In the Enforce stage of the Compliance Program suspicions of violations are investigated, corrective actions taken and the responsible employees sanctioned.
Specific hints of possible violations are investigated by Corporate Compliance or by the local compliance officer in cooperation with Corporate Compliance. Depending on the case, external counsel or investigators get involved. For cases where an immediate reaction is required, a Crisis Intervention Team is defined.
In 2018 the number of investigations conducted by region was as follows:
|Region||No. of investigations|
|in Europe & Africa||32|
|in the Americas||76|
|in Asia, India & Middle East||62|
Audits and Investigations serve to identify perpetrators and stop unacceptable practices. They also suggest corrective actions to ensure that the violations do not reoccur. In a Permanent Action Plan (PAP), the management responsible for the related business process is required to specify how the identified deficiencies are corrected and which measures will be implemented to avoid recurrence. The management keeps record of the implementation of the PAP and informs Corporate Compliance in follow-up meetings.
A Compliance Coaching Process is initiated with employees who engage in practices which are risky but not sanctionable.
In the Compliance Coaching Program, a compliance coach, normally the direct line manager, explains the risks involved in the behaviour and discusses with the person being counseled better and less risky solutions.
The Coaching Process and related results are documented.
Schindler encourages good compliance behavior with incentives.
For example the Performance Rating Grid does not only consider objective achievement, but also evaluates how Schindler Values (including Ethics and Integrity) are complied with.
Furthermore, Green Excellence Awards are given for extraordinary Compliance innovations which are beneficial for the overall Compliance Program.
Schindler's Compliance Sanctioning Guidelines specify the Compliance Violations which are subject to sanctions and the process to impose sanctions.
Following Schindler's Zero Tolerance Policy, sanctions range from reprimands and bonus cut to dismissal.
Additionally, appropriate legal actions, including notifications to relevant authorities, are considered.
In the past years Schindler has imposed sanctions for violations of the Code of Conduct, ranging from written reprimands to dismissals.