20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

We align our actions with our core values: simplicity, responsibility and reliability. These values also express the way the ALDI North Group sees and approaches compliance. Our mission statement “Simply ALDI” states, “We keep our word”. In line with our corporate image as real traders, all of our business decisions must always be driven by objective considerations. Our basis: the mission statement.  

ALDI North expects all employees and business partners to act with responsibility and reliability. Mandatory rules, policies and agreements must be observed, as also stated in the Compliance Goals document that all managers receive.  

The Compliance department is housed under ALDI Buying. It is assisted by the Compliance committee, which consists of representatives from all areas of activity and serves as the point of contact for information related to compliance matters.  

Our corporate mission statement and the compliance management system (CMS) provide ALDI North employees with clear guidelines for ensuring ethically unimpeachable conduct. The respective managers are responsible for making sure that the compliance rules are observed and for using appropriate controls specified in our CMS to check compliance with the rules.  

The General Terms and Conditions of Purchasing define clear rules that govern the relationship between suppliers and ALDI North. Anticompetitive conduct by suppliers and manufacturers is prohibited, and sanctions have been designated to punish any violations. The General Terms and Conditions of Purchasing also specify the compliance requirements for contractual partners. In addition, service providers must adhere to the Code of Conduct governing the observance of social standards for construction, works and services commissioned by the ALDI North Group.  

If there are reliable indications of a violation of these rules – whether by a supplier or an ALDI employee – the Compliance department and Compliance committee will assist in getting to the bottom of the incident through a thorough investigation of the matter. ALDI North takes a firm line on violations by suppliers or employees.  

The CMS, which serves as standard for the ALDI North Group, is designed to help employees live up to our ALDI North core values at all times. Above all else, the CMS aims to ensure and promote ALDI North’s long-term success, and to prevent any damage. The CMS is made available internationally to all ALDI companies. Country-specific adjustments are made in consultation with the respective responsible persons at the ALDI companies in the respective countries. Since late 2017, a compliance management tool (IT tool) has also been making it easier for the responsible managers of ALDI North companies in Germany to handle compliance risks, rules and measures. Plans are currently in the works to roll out this tool internationally.  

We perform various kinds of training to raise employees’ awareness of the importance of compliance. New employees receive training on the key policies of the ALDI North Group companies when they start work. In Germany, ALDI Buying employees in the Purchasing (including Quality Assurance), CR and Corporate Communication departments also regularly complete training, which covers topics such as antitrust law, unfair competition, protection of company and trade secrets, avoidance of corruption and the requirements of the Supply Chain Initiative (SCI). Training takes place at the ALDI North Group companies in the other countries as well. In early 2018, we held training sessions in Germany for some 700 managers of the individual regional companies where we addressed the CMS and the IT tool. The managers themselves are now able to train employees at the regional companies.  

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