Integrity education

Internal governance

Integrity education

The Group wide face to face integrity training is called the 539 ��Ƴ�ʽ Integrity Programme (VIP) and in particular covers

anti-trust/competition
anti-bribery and anti-corruption, and
conflicts of interest.

The training includes information on the Code of Conduct and Integrity and the merits of the 539 ��Ƴ�ʽ whistleblowing function. It is communicated continuously.

The aim of the VIP is to raise the level of awareness, to ensure that 539 ��Ƴ�ʽ's employees understand the integrity standards 539 ��Ƴ�ʽ expects of them and to ensure a common compliance culture.

Participation in VIP is mandatory once every three years for higher managers and for certain other employees, especially those with extensive competitor contacts.

During the face-to-face training, a lot of questions are raised by the participants about Integrity in general and there is room to discuss daily work situations in depth. Further guidance is offered when needed. Questions and dilemmas form a basis to improve the training and to develop the guidance in relation to the Code of Conduct.

E-learning

E-learning is available both as repetition of the VIP face-to-face session and for employees who do not have to follow the full VIP. There are three e-learning tools in the integrity area:

Competition law module.
Anti-bribery and corruption module.
The Code of Conduct and Integrity module, which is composed of a number of dilemmas and describes real life situations where the Code of Conduct comes into play.