Living with integrity
Generally speaking, compliance means adherence to law and internal regulations, but for Uniper, compliance goes beyond that. It is about ‘living with integrity’, an essential part of our company culture. We believe that ensuring compliance is not just the responsibility of our Legal and Compliance team but the responsibility of all employees, at all levels. You can be compliant without being ethical, but at Uniper, we strive for demonstrating the highest ethical standards in everything we do while ensuring adherence with laws and internal regulations. Compliance matters and concerns everyone at Uniper.
The board's commitment to compliance
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)
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.
Being a role model starts from the top
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 and securities law (insider trading) and all risk associated with these activities. That is why we have an internal and an external whistleblower hotline where anyone who becomes aware of a breach can report it – also anonymously. Both ways of reporting are equally available to all third parties (like customers and suppliers) who have a business relationship with Uniper.
Internal Whistleblower Hotline
Reports on potential rule violations within the company may be directed to supervisors serving as internal ombudsmen, to any member of the Uniper Compliance Team at compliance@uniper.energy or our specific whistleblowing channel at whistleblowing@uniper.energy.
External Independent Whistleblower Hotline
Alternatively, if employees are not comfortable reporting a matter internally and wish to remain anonymous or feel as though no action has been taken regarding a matter they have already reported, they may contact our external independent whistleblower hotline operated by the law firm Simmons & Simmons and available at uniper-compliance@simmons-simmons.com.
Each report received will be treated with confidentiality as employees, who report potential rule violations in good faith benefit from special protection according to the principles of our Code of Conduct and the corresponding Whistleblowing Business Directive Underlying guarantees of this directive are confidentiality, non-retaliation and adhesion to the applicable data protection laws.
Investigations, evaluations and remediations relating to compliance incidents are coordinated by the Chief Compliance Officer who is committed to ensuring that all individuals are able to raise genuine concerns in good faith without fear of retaliation or subsequent disadvantage, even if they turn out to be mistaken.
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:
Compliance Organisation
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.
Ms. Sirpa-Helena Sormunen (Chief Compliance Officer), who reports directly to Uniper's Chairman of the Management Board, is responsible for the suitability and effectiveness of the CMS in the area of Legal and Compliance. She is assisted in her 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.
"While Uniper complies with legal requirements, we seek to do more by demonstrating the highest ethical standards in everything we do."
Dr. Jens Hüffer SVP Compliance
Culture and Communication
Our 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.
Uniper's Compliance Day
Uniper's Compliance Day is an international program developed by Compliance to sensitize the business with the basics of the compliance culture & policies and to make employees more aware of their own responsibility when it comes to compliance. Additionally, these events serve to strengthen ties with the Compliance Officers and to get closer to employees of all Uniper locations.
Interactive, communicative and approachable