The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How SIX promotes compliance and lawful conduct

SIX is a financial service provider that operates the infrastructure of Switzerland’s financial centre, ensuring the flow of information and money between banks, traders, merchants, investors and service providers globally. Accordingly, SIX is committed to complying with local laws, to not engaging in anticompetitive conduct, and to combatting corruption.  Tweet This!

This case study is based on the 2016 Corporate Responsibility Report by SIX 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.

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For SIX and its employees it goes without saying that, in every business activity, all applicable laws, regulations and internal guidelines and directives must be complied with, supporting lawful conduct. In order to promote compliance and lawful conduct SIX took action to:

  • implement a Code of Conduct
  • provide compliance training
  • implement a whistleblowing tool
  • combat corruption

What are the material issues the company has identified?

In its 2016 Corporate Responsibility Report SIX identified a range of material issues, such as contributing to the stability and attractiveness of the financial centre, creating a working environment that provides opportunities for all employees and empowers them to give their best, client satisfaction, forward-looking services. Among these, promoting compliance and lawful conduct stands out as a key material issue for SIX.

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 organization should identify its stakeholders, and explain how it has responded to their reasonable expectations.”

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 SIX engages with:   

Stakeholder Group                Method of engagement
Owners ·      Continuous dialogue
Politicians ·      Continuous and active relationship management
Suppliers ·      Project-related discussions
Industry associations

 

·      Active cooperation in working groups

·      Management of membership

Regulatory and supervisory authorities ·      Regular reporting

·      Cooperation in working groups and consultations/hearings

Academia ·      Project-related dialogue
Employees ·      Biannual employee survey
Customers ·      Annual customer satisfaction survey

·      Dialogue about top account management

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics SIX engaged with its stakeholders through an employee and client satisfaction survey, in addition to dialogue with representatives from various stakeholder groups.

What actions were taken by SIX to promote compliance and lawful conduct?

In its 2016 Corporate Responsibility Report SIX reports that it took the following actions for promoting compliance and lawful conduct:

  • Implementing a Code of Conduct
  • The SIX Code of Conduct describes the legal framework and rules that all employees have to observe and uphold. Detailed Group directives specify the duties of all SIX employees and SIX has also issued a new directive, which systematically specifies the financial market regulations that SIX must observe and implement, in both Switzerland and abroad. Since the end of 2015, SIX has been carrying out a Group-wide annual compliance check, across all its locations.
  • Providing compliance training
  • To provide employees with more information on the topic of compliance, SIX organised a number of employee training sessions during the reporting year, with particular emphasis on compliance training for new employees, and courses on the Code of Conduct and on the Group directives, at certain international locations. Additionally, various courses on the theme of money laundering took place in Switzerland and Luxembourg.
  • Implementing a whistleblowing tool
  • SIX rolled out a whistleblowing tool at the start of 2016, enabling SIX employees to report irregularities on an anonymous basis. The Group directive specifies a reporting duty in the case of suspicion of serious misconduct that could have material detrimental consequences for SIX (for example, significant losses, regulatory implications, or severe reputational damage). Three cases were reported in 2016 and in one of these cases Compliance opened an investigation, but it was not possible to confirm the suspicion. In the 2016 reporting year, as in 2015, SIX and its companies were not required to pay any significant fines and did not have any non-monetary sanctions posed on them.
  • Combatting corruption
  • SIX provides information on corruption in employee training courses, on the Code of Conduct, and in staff advisory sessions. All employees are bound to respect the interests of their employer in their professional activities and conflicts of interest should principally be recognised by employees, with the necessary steps taken to avoid them. If a conflict of interest cannot be avoided it must always be disclosed and, in certain cases, a business activity may have to be renounced, due to a conflict of interest. The exercise of public offices, political or economic mandates and secondary forms of employment must be disclosed and submitted for approval, where appropriate. Donations and sponsorship money are awarded only by the Group Executive Board or the CEO. No incidents of corruption were reported, during the reporting year.

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

The GRI Standards addressed in this case are:

1) Disclosure 205-3 Confirmed incidents of corruption and actions taken

2) Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area

 

Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption

Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Compliance with laws and regulations

 

80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.



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References:

1) This case study is based on published information by SIX, 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) http://www.fbrh.co.uk/en/global-reporting-initiative-gri-g4-guidelines-download-page

3) https://g4.globalreporting.org/Pages/default.aspx

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

Note to SIX: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.

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