Culture and structure
Heijmans attaches enormous value to integrity. Transparency is a basic prerequisite for integrity. We encourage an open working attitude by making sure the Executive Board and management set a good example. We discuss integrity issues at Executive Board and Group Council meetings, and we organise review meetings with the managements of the business areas. This is how we try to safeguard our open culture as much as possible. We have also set up a structure for employees to report conduct and integrity issues. If necessary, we launch an investigation and will take action if necessary.
Integrity committee
The integrity committee advises the Heijmans Executive Board on integrity issues and met twice in 2023. The committee discusses issues, dilemmas and themes in the field of integrity and all related topics. Based on this, the committee issues policy recommendations. The Executive Board then adopts the policy and decides what actions to take. The CEO chairs the committee. The core membership also includes the Compliance Officer, the Chief Procurement Officer, Chief Human Resources Officer, the Chairman of the Works Council and an integrity officer from Property Development. Topics of discussion include the content of integrity and conduct training courses, the operation of the code of conduct, improvements to the reporting structure and how we can keep integrity top of mind among our employees.
Reporting structure: compliance officer and confidential counsellors
Working safely is a key priority at Heijmans. This includes a safe reporting environment, a (work) environment in which all employees feel free to report matters that contravene our Code of Conduct and/or core values without having to worry about their position. This means that they dare to seek out a supervisor or confidential counsellor without fearing for their job. Heijmans facilitates this safe environment through a sound reporting procedure, which also allows people to report anonymously, and of course by taking all reports seriously. Heijmans also actively demonstrates the consequences of unacceptable behaviour, including by raising the issue for discussion on Viva Engage and in management team and work meetings.
Heijmans has appointed a compliance officer as a central point of contact and reporting point for (suspected) abuses and integrity issues. In addition, the compliance officer herself pursues an active policy. She makes regular enquiries among management and HRM. Anonymity of reports is guaranteed and the compliance officer examines which actions are needed per report and which procedures apply. The compliance officer also reports anonymous reports during Executive Board meetings. In many cases, issues are resolved on the shop floor, for instance through a conversation between an employee and their manager.
In addition, we have appointed eight confidential counsellors. Employees can turn to them if they encounter undesirable behaviour, such as discrimination, sexual harassment, bullying, aggression, violence or other undesirable behaviour. The group of confidential counsellors is diverse and consists of men and women who differ in terms of their position, background and place in the organisation. Employees can contact the confidential counsellor of their choice.
If employees cannot or do not want to approach the compliance officer or confidential counsellor, they can always report anonymously via SpeakUp, an external platform. Heijmans received no reports via this platform in 2023.
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. We started the dialogue sessions in 2022 and had completed them by the end of 2023. By year-end 2023, 2,900 indirect employees had participated in these dialogue sessions. The sessions were facilitated by around 90 members of our management, who attended a train-the-trainer session for this purpose. Direct employees follow a Zakelijk Zuiver module in the collective bargaining agreement training days. We also offered the e-learning course to our supervisory directors.
The e-learning course remains a regular part of our onboarding programme. To keep the issue of conduct and integrity top of mind among our employees, the Executive Board devotes attention to it in video messages, while we also organise workshops and offer toolboxes, plus it is featured regularly on Viva Engage.
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 following dilemmas:
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Calling each other to account or not
Calling each other to account for undesirable behaviour - in line with the standards we strive to maintain - encourages more openness and, in the end, more acceptable conduct. Calling each other to account is a form of ownership and a sense of responsibility. For example, employees call each other to account about wearing personal protective clothing, separating waste on building sites or submitting incorrect expense claims, not abiding by rules or agreements made, using company equipment for private use and undesirable behaviour towards each other or third parties. To make it easier for employees to call each other to account, we organise dilemma meetings, provide toolboxes and regularly put the subject of integrity and conduct on the agenda of work meetings. In these meetings, we openly discuss certain issues, dilemmas or certain kinds of behaviour. -
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.
Reports
The compliance officer and confidential counsellors received a total of 41 reports on integrity issues and unacceptable behaviour in 2023, which was more than in 2022. No reports were submitted to the anonymous reporting line (SpeakUp). Heijmans encourages employees to report alleged wrongdoing. 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 we conducted in the autumn of 2023, devoted extra attention to unacceptable behaviour. We find it encouraging to learn via the survey that, according to people who had submitted reports, more than 70% of reports are dealt with adequately and they are satisfied with this.
A large proportion of the reports were prompted by labour disputes, but there were also reports of undesirable behaviour of various kinds, such as inappropriate and/or unprofessional behaviour by staff in various positions, verbal aggression and sexual harassment. Furthermore, reports included not following internal procedures and possible administrative irregularities. In each case, the Executive Board first considered the seriousness of the matter and then conducted a fact-finding investigation. Among other things, the reports led to written (final) warnings and, in a few cases, immediate dismissal. All reports (anonymised where necessary) were also discussed in Executive Board meetings and evaluated afterwards with the members of the management team 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 measures and 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. The Code of Conduct is linked to a sanctions policy. We ask managers to set a good 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
Integrity is a fixed topic in job interviews and induction programmes.
Transaction register
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. In the transaction register, we examine, record and document the relevant details of each business-to-business property transaction in advance. This enables us 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 Viva Engage.
We provide specific training sessions and lectures for specific 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. At 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, in 2023 the privacy office and IT security launched a long-term Cybersecurity & Privacy awareness programme. This focuses more on behavioural change and less on knowledge transfer. Heijmans will also use technological tools to actively privacy 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 could be damaged by corruption 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 at 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 offering these employees a training course. 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.
Compliance
Heijmans requires all suppliers and subcontractors to comply with the 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:
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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.