Anti-corruption and bribery matters

Avoidance of corruption and anti-competitive behavior

Ethically correct and lawful conduct includes the prevention of corruption and anti-competitive behavior. HUGO BOSS expects all employees to act lawfully in day-to-day business operations. For HUGO BOSS, corporate compliance is a key responsibility of the Managing Board and includes measures to ensure adherence to legal and official regulations, as well as internal guidelines and codes. These include anti-corruption, anti-bribery, and antitrust regulations.

The central Compliance department reports directly to the CFO in his role as Chief Compliance Officer and supports him in the monitoring of effective compliance management. The department works together with the compliance officers in the Group companies to implement and continually further develop the compliance program. The Audit Committee of the Supervisory Board is kept regularly informed of the Compliance department’s activities.

Targets

Compliance management at HUGO BOSS aims at Group-wide legally compliant behavior. The aim is to prevent legal violations such as corruption, bribery and antitrust violations which may result not only in reputational and financial risk but may also lead to personal consequences under criminal and labor law.

Measures

All employees of HUGO BOSS are required to comply with the Group-wide Code of Conduct and supplementary specific compliance rules, such as antitrust law guidelines and capital market guidelines. Both the publicly accessible Code and the internal guidelines are reviewed regularly and the content is updated, especially with regard to changes in legal requirements. For example, the Company is currently revising its internal procurement policy, which it aims to complete in 2021. In addition, Group companies are subject to regular risk analysis and detailed audits where applicable. Any infringements are reported to the Managing Board and the Supervisory Board.

A Group-wide e‑learning program to be completed by all employees with PC access is intended to raise awareness of the compliance rules. From mid-2021, the program also will be available in Turkish, Italian, and Chinese, making a total of seven languages going forward. Staff in positions where compliance is particularly relevant receive topic-specific face-to-face training courses, such as antitrust law. HUGO BOSS does not tolerate any intentional misconduct or serious compliance infringements.

At HUGO BOSS, employees, suppliers and trading partners can notify an external ombudsman in confidence if there are any indications of fraud, infringements of antitrust law or other compliance breaches. If desired, it is also possible to do this anonymously. The ombudsman’s contact data can be found on the Company’s website.

Performance indicators

In 2020, the Danish competition authority found that there was a breach of antitrust law concerning the alleged disclosure of information relating to HUGO BOSS prices and quantities to local trading partners. HUGO BOSS took a different view of this and thus lodged an appeal with the relevant appeals board. A preliminary decision on this case is not expected before spring 2021. No fine has been imposed so far. Beyond this, in 2020, as in the prior year, no further violations in the sense of legal violations regarding corruption, bribery or antitrust cases determined by an official authority or a court were identified in the Company.