Ensuring legal compliance: guide­lines for respon­sible conduct

Legal compliance is ensured at all company levels at Tchibo. The Tchibo Code of Conduct (CoC) forms the basis for this. It is binding for all employees of Tchibo GmbH and the inter­na­tional business units, and governs our dealings with business partners and customers. The CoC is based on the funda­mental conven­tions of the Inter­na­tional Labour Organ­i­sation (ILO) and among other things prohibits all forms of corruption, and granting or accepting of an undue advantage. If an employee violates any of the principles, they face sanctions under labour law. We regularly train our managers in the appli­cation of our CoC. Once a year, managers confirm in writing that they under­stand the rules of the CoC, that they have complied with them and have reported any breaches they have become aware of. In addition, by signing, they affirm that they have explained the CoC to their staff and that they are monitoring compliance with the CoC. Every new employee receives a copy of the CoC. We inform our employees about new devel­op­ments via the intranet as well as directly, through their super­visors.

Compliance with the CoC is verified in internal audits by the Group auditors of maxingvest ag. A whistle­blowing hotline operated by an independent body serves as an anonymous point of contact so that employees, suppliers and customers can report possible cases of misconduct. If necessary, the infor­mation received is forwarded anony­mously to an ombudsman council as an internal examining body. The ombudsman council consists of various heads of department at maxingvest ag and Tchibo GmbH, as well as the chairman of the works council. Grievances can also be reported to the works council, the Human Resources department, the Legal department, the Direc­torate of Corporate Respon­si­bility, and the Group Audit department.

Beyond this, Tchibo has been a member of the UN Global Compact since 2009, which means it has pledged, among other things, to actively combat corruption. We contin­u­ously conduct training for employees in the relevant depart­ments, such as Purchasing and Sales, in order to make an active contri­bution.

Identify and prevent: risk management

Our business is subject to various risks – e.g. from currency fluctu­a­tions or environ­mental incidents that can have an impact on commodity prices. As part of our integrated risk management system, we identify these risks and take preventive measures to limit them. We make a funda­mental distinction here between company risks and supply chain risks.

We carry out risk inven­tories to take stock of all material risks, which we break down into a risk cluster with three categories: short-term opera­tional risks, one-off risks, and strategic risks. Within these categories a further differ­en­ti­ation is made. Risks that are acutely threat­ening are immedi­ately reported to the management at the time they occur. This allows us to quickly control potential threats. An update on the devel­opment of risks is incor­po­rated into Tchibo's steering and planning systems several times a year. The Internal Audit department reviews the effec­tiveness of the risk management, and informs the Management Board and Super­visory Board of this in regular risk assessment reports. The Boards determine the scope of review for the Internal Audit department. Infor­mation on threat­ening risks is immedi­ately commu­ni­cated to the Boards. For example, as a trading company, Tchibo is exposed to the risk of saturated or shrinking core markets – which would lead to stagnating or declining sales. We guard against this risk with an innovative product policy and inter­na­tional growth. Because the global retail landscape is changing, along with customer behaviour, we have further strengthened the e-commerce sector, and intro­duced cross-channel services and an attractive permanent range of products.

To prevent risks in the area of procurement, we integrate social and environ­mental require­ments in our procurement and quality processes. For instance, we are gradually reducing the number of suppliers we use for our consumer goods, devel­oping the remaining suppliers into strategic partners, and supporting them with the Worldwide Enhancement of Social Quality (WE) quali­fi­cation programme. In our issues management, we analyse the relevant concerns of our stake­holders on an ongoing basis.
For instance, in 2014 we decided to integrate the standards under­lying Green­peace’s DETOX Commitment into our purchasing and quality processes. Beyond this, we also practice resolute supplier monitoring as part of our risk management.

Data protection

The new data protection standards under the EU General Data Protection Regulation (GDPR) pose a variety of challenges for companies – and Tchibo is no exception. More than before, data protection, as a management issue, is required to be integrated into all relevant business processes. In this way, we aim to meet the documen­tation and risk assessment require­ments even better. Raising awareness among our employees and a clear distri­bution of tasks within the national and inter­na­tional business units are as essential to this as the devel­opment of a clear target vision.

In 2016, despite our careful handling of the infor­mation entrusted to us by our customers and our employees, and our three pillars of data economy, trans­parency and security, we failed to fully meet the require­ments placed on us in two cases, when faulty config­u­ra­tions arose during system changeovers. Quality assurance mecha­nisms are being imple­mented and will prevent a recur­rence of such lapses in future.