How we Engage in the Political Debate

Henkel’s business activities are affected by and at the same time have an impact on public policy discussions, political decisions as well as societal behavior and debates. We are convinced that sharing expertise in the context of public policy debates and political decisions is important to best meet societal challenges and to ensure that the legitimate interests of its employees, clients, consumers and shareholders are represented at all levels in political and societal discussions.

We interpret our stakeholder role as one of a solution provider enhancing factual knowledge in the decision-making process about regulatory impacts on our businesses. Our activities also improve the quality of implementation of political ideas and projects by offering a reality-check of political ideas and by playing an active role in business impact assessments.

Our participation in political debates is at all times guided by our strong Values, the Code of Conduct and our Standards and is at no time intended to risk or harm compliance with applicable law. Henkel, for example, has been a signatory to the UN Global Compact since 2003 and is committed to do business responsibly and in line with the 10 Principles on human rights, labor, environment and anti-corruption.

The Code of Conduct contains the most important corporate principles and behavioral rules. It is supplemented by guidelines for dealing with potential conflicts of interest. These guidelines are the basis of our preventive measures against corruption and hold our employees and managers personally accountable for misbehavior against these principles. Based on that, our Public Affairs Standard is dedicated to make Henkel’s public affairs activities more transparent and serves as a global guideline for Henkel employees engaging in the political environment.

Direct engagement in the political debate

The political involvement of Henkel is focused on the European Union. In addition, Henkel has allocated minor resources to the political debate on specific occasions and topics in other countries such as the US, or China. In this respect, we also comply with local legal provisions as well with our Henkel internal guideline.

We openly provide information about our fields of interest and the scope of our work through our entry in the joint Transparency Register of the European Parliament and the European Commission. See European Transparency Register. We also do this on a national level, e.g. through our entry in the lobby register of the German Bundestag and through the US Lobbying Disclosure Electronic Filing System.

Indirect engagement - poliIn this respect, we also comply with local legal provisions.tical involvement via our memberships in associations

Henkel is a member in various associations. They represent the interests of their members and therefore also Henkel’s interest in the political debate.

However, these memberships must not be misinterpreted as being focused on lobbyism and influencing the political environment because we also benefit from our memberships in associations in particular in the form of:

• information exchange with other associations and society organisations,
• stakeholder dialogue,
• cooperating on non-competitive technical developments and standards,
• supporting voluntary initiatives,
• education initiatives provided and promoted by associations,
• reputation building in our industries and beyond,
• general press and public relation activities and
• social partnerships with trade unions and collective bargaining agreements.

In addition to that, associations also play an important role in promoting sustainability and to further develop socially relevant solutions in our industry.

For example, “Chemie³” is a joint initiative of the German chemical industry association VCI, the Mining, Chemical and Energy Industrial Union ‏(IG BCE) and the German Federation of Chemical Employers’ Associations ‏(BAVC). Here, Industry, employers and trade union work jointly and systematically towards establishing sustainability in a whole sector.

In the German “Forum Waschen” by the association Industrieverband Körperpflege- und Waschmittel e.V. members discuss and work towards improving the positive impact of washing and cleaning products on sustainability and how to engage with the consumer.

The European Partnership for Alternative Approaches to Animal Testing ‏(EPAA) was founded in Brussels as a joint initiative between the European Commission, European trade associations and companies, including Henkel, from seven industry sectors.

Donations, whether direct or indirect, to political parties, politicians, or candidates for a political office as well as for political campaigns and referendums are not permitted. Any other commitment that could possibly be interpreted as a donation of this type must be subject to prior written approval by the Public Affairs & Governmental Relations department and authorized by the Compliance Committee or Henkel’s Chief Compliance Officer. No such authorization was requested or given in the last years.

It is recognized that various associations of which Henkel is a member may make donations under their own responsibility and in their own name according to relevant local laws and regulations governing contributions to individual candidates for office or to political parties.
Political activities by employees outside work are neither supported nor sponsored, directly or indirectly, by Henkel. In particular, Henkel does not allow an employee to take company time or resources to enable private political activity.

Henkel’s public policy principles are reviewed regularly by the Public Affairs & Governmental Relations department and the Compliance Committee of Henkel AG & Co. KGaA chaired by Henkel’s Chief Compliance Officer.