Schindler Enforce

Enforce

In the ENFORCE part of the Compliance Program suspicions of violations are investigated, corrective actions are taken and the responsible employees are sanctioned.

Investigations

In addition to the preventive Compliance Audits (see EXAMINE), specific hints of possible violations are investigated by Corporate Compliance (CPL) or by the local compliance officer in cooperation with CPL. Depending on the case, external counsel or investigators get involved.

For cases where an immediate reaction is required, a "Crisis Intervention Team" is defined.

Compliance Counts: Investigations

In 2016 Schindler has conducted 137 Compliance Investigations:
in Europe & Africa10
in the Americas53
in Asia, India & Middle East74
Corrective Actions

Corrective Actions

Audits and Investigations serve to identify perpetrators and stop unacceptable practices. They also suggest corrective actions to ensure that the violations do not recur. 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.
 

Compliance Coaching

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.

Incentives

Schindler has the following incentives for good compliance behavior:

  • The Performance Rating Grid does not only consider objective achievement, but also how Schindler Values (including Ethics and Integrity) are complied with.
  • Compliance innovations which are beneficial for the compliance program overall obtain a "Green Excellence" Award.  

Sanctions

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. 

Furthermore, appropriate legal actions, including notifications to relevant authorities, are considered. 

Compliance Counts: Sanctions

In 2016 Schindler has imposed sanctions for violations of the Code of Conduct, ranging from written reprimands to dismissals.
 

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