The Next Steps - I comply

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NO. 1 2015 – 29 th YEAR CORPORATE MAGAZINE FOR THE WILH. WILHELMSEN GROUP

SPECIAL REPORT:

WW IN THE MIDDLE EAST

WW BUSINESS STANDARDS:

THE NEXT STEPS

NEW CALLENBERG:

GLOBAL AMBITIONS

ROLES ON BOARD:

WHO IS THE “REAL” BOSS?

WW PROFILE:

THE PATHFINDER – KNUT BRATHAGEN


CURRENT AFFAIRS

THE NEXT STEPS With the “I Comply!” campaign rolled out in (almost) all the WW group, focus is now on anti-corruption issues and on ensuring that the compliance work is performed according to the principles established in WW Business Standards. TEXT EINAR CHR ERLINGSEN PHOTO BERTRAND DECK

CLEARLY PLEASED with the level of participation. WW group chief legal officer Morten Aaserud (left) and group CEO Thomas Wilhelmsen (right).

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THE RESULTS OF THE “I COMPLY!” CAMPAIGN HAVE GIVEN US A MUCH BETTER TOOL FOR RISK MAPPING THAN WHAT WE PREVIOUSLY HAD.

MORTEN AASERUD, WW GROUP CHIEF LEGAL OFFICER

‘So what’s comes next?’ ‘Right now we’re in a process where we will evaluate the results before deciding on how to best follow up on them. Some established routines and traditions will have to be challenged. Some of the examples unearthed through the campaign actually show that switching on the spotlight is enough to solve the issues. In some cases, those responsible have simply not been aware of unhealthy practice carried out by their underlings and have actually welcomed it when we challenge them. I think it is fair to say that the world is slowly progressing on these issues,’ says Morten Aaserud.

‘So, have you come across any not recommendable activities as a result of the campaign?’ ‘Naturally, when you focus on Business Standards, things are bound to surface. One reason: the threshold for “blowing the whistle” becomes lower. So the answer is yes. Which is good, really, as it gives management both an opportunity and a duty to correct

‘How grave would you say that these breaches have been?’ ‘A breach is always serious, even though we also recognise that our compliance work has to take into consideration cultural differences and where they occur. Fortunately, we have not identified any major issues, although a handful have been serious enough and have resulted in consequences for those involved, including loss of job in rare cases.’

« WW Business Standards is a project

that focuses on implementing our WW group Code of Conduct and how to comply with our ways of handling anti-corruption, theft and fraud, whistleblowing and competition law. « The “I Comply!” campaign was

launched in June 2014 with the overall goal to educate all WW employees on important compliance issues. « Excellent governance enhances our

brand, our reputation, our ability to meet customer requirements and our compliance with legal requirements. A sound culture of compliance is vital and good for our business. Not being diligent and not complying means putting our business at risk. Our stakeholders all over the world also demand that we comply. « It’s just the way we do business.

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ANOTHER NEXT STEP after the “I Comply!” results have been analysed is to decide where to act in accordance with the rules laid down in WW Business Standards, and where there is room for improvement.

‘Any examples of misconduct?‘ ‘We have identified a number of risk areas, namely facilitation payments, gifts and entertainment. There are also transactional risks involving public officials, middlemen, third party or sub agents. In some parts of the world these things are almost mandatory and expected, but nevertheless in breach with our Code of Conduct,’ says Aaserud.

WW BUSINESS STANDARDS

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any unhealthy practices,’ says Aaserud. Adding: ‘The results of the “I Comply!” campaign have given us a much better tool for risk mapping than what we previously had, identifying practices that will have to change, be monitored or are all clear.’

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SLO, NORWAY: The campaign was launched at the WW headquarters in June 2014, with the rest of the world following in August. It started off with regional managers, followed by general managers and other leaders and finally, each and every employee. By the end of the year, almost all WW employees had been introduced to “I Comply!” The only exception are our seafarers, who for practical reasons have been allowed a deadline stretching into 2015 for completing the eLearning course and participating in the followup workshops included in the campaign. Clearly pleased with the level of participation, WW group chief legal officer Morten Aaserud says that group CEO Thomas Wilhelmsen has especially requested that the campaign is followed up by another topic; competition law, targeting sales personnel and others, as decided by Business Area leaders. ‘We realise that this is time consuming, as competition law is quite challenging, but it is also very important to ensure that we operate within the frames of fair play,’ says Aaserud.

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