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.

Code of Conduct

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.

HHLA Code of Conduct (PDF)

The Code also comprises the possibility for employees and third parties to submit notifications or hints about irregular behaviour in the company. All notifications are treated confidentially and can also be submitted anonymously.

Contact details whistleblower hotline (PDF)
Data protection information whistleblower system (PDF)

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.

General declaration on human rights

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)

Supply chain / Supplier Code of Conduct

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)

To combat and identify human rights and environmental risks and violations in the supply chain, HHLA has set up an external ombudsperson office to receive notices. It is available to all external stakeholders who wish to report a confidential and, if they so wish, anonymous notice of potential human rights and environmental related risks as well as violations of human rights and environment related obligations under the Act on Corporate Due Diligence in Supply Chains (LkSG).

Ombudsperson office (Datenschutz nord GmbH, Mr. Dominik Bleckmann, fully qualified lawyer):

Phone: 0049 (0)421 696632349
Postal address: Datenschutz nord GmbH, Dominik Bleckmann, Konsul-Smidt-Str. 88, 28217 Bremen

Further information on the procedure within HHLA’s whistleblowing system can be found here:

Rules of procedure whistleblower system (PDF)