Annual Report 2022

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Anti-corruption and bribery matters

Avoidance of corruption and anti-competitive behavior

Ethically correct and lawful conduct includes the prevention of corruption and anti-competitive behavior. HUGO BOSS expects all employees to act lawfully in day-to-day business operations. For HUGO BOSS, corporate compliance is a key responsibility of the Managing Board and includes measures to ensure adherence to legal and official regulations, as well as internal guidelines and codes. These include anti-corruption, anti-bribery, and antitrust regulations.

The central Compliance Department at HUGO BOSS reports to the Chief Compliance Officer, who reports directly to the Chief Financial Officer (CFO)/Chief Operations Officer (COO). The department is primarily responsible for supporting the monitoring of effective compliance management. Together with the compliance officers in the Group companies, the department ensures the implementation and continuous further development of the compliance program. The Audit Committee of the Supervisory Board is kept regularly informed about the activities of the Compliance department.


Compliance management at HUGO BOSS aims at Group-wide legally compliant behavior. The aim is to prevent legal violations such as corruption, bribery, and antitrust violations, which may result not only in reputational and financial risk but may also lead to personal consequences under criminal and labor law.


Our employees are required to comply with the Group-wide Code of Conduct and supplementary specific compliance rules, such as an antitrust law and a capital market guideline. Both the publicly accessible Code of Conduct and the internal guidelines are regularly reviewed and their content updated, particularly with regard to changes in legal requirements. In 2022, the Code of Conduct was further developed, among others, in the area of social standards and human rights, and supplemented by the inclusion of the corporate values derived from our “CLAIM 5” strategy. We are currently revising our internal sourcing policy with the aim of completion in the first half of 2023. In addition, Group companies are subject to regular risk analyses and detailed audits where applicable. Any infringements are reported to the Managing Board and the Supervisory Board.

A Group-wide e‑learning program to be regularly completed by all employees with computer access is designed to raise awareness of compliance rules. Against the backdrop of increasing regulatory requirements, the program is to be further developed in 2023. Employees in positions where compliance is of particular relevance are trained by means of both online and physical trainings on specific topics that are of relevance to them, such as antitrust law. HUGO BOSS does not tolerate any deliberate misconduct or serious compliance infringements.

At HUGO BOSS, employees, suppliers, and trading partners can notify an external ombudsman in confidence if there are any indications of fraud, infringements of antitrust law, or other compliance violations. If desired, it is also possible to do this anonymously. The ombudsman’s contact data can be found on our corporate website and on the Company-wide intranet. In addition, a whistleblowing portal is available to the aforementioned stakeholder groups, which offers the opportunity to report misconduct and criminal offenses in the Company confidentially and anonymously.

Performance indicators

In 2020, the Danish Competition Authority identified an antitrust violation concerning an alleged disclosure of information with regard to prices and quantities of HUGO BOSS to local trading partners. However, HUGO BOSS took a contrary view on this and accordingly filed a complaint with the relevant appeals board, which was rejected by three votes to two in court in mid-2021. In order to continue to safeguard all its rights, and in light of the close decision of the appeals board, HUGO BOSS is currently asserting its rights at the Danish Maritime and Commercial High Court. The written preliminary proceedings have started in 2022. A final decision in this case is not expected before the end of 2023. No fine has been imposed so far. Beyond this, in 2022, no further violations in the sense of legal violations due to corruption, bribery, or antitrust cases established by authorities or courts were identified in the Company.