G1
BUSINESS CONDUCT
covered in the Code of Conduct, including the whistleblower system. Module 1 must be completed within 30 days. Once this deadline has been met, new employees are required to register for the CoC refresher in June or December of each year. All existing employees receive annual CoC refresher training. Training on the Code of Conduct and the refresher course covers the following topics: dealings with business partners and third parties, ban on corrup- tion, how to handle gifts, donations and sponsorships, combating money laundering, export controls, business relationships with suppliers and fair competition.
The Zumtobel Group whistleblower system covers the following reporting focal points:
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Health, safety and environmental legislation
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Fraud, breaches of trust, embezzlement & corruption Capital market compliance, insider trading & anti-competitive practices
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Data breaches
Discrimination, harassment, bullying & human rights
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Other violations
In the 2025/26 financial year, a survey was carried out to assess the effectiveness of this whistleblower system among the Group’s own workforce and strategically important suppliers. This anonymous survey was launched in 2025/26 and has not yet been fully completed. As the response rate to the survey (<10% of respondents) on the effectiveness of the Zumtobel Group’s whistleblower system is still too low, it is not yet possible to draw any concrete conclusions regarding the effectiveness of this system. The Zumtobel Group will take further steps to promote the survey in order to produce more meaningful results for the next reporting year. However, due to its active use and the continuous submission of reports in the whistleblower system, the Zumtobel Group considers this system to be an effective tool.
Organisation and integration of the topic within the Group
The Compliance and Audit units of the Zum- tobel Group act separately and independent- ly of each other. Where feasible, the Compli- ance department asks the employees of the Audit department to conduct investigations. In view of potential conflicts of interest and a lack of independence, the work of Corporate Compliance is not reviewed by employees of the Corporate Audit team. The Chief Compliance Officer reports to the Audit Committee twice a year. With respect to administrative matters, the Chief Com- pliance Officer has a direct reporting line to the CFO. The Zumtobel Group keeps its own workforce up to date on current and ongoing compliance issues on the LightLink corpo- rate platform. Links to training can also be found on this platform. Within the Zumtobel Group, certain departments are exposed to a higher risk of corruption and bribery than others. The definition of “at-risk” functions was refined and adjusted in 2025/26. The Zum- tobel Group defines the following depart- ments as at-risk functions: Finance, Human Resources, Investor Relations, Logistics, Procurement, Quality, R&D and Sales.
Compliance training
All new employees are required to complete online training on compliance during their onboarding. The Code of Conduct (Module 1, duration: 40 minutes) and Code of Con- duct Refresher (Module 2, duration: 30 minu- tes) modules are provided on a Group-wide learning platform. Invitations to the online training are sent by email and the courses constitute an integral part of the onboarding process. In Module 1 and Module 2 of the mandatory compliance training, training is provided and knowledge imparted on topics
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