PUMA is a sports brand that conducts business worldwide. As such, we are well aware that we potentially face the risk of non-compliance with laws and regulations by PUMA employees or business partners in all our business functions and all countries where we conduct business. Those risks include the risk of corruption, which can vary from “low” to “high” depending on the country.

PUMA is a member of the UN Global Compact and commits to its principles, among them the 10th principle: “Businesses should work against corruption in all its forms, including extortion and bribery.” The fight against corruption therefore is highlighted as a major goal of our Compliance Program, and also a regular topic during dialogues with NGOs, e.g. the stakeholder dialogue meeting Talks at Banz.

At PUMA, compliance-related topics are primarily addressed at the group-level in the PUMA SE Risk & Compliance Committee, which consists of a defined group of senior management members, including Managing Directors of PUMA SE.

Each planned Compliance (including anti-corruption) initiative at PUMA is presented to and agreed on by the main governance bodies (i.e. Managing Directors of PUMA SE, Audit Committee, Administrative Board).

Apart from the complaint channel for supply chain workers that PUMA operates, PUMA also continues to keep a global, third-party-controlled whistle blowing hotline, as reported in previous years.

The major areas for PUMA regarding business ethics and compliance as well as expected behavior are summarized in the PUMA Code of Ethics. PUMA CEO Bjørn Gulden communicated the current version of the PUMA Code of Ethics – including PUMA’s policy regarding Gifts & Hospitality – to all PUMA employees worldwide. The document is available for download at PUMA’s group-wide Intranet. The PUMA Code of Ethics is also available online at http://about.puma.com/en/sustainability/standards/coe.

Updates of the PUMA Code of Ethics are carried out on a regular basis.

Accompanying the PUMA Code of Ethics, PUMA has – in cooperation with its major shareholder Kering – introduced a group-wide ethics e-learning program with the goal to increase awareness among employees for business ethics including corruption. This program was launched in 2014 and continued in 2015 with its 2nd edition consisting of modules covering the following topics: behavior at the work place, respecting human rights, respect for the environment and anti-bribery.

The e-learning edition of 2015 was promoted
by PUMA’s CEO, as the sponsor of the campaign, to all PUMA employees. All PUMA employees worldwide were called to take part in the ethics e-learning program; as per July 2015, 55% of PUMA employees had completed it.

Going forward, PUMA will continue to focus on increasing the amount of employees covered by the online training program as well as trained face-to-face. In 2015, Kering has established a new Compliance Program, which PUMA has joined. The Compliance Program will strongly focus on antitrust and anti-corruption.

We welcome your comments on our PUMA sustainability strategy and its implementation as well as any topics covered in the sustainability chapter of this report at sustainability@puma.com.

“To take actions against corruption is often the basis to push through objectives in other sustainability areas.”

Sylvia Schenk, Chair of Working Group Sport,
Transparency Deutschland