Compliance Whistleblower Process and Compliance Hotline

Ethical & compliant behavior is of highest priority for Henkel, its employees, and stakeholders ‏(for example customers, suppliers, service providers). This includes strict compliance with whistleblower laws globally as well as compliance with laws that focus on adherence to human rights-related and environmental standards. Henkel’s employees and stakeholders and all persons affected by Henkel's business activities, are, therefore, requested to report potential misconduct. Henkel will analyze all messages thoroughly, through a fair process ensuring the rights of the persons reporting as well as the rights of the persons implicated are respected and all information is treated with utmost confidentiality. Whistleblowers who report potential misconduct in good faith will be protected, any kind of retaliation against them will not be tolerated.

The following information summarizes the whistleblower processes at Henkel:

What can be reported.

Henkel’s Code of Conduct, our Values, Leadership Commitments, and further internal Standards describe the high level of expectation towards our own behavior and business conduct as well as that of our stakeholders. Any potential violations against such benchmark, including any violation of applicable laws, may be reported. In particular, human rights and environmental risks, as well as violations of human rights-related or environmental obligations that have arisen as a result of Henkel's own business activities or those of a Henkel supplier, may also be reported.

Where to submit a report. Multiple reporting channels at Henkel.

Whistleblowers are offered various channels to report potential misconduct.

• Of course, employees may turn to their superiors, HR or Compliance/Legal to raise concerns, get advice and report potential misconduct.
• Henkel’s Compliance organization, mandated by Henkel’s Management Board to responsibly handle all reports to the group, can be reached 
  • by email (compliance_north_america@henkel.com),
  • via the webform, and
  • openly or anonymously through Henkel’s Compliance Hotlines ‏(contact and access codes via phone and webform can be found below). 
• Whistleblowers referring to Henkel-companies in the European Union who prefer to not involve Henkel’s Compliance organization at Henkel AG & Co. KGaA and/or its local Compliance managers, may raise their reports to an external ombudsperson, who is independent of the Henkel organization and bound to professional secrecy.
• Finally, Henkel fully acknowledges that in some jurisdictions whistleblowers may directly turn to public authorities for reporting purposes. 

Access to and processing of whistleblower reports.

Henkel will treat any whistleblower report with utmost care, speed and confidentiality, fully abiding by applicable privacy laws. This includes a strict need-to-know principle, i.e., only Henkel’s Compliance Group-organization ‏(local and global) and, as the case may be, relevant other departments required for the investigation and external professional investigators/auditors will have access to the report, investigate and follow-up. 

The process will be duly registered and documented. Investigations follow the procedural fairness-principle, objectivity, followed by an impartial decision, while all persons implicated are presumed innocent until a violation is proven.

Henkel reacts forcefully to identified misconduct, this may, among others, include appropriate disciplinary measures against offenders. If appropriate, Henkel may involve public authorities and prosecution. Based on investigated facts, a decision on the case and appropriate measures is usually taken by Henkel’s Compliance organization ‏(local and global), in alignment with the competent Business Unit-managers and HR.

Reply to and protection of whistleblowers.

Whistleblowers will be replied to as soon as reasonably possible. As a general guidance, there shall be an acknowledgment of receipt following any report within seven days, as well as a conclusion or update on the case within three months. As per applicable laws, the reply must account for confidentiality and privacy rights of all implicated persons.

There is no tolerance in our organization for any type of retaliation, and we will protect anybody who speaks up in good faith, even if a concern turns out to be unfounded.

Data Protection

For reports to Henkel’s Compliance Group-organization, please refer to the Data Protection Statement of Henkel AG & Co. KGaA. For reports to the Ombudsperson, the data protection declaration there applies.