, managers, and executives with practical guidance on how to independently make professional decisions in compliance with internal and external rules and in line with the KION Group’s fundamental ethical values. The compliance training courses are offered in many different languages to ensure that participants understand them properly.

The KION Group’s compliance training concept takes a two-pronged approach consisting of e-learning and classroom-based training. As well as a general e-learning course on the content of the KION Group Code of Compliance, which is mandatory for every new employee, an e-learning course on the anti-bribery and anti-corruption policy was rolled out in 2020, followed by an e-learning course on respectful conduct in the workplace and anti-discrimination in 2021. An e-learning course on fraud prevention and anti-money laundering and one on conflicts of interest were rolled out in 2022, followed in 2023 by an e-learning course on unconscious bias in the workplace and one on whistleblower protection. The anti-corruption e-learning course is aimed at all employees with access to a PC, for whom it is mandatory. Other mandatory training courses cover data protection, managerial conduct, competition law, special fraud matters, and trade compliance.

Classroom-based training has a range of target groups: employees without access to a PC, who attend a general training course on the content of the KION Group Code of Compliance, and certain groups of employees who are exposed to particular objective compliance risk due to the nature of their work, for example those exposed to heightened corruption risk because they have a lot of contact with customers. Classroom-based training is offered to employees depending on their level of risk. The frequency of classroom-based training depends on the particular risk group.

Whistleblowing system

A key component of the KION Group’s compliance management system is a whistleblowing system that employees and third parties can use to confidentially report actual or suspected cases of unlawful or inappropriate conduct. The KION Group offers a variety of reporting channels to internal and external whistleblowers in order to facilitate the identification of potential compliance breaches.

Actual or suspected incidents of non-compliance can therefore be reported anonymously or otherwise by contacting an external 24-hour compliance hotline, by completing an online form, by sending an email or letter, by calling an internal KION Group hotline, or by contacting a compliance officer directly. The precise contact details can be found online at www.kiongroup.com/whistleblowing.

* The content of this chapter/section is disclosed voluntarily and is therefore unaudited.

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