Driving a sustainable business

Ensuring compliance  GRI 103

Compliance Governance and Management System  GRI 103, GRI 102-18

As one of the world's leading logistics providers, our business activity is based on high ethical and legal standards. By considering integrity a key element in our business behaviour, we are able to foster a sense of trust with our stakeholders, and meet our responsibility of being a reliable and successful business partner. Kuehne+Nagel’s Ethics & Compliance Programme is designed to ensure that we comply with both legal and regulatory requirements as well as with our internal standards in addition to other rules of professional conduct.

Our Ethics & Compliance programme is an integrated element in our business environment, that provides guidance to all Kuehne+Nagel employees and our business partners throughout the entire Group, independent of function, geography or business area.

Our Ethics & Compliance Programme supports us to protect Kuehne+Nagel from negative consequences such as sanctions or reputational damages.

Compliance measures are continuously developed and implemented under consideration of the principles: prevent, detect and act.

The programme and its implementation throughout the organisation is monitored on an ongoing basis. This will ensure that design, implementation and related processes are aligned with Kuehne+Nagel’s operations in all regions and industries.

A number of compliance related key performance indicators have been established to monitor the implementation progress across the entire Kuehne+Nagel Group, and to identify any remediation needs or required amendments to the programme in order to continuously improve its effectiveness and application. It is also identified as a very important and high material topic in the materiality matrix in this report.

Due to the Covid-19 pandemic, the year 2020 was different to prior years. While the world was forced to adjust the ways it interacted with each other, we grew stronger and more agile in everything we did, and were clear that we wanted to remain ethical. For example, in times when physical meetings were no longer viable and potentially even unsafe, we saw opportunity in online interactions. Integrity is at the heart of our business and ensures we convey confidence and security to our customers and partners.

Governance supports progress  GRI 205–2

The Kuehne+Nagel Code of Conduct determines the minimum general and ethical principles that our employees must apply consistently and continuously in all their business activities. As a result, Kuehne+Nagel can show that it is a reliable business partner around the world that will protect its business partners, stakeholders and the Group from adverse effects as a result of its operations.

Every Kuehne+Nagel employee is required to read, understand and comply with the principles, and be fully aware of the meaning and significance of the Code of Conduct and its complementary guidelines.

Kuehne+Nagel employees are also required to promote these the principles to everyone in their sphere of influence.

Internal policies and guidelines complement the Code of Conduct to address specific topics and provide guidance to our employees on standards and procedures that are specific to particular risk fields such as antitrust, anti-bribery and anti-corruption, conflict of interest, or gifts and entertainment.


Code of Conduct participation rates
In per cent 2020 2019 Change in per cent
Live training 91 86 6
Live training top and senior managers 98 93 5
Online training 94 74 27
Annual confirmation 98 93 5

For years, we have been running a dedicated Code of Conduct training programme to ensure that all employees know what is expected from them. It is built as a combination of live and online trainings and forms the first layer of our mandatory Compliance curriculum.

Progress and completion is monitored at corporate level to ensure a continuous participation rate exceeding 95 per cent across all employees and 99 per cent of top and senior managers. Respective monitoring is performed by the Human Resources function for following up on progress, where it is lower than expected. Furthermore, employees with personal company email accounts are required to annually confirm that they have read and understood the Kuehne+Nagel Code of Conduct.

The completion rate of the Code of Conduct Live Training increased by 6 per cent by year-end 2020 compared with 2019. Similarly, the completion rate of top and senior managers increased by 5 per cent. The completion rate of the Code of Conduct Online Training has reached a level of 94 per cent and is based upon a new and updated online training that was launched in October 2019 and thus had not been fully rolled out at year-end 2019. The completion rate of the Annual Confirmation has reached 98 per cent at year-end 2020. Reminder and escalation procedures are in place for ensuring the key performance indicators were met as well as following up on non-compliance at individual level.

SIX (SVVK) requirements
In alignment with the newly defined SIX/SVVK requirements, Kuehne+Nagel is regularly reviewing its portfolio with regard to business critical activities that may jeopardise the aspects of good business practices, the ESG as well as the CSR relevant topics.

A critical threshold can be considered with more than 5 per cent of revenue, that is not reached by any activity.


Critical business activity
In per cent of revenue
Alcohol 1.8
Defence/weapons 1.3
Tobacco 0.9
Adultery entertainment, coal, firearms, gambling, GMO, nuclear energy, oil sands

Creating ethics and compliance awareness

On-demand Compliance trainings complement the corporate-driven mandatory baseline Code of Conduct training as well as dedicated anti-corruption and antitrust education. This third layer of our Compliance curriculum allows for greater flexibility in topics and extended functional and geographic reach across the Group. Despite the title, such training is risk-based and delivered upon request; in response to a need being identified or specific issues; or accessed on a voluntary basis (eg as individual self-education).

To ensure we are continuously applying ethical principles, our employees must complete mandatory training on the Code of Conduct, anti-bribery, anti-corruption and antitrust. To further equip our employees, a variety of additional on-demand training can be done, covering specific situations which may not have been covered in the other training. Through such training, employees are taught about situations they may encounter in the course of their day-to-day business activity. On-demand training can be delivered in various ways, including live sessions and online training.

We are constantly monitoring our employees' training needs and requests for effectively allocating meaningful training resources. To achieve the best training experience, we have introduced a broad portfolio of training types, including but not limited to online trainings, and live or web training sessions delivered by qualified personnel. All participation in training is recorded into our learning management system and allow our employees to constantly develop their training records.

On-demand training compliance was delivered mainly through  computer-based online training which is provided through our Learning Management system and through live and online training. For effectively mitigating adverse training effects from the pandemic, we explored new ways of delivering training.


Compliance on-demand training
Corporate Governance model