Case study: How ALDI Nord promotes compliance

What are the material issues the company has identified?          

In its 2019 Sustainability Report ALDI Nord identified a range of material issues, such as human rights and working conditions in the supply chain, use of more sustainable packaging, reduction of greenhouse gas emissions, protection of forests and soils. Among these, promoting compliance stands out as a key material issue for ALDI Nord.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups ALDI Nord engages with:

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics ALDI Nord conducted online surveys of non-governmental organisations (NGOs), initiatives and associations, alongside business partners and suppliers.

What actions were taken by ALDI Nord to promote compliance?

In its 2019 Sustainability Report ALDI Nord reports that it took the following actions for promoting compliance:

• Implementing General Terms and Conditions of Purchasing
• ALDI Nord’s General Terms and Conditions of Purchasing define clear rules that govern the relationship between suppliers and the ALDI companies. Anti-competitive conduct by suppliers and manufacturers is prohibited. Sanctions are in place for potential violations, such as late delivery or failure of delivery. To ensure that ALDI Nord maintains the same standards across all of its operations, the General Terms and Conditions of Purchasing also specify compliance requirements for contractual partners. If there are reliable indications of a violation of the rules – whether by a supplier or an ALDI employee – the Compliance officers will undertake a comprehensive investigation.

• Applying a Compliance Management System
• ALDI Nord’s Compliance Management System (CMS) is designed to help ALDI employees live up to ALDI’s core values at all times. Above all else, the CMS aims to ensure and promote ALDI Nord’s long-term success and avoid or mitigate any damage or risk. The CMS is internationally available to all ALDI companies but has yet to be introduced and implemented in some countries, such as ALDI Belgium and ALDI France. Each ALDI company has a person responsible for country-specific adjustments. As a part of the CMS, whistleblowing systems that serve to receive information on compliance violations within ALDI Nord have been created. Any violations of applicable law and internal rules can be reported through these channels under a specific name or anonymously. Examples of violations include corruption, unfair competition and unethical behaviour, as well as non-compliance with environmental standards. In Germany noncompliance with social standards such as human rights and work safety regulations may also be reported in this way. The whistleblowing systems are available on the French, German and Spanish websites for internal and external parties at all times. There are also grievance systems and other channels in place, for example at ALDI Netherlands, which ALDI employees have been able to use in cases of sexual harassment, bullying, discrimination, aggression and violence.

• Providing training
• To ensure that compliance forms an integral part of ALDI Nord, a variety of training courses are conducted to raise awareness among ALDI employees. New employees receive training on the key policies of ALDI Nord. In Germany, authorised signatories and managing directors of ALDI Einkauf in all departments also regularly complete training, covering a wide range of critical topics such as antitrust law, unfair competition, protection of company secrets, avoidance of corruption as well as data protection and information security. Since September 2019, this has been part of compulsory attendance training at the ALDI Academy. Similar training also takes place at the ALDI companies in Belgium, France, the Netherlands, Portugal and Spain every two to three years. In Spain, this training was completed in 2019 by both managers and non-executives so that the knowledge is passed down through the team. ALDI Nord is also expanding communication regarding compliance on the websites and takes part in industry events, such as the Bundeskongress Compliance (Federal Compliance Congress) in Germany.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 205-1 Operations assessed for risks related to corruption

2) Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

Disclosure 205-1 Operations assessed for risks related to corruption corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.5

Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices corresponds to:

• Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
• Targets: 16.3

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References:

1) This case study is based on published information by ALDI Nord, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

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