Compliance Management System at PUMA
PUMA is a global sports company, aiming for sustainable growth and innovation. PUMA recognizes the legal risks inherent in running a global business in a fast-paced environment where laws and customs differ from country to country. PUMA has introduced a compliance management system (CMS) to identify, control and monitor compliance risks at an early stage. By developing policies as well as advising and training employees, the CMS aims to prevent potential financial losses or reputational damage for the company and to prevent misconduct.
PUMA’s compliance organization consists of a Chief Compliance Officer based at the headquarter in Herzogenaurach and reporting to the CEO of PUMA SE and a network of Local Compliance Officers. Local compliance Officers have been appointed for operating subsidiaries in all regions to ensure that Compliance measures are rolled out globally and to give employees a local point of contact. As an additional method of preventing and detecting incidents, we have implemented an electronic whistleblowing system which offers employees an additional channel to report suspected compliance violations. Employees are encouraged to report their concerns to their manager, Local Compliance Officer or HR Business Partner. However, if this is not possible for some reason, they can report from anywhere at any time, anonymously if they choose, by using a web-based platform. Incidents are reported to the top management, investigated immediately and thoroughly, and the required disciplinary steps are taken where necessary.
The PUMA Code of Ethics sets out the principles governing our actions and values. It contains rules on the handling of conflicts of interest, personal data, insider information and prohibits anti-competitive behavior as well as corruption in any form. The Code of Ethics is an integral part of every employment contract. In order to further reduce the risk of misconduct, the PUMA Code of Ethics is accompanied by concrete guidelines governing selected risk areas in detail.
The fight against corruption is one of the core topics of the Compliance Management System. At PUMA, we have a zero-tolerance approach regarding bribery and corruption and this is clearly communicated by top-level management.
Employees are regularly familiarized with the rules of the Code of Ethics and the Group guidelines, can access them on the Compliance site on the Intranet and are thus made aware of compliance regulations. Every year, PUMA rolls-out a group-wide mandatory e-learning unit on the PUMA Code of Ethics. To make sure that employees are familiar with all topics described in the Code of Ethics, the e-learning covers different topics every year. The e-learning that was launched in October 2018 focussed on conflicts of interest as a form of bribery, confidentiality of information and financial integrity. Sponsor of the campaign was the Management Board of PUMA SE, above all the CEO Bjørn Gulden, who promoted the e-learning lessons to all PUMA employees. The completion rate of this e-learning on the reference date 31 October 2018 was appr. 99% of PUMA Group (PUMA SE appr. 99%) employees with a corporate email account. In addition, special face-to-face training sessions were held on individual topics such as antitrust and anti-corruption, which raise awareness of the essential legal framework and internal company regulations.
Highlights: 99% of all PUMA staff with email account globally completed our Code of Ethics training and 93% of our core suppliers were trained in corruption measures
To emphasise PUMA‘s commitment to the fight against corruption along the supply chain, we have explicitly included appropriate principles of conduct in the PUMA Code of Conduct in 2016. The Code of Conduct sets out the minimum standards to which our partners in the supply chain must adhere. In 2017, we added anti-corruption clauses to the contracts with our suppliers on this basis. They oblige our contractual partners to establish or further develop appropriate systems for fighting bribery and corruption in their respective companies. PUMA controls compliance with these requirements within the scope of its annual SAFE audits. In 2018, 93% of all PUMA‘s core suppliers submitted their certificates of the UN Global Compact e-learnings tool on the subject in order to raise awareness of the fight against corruption. We provide our suppliers with our guidelines for combating and preventing bribery and corruption in order to facilitate the establishment of appropriate internal standards.