Case study: How Miele promotes compliance
With 13 plants at a total of 12 locations, 8 of which are located in Germany, Miele is the world’s leading supplier of premium appliances for kitchen, laundry and floor care, also offering solutions for commercial applications. All Miele employees worldwide are obliged to abide by the law at all times Tweet This! and to comply with internal guidelines, as well as self-imposed social and ethical standards.
This case study is based on the 2019 Sustainability Report by Miele published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.
Abstract
The corporate culture at Miele involves fair and cooperative conduct vis-à-vis customers, colleagues and business partners. That is why the Miele Code of Conduct was introduced in 2008. In order to promote compliance Miele took action to:
- implement a Code of Conduct
- raise employees’ awareness of compliance
- introduce an external ombudsperson
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With this case study you will see:
- Which are the most important impacts (material issues) Miele has identified;
- How Miele proceeded with stakeholder engagement, and
- What actions were taken by Miele to promote compliance
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What are the material issues the company has identified?
In its 2019 Sustainability Report Miele identified a range of material issues, such as resource-efficient and consumption-optimised products, climate protection, digital products and services, supplier management. Among these, promoting compliance stands out as a key material issue for Miele.
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:
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 Miele engages with:
To identify and prioritise material topics Miele engaged with its stakeholders through the following channels:
| Stakeholder Group | Method of engagement |
| Employees | · Works council · Employee reviews · Corporate suggestion scheme · Employee survey · Complaints office |
| Customers | · Miele Customer Service and sales talks · Customer hotline · Usability tests for various product groups in the test studio · Brand positioning surveys |
| Dealers | · Dialogue with dealers and project partners in the area of domestic appliances and commercial equipment, particularly concerning customer requirements |
| Suppliers and service providers
| · Common working groups · Discussions with Miele’s purchasing department · Dialogue in the context of audits and training · Product innovation workshops |
| Associations and interest groups
| · Membership and active participation in national and international associations and interest groups, such as the ZVEI or APPLiA · Conference participation · Participation in EU public consultations |
| Non-governmental organisations | · Dialogue with non-governmental organisations (NGOs) on relevant topics in the sector |
| Science and research
| · Collaboration with scientific institutions such as the universities in Bielefeld, Paderborn and Munich, as well as the Fraunhofer-Gesellschaft on issues such as product development · Commissioning of studies on specialist topics · Exchange with the Oeko-Institut |
| Policymakers and legislators
| · Dialogue at national and European level by participating in committees, working groups and conferences · International dialogue with the sales subsidiaries, which in turn are represented in working groups and committees · Personal exchange at a regional level |
| Society/ public/ media
| · Answering questions on sustainability topics · Sustainability communication and report |
| Local communities
| · Exchange with the citizens at the locations in direct contact and at events · Social engagement at the locations |
What actions were taken by Miele to promote compliance?
In its 2019 Sustainability Report Miele reports that it took the following actions for promoting compliance:
- Implementing a Code of Conduct
- The Miele Code of Conduct, which is available on the Miele intranet, contains provisions on how to prevent bribery and corruption, as well as policies on proper conduct in relation to conflicts of interest, donations and sponsoring. It also requires strict adherence to competition and antitrust legislation. The Code of Conduct is based on the corporate philosophy, the ethical guidelines for procurement, the principles of the UN Global Compact, the social standard SA8000 and the APPLiA Code of Conduct (formerly CECED). Since 2011, Miele has been a member of the BME compliance initiative and has committed itself to the association’s code of conduct. Compliance with individual aspects of the Code of Conduct, such as receiving and offering gifts, or how to deal with conflicts of interest, is reviewed in internal audits. In the event of violations, Miele will agree on corrective measures. As a rule, however, it is the responsibility of the functional managers to put appropriate guidelines in place to ensure that their employees’ tasks are always carried out in compliance with applicable laws, internal rules and the self-imposed ethical and social standards.
- Raising employees’ awareness of compliance
- At Miele, it is mandatory for relevant groups of employees to participate in an online compliance training programme on the Miele Code of Conduct. This includes managers as well as employees for whom the contents of the Miele Code of Conduct and the issue of compliance are particularly significant. They work primarily in the purchasing, internal audit, sales/field sales and specialist sales departments or are customer service inspectors. The programme is also open to all other interested employees and new employees are automatically informed that they have to complete the programme. To date, 3,514 people worldwide have completed the software-based training programme on the Code of Conduct, 812 of whom completed it during the reporting period. Since the end of 2016, employees at all locations involved in issues relating to competition and antitrust law are obliged to use this self-learning software on the subject of competition and antitrust legislation. The programme ends with a test, and records are kept on whether tests were passed. There is also a legal management system for the areas of environmental protection, energy and occupational health and safety, and an information management software system addressing product-related regulation worldwide.
- Introducing an external ombudsperson
- Since 2010, an external ombudsperson can be contacted if there is a suspicion of corruption, fraud or theft within Miele’s sphere of influence. Employees, suppliers and third parties all over the world are able to contact the ombudsperson. All employees throughout the world, and all suppliers in Germany, are informed about the existence of the ombudsperson upon starting work or entering into a relationship with Miele. No notifications were made to the ombudsperson during the reporting period, and there were no instances of contracts with business partners being terminated or failing to be extended due to corruption-related violations.
Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?
The GRI Standards addressed in this case are:
1) Disclosure 205-2 Communication and training about anti-corruption policies and procedures
2) Disclosure 205-3 Confirmed incidents of corruption and actions taken
3) Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices
4) Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area
Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:
- Sustainable Development Goal (SDG) 16: Peace, Justice and Strong Institutions
- Targets: 16.5
Disclosure 205-3 Confirmed incidents of corruption and actions taken 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
Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area 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 Miele, 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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