Governance

1. Compliance Policy
(Updated 2024)

This policy outlines the HeidelbergCement compliance programme:

• Responsibilities (general and specific compliance management)
• Compliance in joint entities
• Contents and tools
• Sanctions in case of non-compliance

The Code of Business Conduct sets the ethical and legal standards
for day-to-day business activities in terms of:

• Compliance with applicable laws and internal policies
• Antitrust law
• Health and safety
• Environmental and sustainability issues
• Human rights
• Plenty of more compliance topics

Emphasis is laid on the responsibility of all employees to uphold
these standards and the fact that violations are not tolerated

3. Anti-Corruption Guideline
(Updated 2023)

This document provides guidance in situations which could bear corruption risks, such as:

• Giving or receiving gifts or hospitality to or from business partners
• Gifts or hospitality with respect to representatives of public authorities
• Conflicts of interest
• Corporate citizenship activities
• Cooperation with agents and advisors
• Merger and Acquisition projects

Risk-mitigating measures include

• Personnel-rotation
• Two-person integrity and segregation of duties
• Adequate documentation
• Information and training of employees exposed to corruption risks

• All employees and focus on Management
• Employees involved in procurement, i.e. purchasing employees as well as engineers (e.g. by determination of specifications)
• Employees of specialist departments that use external service providers (e.g. attorneys, accountants, auditors, consultants, etc.)
• Employees of departments responsible for obtaining governmental permits of all kinds and other approvals
• Sales employees
• Employees involved in corporate acquisitions
• Employees involved in Corporate Citizenship activities (sponsorships, donations, etc.) that accompany HC CAPEX projects.

This guideline gives an overview over the following topics:

• Responsibilities in terms of competition law
• Competition law infringements relevant to our business and their legal consequences
• Rules of conduct in order to avoid competition law violations
• Instructions for conduct in the event of competition law
• investigations
• Reporting on competition law incidents
• Implementation of and minimum requirements for national
• Competition law guidelines
• Mitigation measures, such as:
  • Adequate documentation,
  • Yearly risk assessment,
  • Information and training of employees exposed to
• Competition law risks
• Specific Grey Cement/Cementitious compliance rules for EEA Countries

• Upper management
• Sales managers and officers
• Purchasing managers and officers
• Managers and employees involved in procurement
• Merger and Acquisition projects
• All other

This document provides guidance on:

• The types of incidents to be reported as compliance incidents
• The various reporting channels
• How a compliance incident should be reported
• How the investigation process is organized (responsibilities, timing, documentation, communication, etc.)
• Which persons need to be informed within the organization in case of reported compliance incidents
• Securing data if severe compliance violations are suspected
• Responsible persons for remedial measures in case of proven
• Misbehaviour
• The investigation principles

This policy provides:

• An overview of national and international trade sanctions
• The types of EU and U.S. trade sanctions and their scope of applicability
• Details on the responsibilities on Group and local level

• Upper Management
• Sales managers and officers
• Purchasing managers and officers
• HR managers and officers
• Managers and employees involved in procurement and
• Merger and Acquisition projects 
• All employees charged with screening of business
• Partners for trade sanctions compliance

This policy specifies:

• HC’s commitment to a list of different human rights documents
• The application of human rights in our relationship with our
  • Employees,
  • Suppliers and customers
  • Surrounding of location (corporate citizenship)

This policy specifies HC’s

• Obligations to prevent money laundering
• Regulations for cash payments
• Approach to money laundering risk management

• Treasury/staff involved in financial transactions
• Master data requester (purchasing, sales)
• Master data administration
• All employees involved in selection of business
• Partners and business transactions