Special attention is paid to infringements of antitrust and anticorruption law because these can cause substantial financial or reputational damage (see section “Opportunities and Risks” in the Management Report) Our specific Antitrust and Anti-Corruption Policies set forth our commitment to ensure that QIAGEN and its subsidiaries abide by the antitrust and anti-corruption laws of the countries in which we operate.
All our policies are provided to all employees worldwide. Online training reaches all employees in local language, supported by multiple communication resources. All new employees are required to take online training on our Corporate Code of Conduct and Ethics at a minimum. Additional trainings which are customized to the specific area of responsibility are mandatory. All employees in Sales and Marketing as well as Upper Management are required to take training on corruption and anti-trust laws. Such basic trainings are followed by refresher courses on a regular basis.
We have established a hotline for reporting accounting-related concerns on an anonymous basis in good faith. We also offer a direct email and telephone hotline for employees to address questions or make suggestions for our Compliance Program. In the reporting period no cases with regard to antitrust or corruption had been reported.
Our Compliance Program is overseen by the Compliance Committee under the leadership of the Head of Legal Affairs and Compliance, that coordinates our efforts, consisting of managers from Legal, Internal Audit, HR, Commercial Operations, Trade Compliance and Regulatory functions. The Compliance Program is overseen by the Audit Committee of the Supervisory Board.
The Head of Legal and Compliance coordinates investigations and enforcement as necessary and gives regular updates to the Executive Committee. In the reporting period QIAGEN had no legal actions pending or completed with regard to antitrust or corruption.