Annual report 2022 - Report - Page 14
Compliance
14 Annual Report 2022
Ethics
Horten has a general goal that its
employees should have a high ethical
standard, in carrying out their work
duties and in their general conduct.
Horten’s ethical guidelines reflect the
ethical rules that apply in the respective
countries and the CCBE (Council of Bars
and Law Societies of Europe) Code of
Conduct. We require all employees to
actively comply with the letter and spirit
of these rules, and have a formulated
policy on ethical guidelines at Horten.
Against this background, we believe it is
not necessary to formulate separate
policies on human rights. Given our
geographic location and business model,
we do not foresee any special risks
related to human rights.
Money laundering
Horten is covered by the rules on
combating money laundering and
terrorist financing. We continually strive
to reduce the risk that Horten
inadvertently contributes to money
laundering or terrorist financing. In our
policy, procedures and monitoring for
combating money laundering and
terrorist financing, we have a strong
focus on anchoring in management,
training our employees, comprehensible
internal guidelines with a clear division of
responsibilities and roles, document
templates and monitoring compliance
with our internal processes.
At Horten, all relevant employees
undergo mandatory anti-money
laundering training during onboarding.
We also conduct thorough background
checks on our clients and screen our
employees during recruitment. In 2022,
we have regularly obtained criminal
records for our employees. We expect to
continue this work in the future.
Whistleblower scheme
Horten has an online whistleblower
scheme whereby employees can
anonymously report any potential or
actual violations of anti-money
laundering legislation by the company.
Horten’s whistleblower scheme aims to
provide a confidential and independent
channel for reporting matters that cannot
be handled directly through the regular
channels. Reports to Horten’s
whistleblower scheme are handled
confidentially and securely by our
whistleblower team.
All internal and external persons who
have a work-related connection to the
matter in question may report to Horten’s
whistleblower scheme.