Commitment of the board
Through its commitment to compliance, the board makes clear its rejection of infringements of any kind.
"Compliance is particularly important for Uniper as a company operating worldwide and forms an essential part of its integrity and culture. We can expect our business transactions and projects to be accepted by society only if we always comply with laws and regulations elsewhere and at all times. The integrity of each staff member is indispensable if we want to retain the trust of our stakeholders, such as our customers, suppliers and shareholders.“
(Extract from Uniper Board Commitment)
Being a role model starts from the top
Additionally, according to our Code of Conduct, at the end of the year, the Leadership Team members or board members must confirm in writing to their immediate supervisors that they, together with those in their area of responsibility, have complied with the Code of Conduct since the last exercise.
At Uniper the principles of compliance are reinforced and lived by our management who serves as a role model encouraging employees to strive towards those standards throughout the organizational structure.
Code of Conduct
"Our Code establishes the basic principles of conduct that everyone at Uniper must follow. It reflects our commitment to one another, to our business and to our communities. This Code is a compass to guide our decisions and, in particular, to help us to do the right thing when difficult situations arise.”
(Extract from the Code of Conduct)
Supplier Code of Conduct
Uniper also has a Supplier Code of Conduct, which is an integral part as general terms and conditions of all contracts between Uniper and its suppliers. It expressly recognizes the ten UN Global Compact principles and provides an expectation that our suppliers also observe these fundamental provisions in their actions.
Reports on violations (Whistleblowing)
At Uniper we are committed to fostering a culture where our employees feel safe to speak up and report any potential infractions against the Code of Conduct and other violations of law or internal company policies, in particular those involving corruption, money laundering and terrorism financing, sanctions, as well as antitrust, securities law (insider trading), environmental or human rights violations, and all risk that have arisen as a result of the actions of our own employees or of a direct supplier. That is why we have an internal and an external whistleblower hotline where anyone who becomes aware of above mentioned breaches or risks can report them at any time – also anonymously. Both ways of reporting are equally available to all third parties in verbal or text form.
Uniper’s Internal Whistleblower Hotline
Reports on potential rule violations or risks may be directed to the Uniper Compliance Whistleblowing Team at our specific whistleblowing hotline at [email protected].
Uniper’s External Independent Whistleblower Hotline
Alternatively, whistleblowers may contact our external independent whistleblower hotline operated by the law firm Simmons & Simmons and available at [email protected] or by telephone.
Procedure and guarantees:
To allow a transparent approach and communication of any grievance, Uniper has set up a complaints procedure that is further described in the Business Directive Whistleblowing Procedure.
Reports will be accepted in all local languages and the receipt will be confirmed within 7 days after the reception.
Our Compliance Whistleblowing Team and the operators of our external whistleblowing hotline are not bound by instructions, they are independent and bound to secrecy. They will discuss the facts with the whistleblower.
Confidentiality of identity of the whistleblower as well as effective protection against disadvantage or punishment as a result of a complaint is ensured. The process adheres to the applicable data protection laws.
Any founded non-compliant behavior report is subject, if applicable, to the respective disciplinary actions or sanctions under labor law (including dismissal) and other legal sanctions.
Reporting for employees employed by a Swedish entity
Uniper Sweden has its own legal whistleblower channel. If you are employed by a company in Sweden with more than 50 employees, please refer to the link below for instructions on how to report:
Swedish web about whistleblowing: : https://www.uniper.energy/sv/sverige/integritetspolicy
-> Employees of companies in Sweden with fewer than 50 employees should continue using the global process (as described above).
Compliance Management System
In order to prevent, detect and stop compliance violations a Compliance Management System (“CMS”) for all core compliance topics was established by the Board when Uniper was founded.
Uniper’s CMS is based on the framework of the widely accepted auditing standard IDW Assurance Standard 980 and is reviewed and updated regularly based on a company-specific risk analysis.
Uniper compliance measures focus on preventing corruption, money laundering, terrorist financing, international sanctions, as well as violations of antitrust and securities law (insider trading) among other topics and all risks associated with these activities.
Our Compliance Programme promotes
An organizational culture that encourages ethical conduct and commitment to compliance with the law supporting a strong compliance programme, frequent training and fluent communication;
Doing what is right, following the rules, feeling safe to speak up when identifying something wrong, being vocal about compliance’s importance and asking critical questions;
Not letting business or personal interests thwart legal and ethical standards;
Embracing a preventive, rather than reactive, mindset towards compliance risks.
Compliance Organization
The Legal and Compliance Team supports Uniper employees to navigate the vast sea of laws, statutes and regulations affecting day-to-day operations and the internal rules which define their compliance responsibilities.
International Compliance Network
To manage compliance risks more effectively and to support the management in acting compliant throughout the business, Uniper has put in place an international compliance network of Compliance Officers.
Uniper’s Chief Compliance Officer Marc Merrill reports directly to Uniper's Chairman of the Management Board and is responsible for the suitability and effectiveness of the CMS in the area of Legal and Compliance. He is assisted in his role at corporate level by Dr. Jens Hüffer (Senior Vice President for Compliance) and his team as well as by decentralized compliance officers and line managers (in the various divisions or legal entities). The board serving as a collegial body bears overall responsibility for compliance.
Marc Merrill
Jens Hüffer
Culture and Communication
Our internal logo, our values, our culture
Some define “living integrity” as living life in accordance with an internal set of beliefs. For us, integrity is more than a belief. It is a part of our built-in compliance culture.
Communicating is just as important as regulating
No matter how good your policies are, if employees aren’t aware of them, organizations haven’t fulfilled their goals. For this reason, at Uniper we believe that clear communication is an essential element of our compliance programme. One example of our communication activities is the Uniper’s Compliance Day.
