Our global Compliance Management System

Our Compliance Management System (CMS) helps us to ensure that legal regulations are complied with while implementing our internal company policies and ethical standards, to which we are committed.

Overall responsibility for the CMS lies with the Management Board of Verbio SE. Our Head of Global Compliance advises and supports the Management Board in fulfilling its compliance-related due diligence obligations and reports directly to the CFO.

The Head of Global Compliance is responsible for the management, implementation and further development of the CMS and heads the Global Compliance department. In this respect, Global Compliance is responsible for all Group-wide compliance activities.

For all continents in which Verbio SE operates, Global Compliance is supported by local specialists and managers (Local Compliance Coordinators). The Local Compliance Coordinators are responsible for coordinating and monitoring the day-to-day implementation of the CMS in accordance with the requirements and recommendations of Global Compliance in the area for which they are responsible. Due to their technical and location-specific expertise, they are able to assess and identify local compliance risks. On a case-by-case basis and as required, they coordinate closely with Global Compliance.

Innovative solutions have made Verbio the technology leader in the European biofuels market. In Asia and North America, we are on course for international growth.

In order to achieve our goals, employees, customers, business partners and all other stakeholders must be able to be sure that our actions always meet the highest standards.

That's why we've established a global corporate culture that focuses on professionalism, honesty and responsibility. Our central compliance rules form our corporate commitment.

All compliance activities as well as internal guidelines and procedural instructions are based on the central compliance rules (Corporate Commitment Policies).

These are:

• the Code of Conduct (PDF)
• the Supplier Code of Conduct (PDF), and
• the Statement on Respect for Human Rights (PDF).

The benchmark for all business activities and compliance measures is the Verbio Code of Conduct (PDF), which is addressed to our employees. The Code of Conduct translates our corporate values into clearly defined, central rules of conduct for all managers and employees worldwide, provides them with orientation in fulfilling their daily work and forms the basis of our corporate culture.

To ensure that these binding regulations are known and observed, we attach particular importance to the training of our employees. All new employees receive training on the Code of Conduct as part of their onboarding. (Future) Managers are given the opportunity to attend a leadership training course. We pay particular attention to informing our employees in sales-related areas and purchasing intensively about corruption prevention and explaining to them the correct behavior when receiving benefits and invitations.

In addition, the specifications for each area of responsibility are­ specifically drawn up on the basis of other, locally applicable internal company policies.

On the company's internal Verbio intranet, all employees can find detailed information and assistance on corporate commitment policies and various compliance topics.

Outside our company, we are also committed to respecting and complying with human rights and international labour standards as well as combating corruption. Verbio is a member of the UN Global Compact and is committed to adhering to the principles set out therein.

We are convinced that only by openly addressing problems or concerns can existing or imminent conflicts be resolved in a constructive way. We therefore attach particular importance to the fact that our employees actively seek advice at an early stage in the event of any questions or doubts. In addition to managers and responsible departments such as the legal and/or human resources departments, the Global Compliance department is available as a point of contact for various compliance topics via direct contact.

Sometimes, however, it is possible to report concerns confidentially and anonymously. Another central element of our CMS is therefore the Verbio whistleblower system:

Employees and external third parties can anonymously report misconduct or violations of our compliance principles either via a website or a toll-free telephone number.

Verbio has commissioned an independent external company to carry out the technical implementation of the whistleblowing system, so that all reported cases worldwide are recorded and processed by a central system in the respective national language.

The Verbio Corporate Commitment Policies provide guidance on how to deal with the most important compliance issues and are the benchmark for all our business activities.

We therefore encourage anyone who has knowledge or suspicion of an actual or potential compliance violation to use the available avenues to report such violations. In order to be able to detect violations of laws and regulations in good time, to remedy them immediately and, if necessary, to punish them, the cooperation of each individual is required.

In addition to contacting Global Compliance directly, our telephone or web-based whistleblowing system is available for this purpose – free of charge, anonymously and available 24/7.

Verbio Compliance Hotline (toll-free)
Germany: +49 30 992 571 46
United States: +12 13 279 101 5
The Company Access PIN is 1004.

Verbio Whistleblower System

Verbio undertakes to investigate all (potential) compliance violations of our Corporate Commitment Policies and/or applicable legal norms. Each report is recorded according to certain criteria, properly investigated according to the internally defined procedures and answered in the shortest possible time. The results of the investigation and any measures taken are documented accordingly and are incorporated into internal reporting.

The Procedure for the Whistleblower System (PDF) contains all further information.