Conduct and integrity
Culture and structure
Heijmans attaches a great deal of importance to integrity. Openness is a key condition for this. We encourage an open working attitude by having the Executive Board and senior management set an example. We also discuss integrity issues in the Executive Board meetings and group board meetings. We hold review meetings with the managers of the business areas, in which we discuss both financial results and other topics and dilemmas that affect operations. This is how we try to embed our open culture in the organisation as much as possible. We have also introduced a structure for the reporting of issues related to conduct and integrity. If necessary, the reported issue will be investigated and action can be taken.
Integrity Committee
The task of the Integrity Committee is to advise the Executive Board on integrity-related matters. The Integrity Committee discusses integrity-related issues, dilemmas and themes and all related matters. On the basis of these discussions, the committee then issues policy recommendations, such as the need to initiate training courses. The Executive Board establishes the policy and decides which actions are to be taken in this context. The committee is chaired by the CEO. The other core members of the Committee are the Compliance Officer, the Chief Procurement Director, the Chief Human Resources Officer, the Chair of the Works Council and a representative from Property Development responsible for integrity-related matters. The topics discussed include the implementation of conduct and integrity training, the functioning of the Code of Conduct, improving the reporting structure, and the ways in which Heijmans can keep the subject of integrity permanently top of mind for employees.
Reporting structure: compliance officer and confidential counsellors
Heijmans prioritises a safe working environment. This includes a safe reporting environment, a working environment in which all employees feel safe to report situations violating the Code of Conduct or core values without fearing for their position. In other words, employees must feel that they can go to their supervisor or to a confidential counsellor without fearing for their job. Heijmans facilitates this safe environment by providing an effective reporting procedure that enables anonymous reporting, and by taking every report seriously. Heijmans also actively demonstrates the consequences of unacceptable behaviour, including opening this for discussion on Yammer, and in management team meetings and work meetings.
Heijmans has appointed a compliance officer as a central point of contact and reporting point for (suspected) abuses and integrity issues. The system safeguards anonymity of reports and the compliance officer reviews per report which actions are necessary and which procedures apply. The compliance officer also reports on reports anonymously at Executive Board meetings. In many cases, issues are resolved on the shop floor, for example through a conversation between employee and supervisor.
In addition, in late 2021 Heijmans appointed six new confidential counsellors, who introduced themselves via a communication campaign in early 2022. This means Heijmans now has seven people employees can turn to when faced with inappropriate behaviour, such as discrimination, sexual harassment, bullying, aggression, violence or any other inappropriate behaviour. The group of confidential counsellors is diverse and consists of men and women who differ in terms of their positions, background and place in the organisation. Employees can contact the confidential counsellor of their choice.
If employees cannot or do not wish to approach the compliance officer or confidential counsellor, they can always report anonymously via SpeakUp, an external platform.
Business Integrity
Heijmans attaches enormous value to the integrity of its employees, which is a prerequisite to running a successful company. That is why we developed the Zakelijk Zuiver (Business Integrity) programme, consisting of an e-learning course and physical dialogue sessions in which colleagues discuss dilemmas with each other. After it was necessary to postpone the in-person dialogue sessions as a result of the Covid-19 outbreak, these sessions finally started in the summer of 2022. Around 90 members of management attended the train-the-trainer sessions. A large number of them have already led their assigned dialogue sessions on integrity and conduct. By the end of 2022, some 1,400 employees had attended or been invited to attend dialogue sessions. We expect to complete all dialogue sessions by the summer of 2023. Direct employees follow a Business Integrity module in the collective bargaining agreement training days. We also offered the e-learning course to our Supervisory Board members.
Heijmans Code of Conduct
The Heijmans Code of Conduct is not voluntary and applies to everyone involved with Heijmans: the management, our (temporary) colleagues, but also our partners, subcontractors and suppliers.
Dilemmas and conduct
Heijmans is convinced that conduct has a major impact on the quality and results of the company. For example, the impact of conduct in the field of safety; in the construction industry, this can make all the difference.
Heijmans still faces integrity and conduct issues. Not everyone has the same opinion about what is and is not acceptable. A large proportion of the reported issues are related to the dilemmas below:
Should you call someone to account or not
Calling each other to account in the event of unacceptable behaviour - in line with the standards we strive to maintain - actively encourages more openness and, in the end, more acceptable conduct. Calling each other to account is a form of ownership and taking responsibility. For example, calling each other out on the wearing of safety clothing, the separation of waste at building sites, or the deliberate submission of incorrect expense sheets, the use of company property for personal purposes and unacceptable behaviour towards third parties. To make it easier for employees to call each other to account in cases of unacceptable behaviour, we organise dilemma discussion groups, provide toolboxes and regularly put the subject of integrity and conduct on the agenda of work consultations. Employees can use these consultations to discuss certain issues or certain kinds of conduct both openly and freely.
Acceptable versus unacceptable behaviour
It is sometimes difficult to define the fine line between acceptable and unacceptable behaviour, but it is crucial for the culture on the shop floor. Heijmans considers a safe working environment - where everyone is treated with respect – a prerequisite on this front. We do not accept unacceptable behaviour. We take appropriate measures whenever necessary.
Self-determined rules versus applicable rules
Not everyone abides by the rules of our Code of Conduct. This can apply to submitting expense claims, remuneration or the use company assets. It can be difficult for (new) employees to call out colleagues on the rules that actually apply. That is why we devote attention to the subject of conduct and integrity in work meetings, toolboxes, management meetings, progress meetings and in the Business Integrity programme. And to the importance Heijmans attaches to a safe working environment in which everyone dares to speak out.
Compliance / reports
The compliance officer and confidential counsellors received a total of 30 reports on integrity issues and unacceptable behaviour in 2022. This was more than in 2021. No reports were submitted to the anonymous reporting line. Heijmans encourages employees to report alleged wrongdoing and offers various opportunities to do so. In addition, the compliance officer herself pursues an active policy. She makes regular enquiries among management and HRM. The Executive Board feels it is important that employees feel free to report matters. Everyone needs to know that their report will be treated seriously. Partly for this reason, the employee engagement survey, which we will repeat in the autumn of 2023, will devote extra attention to unacceptable behaviour.
Confidential counsellors received reports of unacceptable behaviour of various kinds, such as inappropriate or unprofessional behaviour by employees in various positions, verbal aggression and sexual harassment. Furthermore, reports included not following internal procedures and possible administrative irregularities. In each case, the management first considered the seriousness of the case and then conducted a fact-finding exercise. In one case, an investigation was conducted by a detective agency. The reports resulted in written (final) warnings or, in some cases, termination of the employment contract. All reports (anonymised where necessary) were also discussed in board meetings and evaluated afterwards with the management members involved.
Integrity and conduct
The integrity and conduct Heijmans expects from its employees are laid down in a number of regulations and guidelines:
Dossier statement: in this statement, the responsible manager explicitly declares that there was no anti-competitive behaviour in the preparation of the tender. The statement is part of the so-called final sheet, the calculation of the tender price that is signed off by the management and the Executive Board.
Integrity-sensitive positions: Heijmans has a ‘Procedure for integrity-sensitive positions’. Integrity-sensitive positions include members of the Executive Board, members of the group board, members of the senior management and a number of specifically defined positions. Screening is mandatory for these functions. Employees in integrity-sensitive positions and applicants applying for such positions are asked to provide a Personal Statement of Judicial Records and are also asked to submit a Certificate of Good Conduct.
Reviews: the Executive Board discusses integrity issues and shares these, anonymously, with the management teams. In consultation with the Integrity Committee, the Executive Board makes sure that reports and issues are translated into appropriate policies.
Heijmans Code of Conduct: the ‘This is how we work’ code is about being respectful with each other, safety, integrity, honesty and following rules. The Code of Conduct applies to everyone who works at or for Heijmans. A sanctions policy is linked to the Code of Conduct. We ask managers to set an example. The Code of Conduct forms an integral part of the employment contract with permanent and temporary staff and also applies to any self-employed people with whom Heijmans works.
Integrity is a fixed topic in job interviews and induction programmes.
To promote integrity in project development, in 2009 Heijmans Property Development set up a Transaction Register in accordance with the NEPROM Code of Conduct. This complements the quality management system and the Heijmans Code of Conduct. The Transaction Register is used to examine, record and document the relevant details of each business-to-business property transaction in advance. This enables Heijmans to check transactions retrospectively for correctness, integrity and legality. This is also laid down in the Heijmans Procurement policy.
Procurement policy. We ask new suppliers to sign a ‘Sustainability statement’. This statement includes ground rules for improvements in social aspects, working conditions and safety, health and the environment.
Privacy compliance
Heijmans devotes significant attention to privacy compliance. All employees regularly follow an e-learning module on this subject, and we share a lot of practical information via our internal platform Yammer. We host specific training sessions and lectures for various target groups. We have also appointed GDPR (General Data Protection Regulation) contact persons in all our business areas, who can offer advice on all privacy matters. On a central level, the Chief Privacy Officer and the privacy officer focus on policy-related aspects.
Over the past few years, we have brought the topics of cybersecurity and privacy to the attention of employees through e-learning modules and communication campaigns. Given the increasing importance and complexity of both topics, the privacy office and IT security conducted a joint study into the possibilities of raising awareness of cybersecurity and privacy. Since both topics overlap to some extent, it was decided after this study to start a multi-year Cybersecurity & Privacy awareness programme in 2023. This will focus more on behavioural change and less on knowledge transfer. Heijmans will also use technology to actively reduce risk even further.
Fighting corruption and bribery
The trust our clients and partners, as well as our shareholders and employees, have in our company is crucial to our licence to operate. That trust will be damaged if Heijmans or its employees are found guilty of corruption and/or bribery. Fighting corruption and bribery is therefore an integral part of Heijmans’ general compliance programme. Heijmans’ code of conduct applies to the employment contract of every employee. It states that Heijmans expects employees to avoid all actual or apparent conflicts of interest between personal and business interests. Employees are not allowed to accept or offer any gifts or invitations that call into question their independence. Offering such gifts could also endanger the independence of either Heijmans or the purported recipient of said gifts or invitations. Heijmans and its employees must strictly abide by all legal regulations and generally accepted norms applicable to business operations and that are expressed in Heijmans’ own guidelines, such as the Transaction register used within Heijmans Property Development. We impose the application of our code of conduct or an equivalent code on the subcontractors and partners with whom we do business.
If an employee can, by the nature of their position, find themselves in a situation where they may encounter corruption or bribery, the company will devote specific attention to this situation, for instance by organising special training. This primarily applies to our Procurement department. Heijmans has taken measures at this department to minimise the risk of bribery and corruption. For instance, the department is centrally organised, which increases the level of direct supervision. Procurement has a clearly defined segregation of tasks and procedures that are subject to the ‘four eyes principle’. The department uses standard contracts that are exchanged digitally. Preferred suppliers are also selected and evaluated centrally and very carefully on the basis of a transparent evaluation system. Suppliers that do not meet Heijmans’ standards can no longer be preferred suppliers. This approach has proven very successful. The indicators associated with this theme are ‘Purchasing spend at preferred suppliers’ and ‘Purchasing spend at preferred suppliers with framework contract with signed sustainability statement’, as included in the KPI table in the appendices.
Compliance
Heijmans requires suppliers and subcontractors to comply with Heijmans’ Code of Conduct and act in accordance with the principles and requirements set out in the ‘Sustainability Statement’.
Additional and separate regulations
The values from the Code of Conduct are sometimes laid down in supplementary and separate regulations:
Internal reporting procedures inappropriate behaviour and irregularities
For situations in which it is difficult to find a solution within the day-to-day work situation, in early 2022 Heijmans introduced updated internal reporting procedures for inappropriate behaviour and irregularities. These procedures set out the steps to be used to report inappropriate behaviour and (suspected) irregularities. In addition, they describe how an investigation into a report proceeds and what role management plays in this.Heijmans N.V. Insider Trading Regulations
These regulations contain provisions that apply to the officers named by law and to other Heijmans employees. These regulations were amended following the implementation of the EU Market Abuse Regulation in mid-2016.Private investment regulations
Heijmans has a set of regulations that apply to personal investments by members of the Executive Board and the Supervisory Board. The Chairman of the Executive Board is the compliance officer for transactions in shares, depositary receipts for shares and options on shares for a member/the members of the Executive Board. The Chairman of the Supervisory Board acts as the compliance officer for the Chairman of the Executive Board.