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An important part of corporate governance at HHLA is compliance with statutory provisions which apply for its business activities as well as internal policies (hereinafter referred to as “Compliance”). In this respect HHLA takes its responsibility towards business partners, shareholders, employees and the public very seriously.
As the core element of the Compliance management system, HHLA has introduced a Code of Conduct. The Code contains superior principles with respect to specific Compliance topics such as business conduct in competition, prevention of corruption, conflicts of interest and handling of confidential information.
Professional training and intra-company media are employed to continuously inform the staff about the contents of the Code of Conduct, as well as further in-depth subjects such as corruption prevention and behaviour towards competitors. The Group-wide coordination of the Compliance management system is managed by the Group Compliance Officer, who cooperates – inter alia - with the risk management and internal audit department. To preserve his independence, the Group Compliance Officer reports directly to the Executive Board and the Audit Committee. In addition he acts as an advisor and contact person for the staff and external parties in case of emerging questions concerning Compliance.
In order to protect the interests and the confidence of all stakeholders, HHLA continuously enhances and improves the current Compliance management system.
The Code also comprises the possibility for employees and third parties to submit notifications or hints about irregular behaviour in the company. The company ensures that employees who report incidents in good faith do not suffer any disadvantages as a result. All notifications are treated confidentially and can also be submitted anonymously. This also applies to notifications and information that we receive from third parties.
In particular, the company has set up the HHLA digital whistleblower portal (BKMS® System) to identify and combat potential breaches of the law and violations of internal guidelines. It is available to all internal and external stakeholders who wish to report potential compliance risks and violations digitally and anonymously (optional). Reports can be submitted at any time via a secure application provided by a specialised provider:
The HHLA whistleblower portal (BKMS® System) offers whistleblowers the opportunity to submit their report digitally and optionally anonymously and to communicate with the local HHLA compliance contact person of the respective subsidiary (if available) or the central HHLA Compliance Department.
Information can also be provided via the following reporting channels:
Further information on the procedure within HHLA’s whistleblowing system can be found here:
Rules of Procedure Whistleblower System (PDF)
Data protection information whistleblower system (PDF)
As part of its corporate responsibility HHLA commits itself to respect for and compliance with human rights. As a basis for this, HHLA orientates its actions in line with the General Declaration of Human Rights of the United Nations (UN) and the Guiding Principles for Business and Human Rights of the United Nations (UNGP). In addition, further international standards and agreements such as the principles of the UN Global Compact (UNGC) and the international core labour standards of the International Labour Organisation (ILO) are fundamental to our actions and corporate culture.
The general declaration on human rights serves as a commitment to live up to and promote respect for human rights and to continue integrating internationally recognized human rights principles into existing processes at HHLA. HHLA investigates every violation of human and environmental rights very thoroughly. Mitigation measures are assessed and implemented on an individual basis depending on the violation. The implemented measures can lead to the suspension or termination of business relations. HHLA regularly evaluates the established measures with regard to their effectiveness in order to continuously improve.
General declaration on human rights (PDF)
Policy statement against racism (PDF)
Also along the supply chain, HHLA strives for a relationship with business partners characterized by integrity, fairness, responsibility and sustainability. HHLA expects its suppliers to apply certain principles as the basis for their business activities. For this purpose, HHLA has developed a Supplier Code of Conduct that describes these principles and formulates the clear expectation towards suppliers that they comply with the business practices we expect of them, comply with the law and conduct their activities while respecting human rights.
HHLA Supplier Code of Conduct (PDF)
HHLA has set up a digital whistleblower system (BKMS® System) to identify and combat potential breaches of the law and violations of internal guidelines within the HHLA Group and, in particular, to identify and combat human rights risks in the supply chain related obligations under the Act on Corporate Due Diligence in Supply Chains (LkSG). Reports can be submitted at any time via a secure application provided by a specialised provider. We encourage users of the whistleblowing system to give us their name. If this is not desired, the whistleblowing system offers the option of submitting reports anonymously and communicating with us without revealing your identity. We would like to emphasise that we take all reports seriously and examine them carefully to ensure that we live up to our values and standards in every respect. Your co-operation is of particular value in promoting a positive and responsible corporate culture. We thank all whistleblowers for their support in upholding our shared values.
Further information on the procedure within HHLA’s whistleblowing system can be found here:
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