STRATEGY 12The HSE strategy – safety firstOur Health, Safety and Environment (HSE) strategy is a keycomponent of our sustainability strategy and our corporatestrategy for years. Our aim is to be the safest chemical distributor,and when it comes to safety, we do not make any compromises.This is the basis for our global HSE strategy. Feelingresponsible and taking responsibility are vital when it comesto health, safety and the environment. The extent to which<strong>Brenntag</strong>’s employees support our aims is proven by theirdedication and commitment to continue maintaining existingprocesses.Our HSE strategy is divided into the following topics:Safety policyThe health of our employees and the safety of our sites arean absolute priority for <strong>Brenntag</strong>. We work on continuallyimproving work processes and plant safety.Product stewardship policy<strong>Brenntag</strong> takes appropriate measures to ensure the properhandling of its products while they are under the Group’sstewardship. This includes procurement, packaging, classificationand labelling, handling and storage, possible disposaland providing product dossiers and safety instructions.Environmental policyWe continually work towards minimising environmentalimpacts on soil, water and air. There are no cases of finesfor non-compliance with environmental laws known abovea threshold of EUR 2,000 in 2012.HSE compliance policy<strong>Brenntag</strong> is committed to complying with all health, safetyand environmental requirements, including import andexport regulations, marketing and use restrictions forchem-icals in all its operations and sales organisations.We also take part in the International Council of ChemicalTrade Associations’ (ICCTA) Responsible Care/ResponsibleDistribution (RC/RD) programme. We will go into moredetail on this topic at the start of the chapter entitled“Processes”.We are members of all the regional and local associationsfor chemical distributors – Fecc (Europe), APLA (Latin<strong>America</strong>), NACD (<strong>North</strong> <strong>America</strong>) – and play a leadingrole in them.In order to be able to measure our performance in the fieldsof quality, safety, health and the environment effectively, wehave developed various programmes whose evaluation criteriaare based on regional requirements. The programmesare focussed on promoting a culture of excellence in safetythroughout the entire company.The following HSE programmes have been launched inindividual regions:Europe: “Cornerstone Programme”<strong>North</strong> <strong>America</strong>: “<strong>Brenntag</strong> Cornerstone Process”Latin <strong>America</strong>: “CASA”Asia-Pacific: “5-Star Facility Award”Training sessions for our employees are of major importanceto occupational safety. This starts with safety introductionsfor new colleagues and continues with presentations ondealing with specific work processes and equipment.Training sessions that are required by law are documentedfor the individual warehouse locations, as are all other trainingsessions. Digital means are also increasingly integratedinto training sessions via e-learning and video clips.As a result of these ongoing improvements to our safetymeasures, we continiously reduced the number of reportableindustrial injuries in 2012. From 65 cases in 2011, thenumber decreased to 55 cases in 2012. This also led to adecrease in the lost time injury rate (LTIR) from 2.5 in 2011to 2.0 in 2012. The LTIR describes the number ofoccupational incidents resulting in at least three days offwork per million working hours (3 d/1 mill).At <strong>Brenntag</strong>, all occupational incidents are analysed downto the smallest detail by our international team of experts.The results of these analyses are translated into concretemeasures and initiatives to ceaselessly improve occupationalsafety (for example, Cornerstone in Europe and <strong>North</strong> <strong>America</strong>).Year Number of LTIRreportable injuries2011 65 2.52012 55 2.0Corporate Compliance –a term with added valueWe are committed to a high level of integrity in our businesstransactions, in dealing with our customers, suppliersand competitors, as well as towards our employees and thepublic.As a global company, <strong>Brenntag</strong> is subject to a wide varietyof laws, policies and regulations. As part of <strong>Brenntag</strong>, eachof us has a personal responsibility to conduct ourselves instrict compliance with the letter and spirit of these laws,policies and regulations.
STRATEGY 13The Code of Business Conduct and Ethics summarises.<strong>Brenntag</strong>’s basic corporate values, ethics, laws, rules andregulations and the related policies and procedures of thecompany which are particularly important to the companybusiness and the preservation of its admirable name and reputation.The Code of Business Conduct and Ethics contains fundamentalrequirements with regard to health, safety and theenvironment, how to deal with business partners or publicinstitutions, bribery and corruption, competition and antitrustlaws, avoidance of conflicts of interest as well as dataprivacy and information security.Key aspects of our compliance activities are the adherenceto competition regulations and the protection ofthe environment and personal health. We conduct regularemployee training sessions on compliance with the aim tokeep the employees’ knowledge up-to-date and avoid anyillegal actions as well as to protect the environment, theemployees and the company.Compliance Reporting and Organisation<strong>Brenntag</strong> has installed established procedures throughoutthe Group for receiving and handling complaints and anonymousreports of questionable matters. In case employees,business partners or the public in general have concernsabout any activity by our company and its employees, wehave created a portal on our website where these concernscan be reported. The information received is treated inthe strictest of confidence so the source of the informationdoes not suffer any negative consequences frommaking complaints or reports. Any received reports areexamined, evaluated, investigated and appropriate actiontaken if an infringement has taken place. These processesare steered by the Governance, Risk & Compliance (GRC)Manager at <strong>Brenntag</strong> AG.Material complaints and reports are addressed to therelevant member of the Compliance Committee, an internaladvisory body whose members include corporatedepartmental heads representing the various corporatedisciplines, where also general questions on complianceare discussed.Current compliance cases as well as the further developmentof the Group-wide compliance organisation andstructures are regularly reported to the Audit Committeeof the Supervisory Board. On operational level RegionalCompliance Managers ensure close monitoring of ourbusiness activities.Warehouse in Querétaro, Mexico