Sustainability strategy and fields of action

At Heidelberg Materials, sustainable management means pursuing revenue opportunities while never losing sight of the future health of our business. We always weigh the social and environmental impacts of our activities. Our sense of responsibility to people and the environment is not just motivated by ethical concerns, however – it is also good for our bottom line.

The Sustainability Commitments 2030 set forth the most important fields of activity of our company. They define the key topics and core principles of the future sustainability strategy at Heidelberg Materials.


In all countries in which we are active, we comply with the applicable laws and regulations as the legal basis of our business activity. Heidelberg Materials' globalization process – characterized by rapid growth and geographical expansion – has required the integration of many different cultures.  Being successful as one Group requires the sharing of common values. In our Corporate Mission, the company’s culture and our fundamental values are laid down in general.

Our company’s ambition for operational excellence and a prime position among the best in our industry needs a solid foundation of commitment to lawful and ethical conduct. Therefore, the Code of Business Conduct describes our values of high ethical and legal standards for all our business activities from strategic planning to day-to-day procedures in all countries in which we operate.

Consequently, ethical and compliant behaviour of our employees as stipulated in our Code of Business Conduct is assessed and documented as part of our annual performance review system.

Moreover, Heidelberg Materials commits to its responsibility to respect human rights.

To further underline our commitment to compliance and social responsibility, we have taken specific measures that go beyond compliance with laws and internal guidelines. We create jobs at our locations – both directly at our production sites and indirectly in upstream and downstream business sectors. We promote economic development with wages, investment, procurement, and taxes, particularly in economically weak regions, and assume our social responsibility. Since 2022, our financial instruments have also been linked to sustainability aspects.

A man with a helmet is looking at a cement plant

Our Sustainability Commitments 2030 apply Group-wide to more than 3,000 locations in over 50 countries.

Responsibility and organization

The compliance programme, which is firmly anchored in the Group-wide management and supervisory structures, is part of our management culture. It comprises the entire compliance organization within the Group, the set-up of guidelines, and the verification of compliance with these guidelines. The compliance management addresses all compliance topics that Heidelberg Materials has identified as relevant in the compliance risk assessment. These include, in particular, competition law, anti-corruption, and human rights.

The compliance organization is under the authority of the Chairman of the Managing Board, to whom the Director Group Legal & Compliance reports directly. Each country has its own compliance officer with a direct reporting line to the country manager. However, responsibility for ensuring that employees’ conduct complies with the law and regulations lies with all managers and, of course, with the employees themselves.

Compliance processes

We have implemented an integrated compliance programme across the Group to achieve conduct that is compliant both with the law and with regulations. A central element of this programme is the self-commitment made by the Group management not to tolerate violations of applicable laws and to impose sanctions. The programme also includes internal policies and measures that express the legal provisions in concrete terms. In addition to regular communication of these policies, there are compliance letters to the management and the entire workforce, such as the annual letter from the Chairman of the Managing Board and ad hoc circulars on current issues, to raise awareness of the topic of compliance.

We offer the internet- and telephone-based reporting system “SpeakUp” and employee training that makes use of modern media, such as electronic learning modules. The range of electronic courses, which must be completed by specified groups of employees, covers topics such as the Code of Business Conduct (e.g. discrimination and harassment at the workplace), competition legislation, and the prevention of corruption.

The entire compliance programme is reviewed on an ongoing basis for any necessary adjustments with regard to current legal and social developments, and it is improved and accordingly. Violations of applicable laws and internal policies are sanctioned. In addition, suitable corrective and preventive measures are taken to help prevent similar incidents in the future. 

Group-wide implementation of the compliance programme is monitored by regular and special audits by Group Internal Audit as well as via special half-yearly compliance reporting by the Director Group Legal & Compliance to the Managing Board and the Audit Committee of the Supervisory Board. The latter monitors the effectiveness of the compliance programme and verifies in particular whether it adequately satisfies the legal requirements and recognised compliance standards. An additional quarterly report regularly informs the Managing Board members with regional responsibility about the most important compliance incidents in their Group areas.

Every two years, we conduct a comprehensive analysis to assess and prevent corruption risks and possible conflicts of interest. A rolling approach ensures that different countries are analysed each year as part of this cycle. First, the potential risks within a country organization are assessed. Then, the measures already in place to limit these risks are evaluated to assess the net risk, and finally, we examine whether further measures are needed. On the basis of this assessment, an action plan is drawn up for each country, and its implementation is monitored by the Group Legal & Compliance department.

In the area of competition legislation, we have a comprehensive cartel reporting system on cartel investigation proceedings. An annual competition legislation update takes place at the level of the Managing Board and of the employees who report directly to the members of the Managing Board with responsibility for sales. Furthermore, annual qualitative assessments of the cartel risks take place in the countries. A regular external audit of the Antitrust Compliance Programme by a specialist law firm is conducted every three years.

Compliance Risk Assessments

Heidelberg Materials' Compliance Management System includes as essential component various risk assessments. On the one hand, compliance risks are regularly evaluated for likelihood and impact on Heidelberg Materials Group in order to review if the Group’s Compliance Management System covers all relevant compliance topics and sets the right focus of compliance work. On the other hand, risk assessments are performed on specific compliance themes like competition law, corruption and human rights and are regularly updated. These specific compliance risk assessments are conducted on the level of the country organizations and monitored by Group Compliance. This is in line with the organizational setup of Heidelberg Materials Group and reflects the different legal requirement in each jurisdiction.
Within each country organization, specifics of different operating lines and potential regional differences need to be taken into account. 

Methodology Corruption Risk Assessments

Our risk assessment methodology starts with defining risk types which the company may be exposed to. For corruption these include active and passive corruption, corruption involving public officials, indirect bribery and conflict of interest. These risks are analysed from different functional views including operations, procurement, sales, human resources and investment project teams. Risks and functional views are defined by Group Compliance experts to have the same comparable structures for all countries.

After establishing the above explained structure the assessment starts with collecting information that forms the basis for assumptions that determine the gross risk. The local compliance team reviews the legal environment of the respective country, the enforcement of law by authorities and external evaluations such as the Corruption Perception Index of Transparency International. Further, the occurrence of historical statistics of compliance violations in the local organization is analysed. Besides these rather objective criteria the compliance team collects information from their expert colleagues from different departments and operating lines how they perceive the specific compliance risks in the building materials industry based on their experience, observations and real-life events. With this input the gross risk is assessed in a qualitative way as high, medium or low.

The next step is a review of the already existing risk mitigation measures in the organization. Mitigation measures may include policies, trainings, process controls etc. Taking these measures into account results in the net risk that the organization is effectively exposed to. Based on this the risk assessment continues with setting up an action plan that defines single action items including responsibility and deadline targeting further net risk reduction.

The entire risk assessment including action plan is reviewed by Group Compliance experts and finally must be approved by the responsible Country General Manager. The action plan is followed up by the compliance staff and subject to regular top management review. The entire assessment process is scheduled to be updated after a cycle of about two years.

Compliance incident performance indicators

As part of Heidelberg Materials Group’s workflow processes for compliance incident reporting and case management all reported incidents are classified in categories including employee relations, harassment, discrimination, corruption, conflict of interest, theft, fraud, etc.

In 2023, a total of 283 incidents were reported in our case management system and investigated under the supervision of compliance employees in the country organization or by the Group Compliance & Data Protection department.

Incidents reported via case management system
Infographic showing that 78% of incidents have been reported via SpeakUp and 22% via emails/letters

Most of the reports concerned employee relations. Other reports related to health and safety; fraud, theft or embezzlement; and corruption or conflicts of interest. Other categories of cases accounted for lower percentages of the total.

Donut chart showing the incident categories in %: 39 employee relations, 10 corruption or conflict of interest, 8 health and safety, 8 fraud, theft or embezzlement, 5 discrimination or harassment, 30 other

Of the 283 incidents reported, around half proved to be unfounded, while for 14%, no final result could be determined by the editorial deadline. In the case of 36% of the incidents, the investigations revealed that they were at least partially substantiated. None of the substantiated incident reports had a material impact on the consolidated financial statements.

In the case of substantiated incidents, measures were generally taken, ranging from root cause analysis, changes to policies and processes, and communication and training through to disciplinary action (such as a written warning or dismissal). In 45% of the substantiated incidents, sanctions were imposed, and for 69% of these incidents, preventive measures were implemented.

The country organizations are required to report key figures, such as the number of compliance incidents reported through the case management system that involve suspected human rights violations. Apart from incidents relating to health and occupational safety, nine incidents of discrimination were reported in relation to human rights issues, one of which is still under investigation while the others have not been confirmed, and four incidents of harassment, with three justified complaints. The investigation of the fourth case is still ongoing. There were also ten complaints about suppliers, of which two were confirmed and three are still under investigation. Of the ten cases, nine were related to possible unfair working conditions, and one concerned occupational safety. 

Looking into further details for incident types of interest for sustainability ratings we received reports for 22 cases of the category corruption or bribery of which 13 turned out to be unsubstantiated. We registered seven cases of conflict of interest of which four were unsubstantiated. No reports were noticed for the categories money laundering or insider trading. The protection and security of personal data is of great importance to us. Our statistics show no cases where sensitive customer data was affected.

Compliance Reporting System

In order to support our commitment to compliance with applicable laws and international ethical standards we offer our employees as well as external persons the possibility to report concerns regarding any kind of unlawful behaviour or violation of internationally acknowledged conventions via our compliance hotline SpeakUp.

Examples of incident types to be reported:

  • Corruption, bribery, kickbacks
  • Child or forced labour
  • Discrimination
  • Data breach/breach of privacy
  • Environmental issues/sustainability
  • Health and safety issues etc.

The description of the incident should be as precise and straightforward as possible.


If wished so, the report can be made anonymously. The submitted incident reports are handled confidentially and in a way which avoids any retaliation towards the reporting person.

Access to SpeakUp

The SpeakUp internet portal can be accessed by clicking

The portal provides a means for communication between the reporting and the investigating person with the possibility to guarantee full anonymity of the reporting person if required.

SpeakUp Phone Numbers
Country Phone number Phone instructions
Albania 0035545301801 Number: +355 4 530 1801 Call charged at local rate
Australia 0061282846262 Number: +61 2 8284 6262 Call charged at local rate
Bangladesh 008809610998462 Freephone: +880 (0) 9610 998462
Belgium 080089326 Freephone: 0800 89 326
Benin 0022920900380 Number: +229 20 90 0380 Call charged at local rate
Bosnia and Herzegovina 0038770330093 Number: +387 70 330 093 Call charged at local rate
Brunei Darussalam 8014657 Freephone: 801 4657
Bulgaria 8002100645 Freephone: 800 210 0645
Burkina Faso 0022625300982 Number: +226 25 30 09 82 Call charged at local rate
Canada 1-888-898-3316 Freephone: 1 888 898 3316
China 108001523042 Freephone (via China Telecom): 1080 0152 3042
China 108008522221 Freephone (Via China United Network): 1080 0852 2221
China 4001201842 Country wide number with no supplier restriction: 400 120 1842 Call charged at local rate.
Croatia 08007745 Freephone: 0800 7745
Czechia 800050833 Freephone: 800 050 833
Denmark 004543310961 Number: +45 43 31 09 61 Call charged at local rate
Egypt 08000000083 Freephone: 0800 000 0083
Estonia 003726093008 Number: +372 609 3008 Call charged at local rate
Finland 0800392912 Freephone: 0800 392 912 
France 0805543753 Freephone: 080 554 3753
Germany 08001818952 Freephone: 0800 1818 952
Ghana 00233596993553 Number: +233 59 699 3553 Call charged at local rate
Greece 0080044145924 Freephone: 0080 0441 45924 The number will not work when called from a mobile
Hong Kong 0085230194193 Number: +852 3019 4193 Call charged at local rate
Hungary 0680984589 Freephone: 06 809 845 89
Iceland 003544150349 Number: +354 415 0349 Call charged at local rate
India 0008000503159 Freephone: 0008 0005 03159
Indonesia 00622180630074 Number: +62 21 8063 0074 Call charged at local rate
Israel 0097233741225 Number: +972 3374 1225 Call charged at local rate
Italy 800147694 Freephone: 800 147 694
Kazakhstan 007877273574582 Number: (+7) 877 2735 74582 Call charged at local rate; No mobile access
Latvia 80005929 Freephone: 800 05929
Lithuania 880030366 Freephone: 8800 30366
Luxembourg 003523420808982 Number: +352 342 080 8982 Call charged at local rate
Malaysia 0060377243136 Number: +60 3 7724 3136 Call charged at local rate
Morocco 00212530144108 Number: +212 5 30 14 41 08 Call charged at local rate
Netherlands 0031107007503 Number: +31 10 700 75 03 Call charged at local rate
Norway 004724140601 Number: +47 24 14 06 01 Call charged at local rate
Poland 00800012953 Freephone: 0080 0012 953
Romania 0800400653 Freephone: 0800 400 653
Singapore 006564037051 Number: +65 6403 7051 Call charged at local rate
Slovakia 0800113418 Freephone: 0800 113 418
South Africa 0027214277937 Number: +27 (21) 427 7937 Call charged at local rate
Spain 0034900031156 Number: +34 900 031 156 Call charged at local rate
Sweden 0201604703 Freephone: 020 160 4703
Tanzania, the United Republic of 0800111020 Freephone: 0800 11 1020
Thailand 006628449693 Number: +66 2 844 9693 Call charged at local rate
Turkey 00800448828602 Freephone: 0080 04488 28602
United Arab Emirates 80004440408 Freephone: 800 0444 0408
United Kingdom 08000224118 Freephone: 080 0022 4118
United States of America 1-888-898-3316 Freephone: 1 888 898 3316



Roland Sterr
Director Group Legal & Compliance
Tel.  +49 6221 481-13361

Corporate Governance

The management and supervisory structures at Heidelberg Materials comply with the regulations under the German Stock Company Act, the company's Articles of Association, the procedural rules of the Managing Board and Supervisory Board, and – with a few exceptions (see statement of compliance) – the German Corporate Governance Code (GCGC).

Further information on Corporate Governance

Taking Stakeholder Expectations into Account

We know that we can only be successful as a company if we maintain cordial and cooperative relationships with the various stakeholders in society who are affected by our business operations on the local, national, and international levels. That’s why we place great value on open communication that directly addresses problems, as well as on maintaining a constructive dialogue with all the relevant stakeholder groups. In line with these values Heidelberg Materials will prepare and publish a Public Country-by-Country Reporting for FY 2025 as required by German legislation and EU directive (filing date foreseen by legislation is end of FY 2026). The Public Country-by-country reporting will include information on selected key business, financial and tax information for jurisdictions the Group is active in.

The expectations of our external and internal stakeholders play a key role in the development of our sustainability strategy. We identify these expectations systematically through a materiality analysis and incorporate them into our plans for the further development of our sustainability strategy.

Worldwide Heidelberg Materials is a member of cross-sector as well as industry-specific associations that represent their members’ interests through a continual dialogue with governments, businesses, and the general public. The associated cooperative partnerships focus on challenges that are specific to individual countries and to the cement industry with regard to raw materials security, environmental protection, energy conservation, health and occupational safety, and compliance.