Anti-corruption and bribery matters

Avoidance of corruption and anti-competitive behavior

Ethically correct and lawful conduct includes the prevention of corruption and anti-competitive behavior. HUGO BOSS expects all employees to act lawfully in day-to-day business operations. For HUGO BOSS, corporate compliance is a key responsibility of the Managing Board and includes measures to ensure adherence to legal and official regulations, and internal guidelines and codes. These include anti-corruption, anti-bribery and antitrust regulations.

The central Compliance department reports directly to the CFO in his role as Chief Compliance Officer and supports him in the monitoring of effective compliance management. It works together with the compliance officers in the Group companies to provide for the compliance program to be implemented and continually further developed. The Audit Committee of the Supervisory Board is kept regularly informed of the Compliance department’s activities.

Targets

Compliance management at HUGO BOSS aims at Group-wide legally compliant behavior. The aim is to prevent legal violations such as corruption, bribery and antitrust violations which may result not only in reputational and financial risk but may also, in particular, lead to personal consequences under criminal and labor law.

Measures

All employees of the HUGO BOSS Group are required to comply with the Code of Conduct applicable throughout the Group and specific supplementary compliance rules. All Group companies are subject to regular risk analyses and detailed audits where applicable. Any infringements are reported to the Managing Board and the Supervisory Board. The Code of Conduct is available on the Company website.

In 2019, the internal antitrust law guidelines and the insider guidelines were revised. As well as an update of the content, in particular with regard to changes in regulatory requirements, this revision also included an approach to better adapt the two topics to the target groups.

A Group-wide e‑learning program to be completed by all employees with access to a PC should heighten awareness of the compliance rules. The program was revised extensively and expanded in 2019, particularly with regard to the topics of antitrust law, data protection and social compliance. Staff in positions where compliance is particularly relevant receive face-to-face training courses on specific topics that are of relevance to them, such as antitrust law. HUGO BOSS does not tolerate any willful misconduct or serious compliance infringements.

At HUGO BOSS, employees, suppliers and trading partners can notify an external ombudsman in confidence if there are any indications of fraud, infringements of antitrust law or other compliance breaches. If desired, it is also possible to do this anonymously. The ombudsman’s contact data can be found on the Company’s website.

Performance indicators

In 2019, as in the prior year, no violations in the sense of legal violations due to corruption, bribery or antitrust cases that had been determined by an official authority or a court were identified in the Company.