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Company Code
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Company Code
KPN is aware of its social and ethical responsibility and wants its company-wide modus operandi to conform with the law and with social and ethical standards.
On top of legislation, KPN sets itself additional standards to guarantee that we do business in an honest manner. These standards are described in the Company Code and the associated supporting codes. The Company Code describes KPN’s three core values: personal, simplicity and trust, and the meaning they have for stakeholders, such as customers, shareholders, employees, business associates, competitors, social organizations, international contacts and society in the broadest sense. All stakeholders can hold us accountable for these.
The supporting codes give concrete rules of conduct for specific areas. Some supporting codes, such as the supporting codes for competition and inside information, give further substance to statutory rules. Other supporting codes relate to topics such as integrity (e.g. business gifts and holding other positions), safety and (information) security.
To complement the rules in the supporting codes, KPN has introduced three general guidelines: the whistleblower procedure, the fraud policy and the integrity review protocol. KPN encourages its employees to report non-compliance or suspected non-compliance with the Company Code or supporting codes. The internal security department has an important role to play in this. It offers support via the Security, Compliance & Integrity Helpdesk, where employees can report non-compliance and can get information about the codes.
In 2012, the Helpdesk registered 292 reports* regarding a possible breach of the Company Code and 655 reports* relating to one of the supporting codes.
An investigation is carried out following each report. This investigation is generally carried out by a KPN Security Integrity Consultant or, in specific compliance cases, by a KPN Compliance Officer. The investigations often lead to sanctions, the level of the penalty being determined in part by the actual circumstances of the case. Possible measures are set out in the Company Code and supporting codes. Examples are a written warning, a reprimand, a suspension, withholding of salary and dismissal. In 2012, one of these measures was applied 136 times to KPN employees and 50 times to hired-in staff.
* Including reports about hired-in staff and subcontractors.
Political donations
KPN doesn’t make any political donations. No member of KPN Group is permitted to make gifts in cash or in any other form (including loans) to political parties or affiliated organizations. This policy applies in the United States of America as well and encompasses gifts to political parties, persons affiliated to political parties or trade associations that are active in politics or public administration. No charity donations are ever given to the aforementioned groups either.
Compliance Officer
Since 2005, KPN has a Group Compliance Officer to support management in compliance. The Group Compliance Officer has the responsibility to set up a compliance program, in particular for telecommunications and competition law and the Company Code. Business Compliance Officers have been appointed in the most relevant divisions of the company. The Group Compliance Officer periodically reports to the Board of Management and the Audit Committee of the Supervisory Board.
In 2003, KPN introduced a whistleblower procedure (available in English) which allows employees to report abuses.
- Company code (PDF, 1.1 MB)
- SpeakeUp Line (PDF, 165 KB)
- Protocol for Integrity investigations (PDF, 40 Kb)
