At GrandVision, we prioritize effective corporate governance and good company-wide business practices to maintain the value we create. We do this by complying with all regulations and engage with our employees on maintaining ethics and good conduct.
Ethics and good conduct
GrandVision’s Management Board is committed to providing a respectful working environment that creates a culture focused on long-term value creation across our business and affiliated enterprises. And we are proud of our core GrandVision values that support this commitment:
- Superior customer service and store performance
Maintaining focus on customers' needs and experiences is at the heart of all we do. This helps us continue creating value for the long term. And it is why we share a common understanding and guidelines to help reinforce and uphold our values, which are actively promoted by our Management and Supervisory Boards.
The GrandVision Code of Conduct and our Whistleblower Procedure support our employees, customers, suppliers and other stakeholders to detect and alert the organization if a deviation may occur. They are available in all local languages to make sure every employee has a thorough understanding of both policies.
Our Code of Conduct
Our Code of Conduct provides everyone with a clear and common understanding about our guidelines that reinforce and apply our core values. Each year, every employee in our stores and offices is required to take our Code of Conduct on our GV Academy e-learning platform. Training completion is also mandatory for new hires in their onboarding process. In 2020, 94% of our employees signed the Code of Conduct and we are improving the participation and completion rate to meet our target of 100% by 2025.
Our specialized Code of Conduct training course covers a variety of topics such as anti-corruption, bribery and data security. We also send all employees regular reminders and leadership communications about the topic.
You can find our Code of Conduct online at GrandVision.com.
Our Whistleblower Procedure
We encourage everyone to report any infringement of our Code of Conduct by following the GrandVision Whistleblower Procedure. It can be used by employees and contractors, customers, suppliers, business partners and the general public who can share evidence of infringements of our GrandVision Code of Conduct.
In 2020, our Compliance Officer received four Whistleblower reports, and they were followed up in line with our Whistleblower Procedure and duly reported to the Audit Committee.
You can find our Whistleblower Procedure online at GrandVision.com.
Antitrust and competition law compliance at GrandVision
GrandVision proactively ensures full compliance with all legal as well as good-governance principles. This includes all aspects of competition law and antitrust compliance, which is why we established a company-wide policy about antitrust and competition law compliance. The Management Board monitors its effectiveness and implements this policy. Every GrandVision employee receives mandatory annual awareness training on antitrust and competition law compliance.
You can find more details about our Competition Law and Antitrust Compliance Policy online at GrandVision.com.
Data protection and cybersecurity are part of our wider compliance program. They ensure compliance with all relevant local legislations, including the EU General Data Protection Regulation (GDPR). We take our responsibility seriously as an employer and health service provider to protect everyone from potential data security issues. And in 2020, we ensured our countries were GDPR-compliant, while further strengthening our governance structure.
Our data compliance program also helps create and maintain a culture of responsible and safe handling of personal, customer and employee data. It includes company-wide policies for personal data and information protection, data retention, IT end-users, data breach protocol and social media use. We have also set up a governance structure to make sure the cybersecurity compliance program is implemented in all GrandVision countries.
We appointed Data Protection Officers (DPOs) in every country who implement their respective policies. They report to our Group Data Protection Officer (Group DPO), our CFO. Each year, DPOs receive training through internal legal webinars and organize calls to facilitate the sharing of best practices. Our cybersecurity training is also mandatory and available on our employee GV Academy e-learning platform.
Data privacy and security
GrandVision obtains user data through lawful means, with explicit consent of the data subject as required. Our privacy policies adhere to local requirements and are available on all GrandVision retail brand websites.
We also standardized our cookie consent management for all globally-managed GrandVision retail brand websites using a third-party platform. Otherwise, cookies are managed on a local level using the same or similar management platform.
We also make sure that all emails and SMS messages sent to customers meet local, applicable policies on consent, whether they are governed by a purpose framework in GDPR markets or a communication channel framework, or both.
GrandVision also clearly defines any actions involving the collection, use, sharing and retention of website user data, including data transferred to third parties. These locally-owned policies as legal requirements are explicit and vary depending on the market. Each of our policies are publicly available in the data privacy section of each of the retail brands' websites.
Data privacy program
Keeping our data secure respects the privacy of our customers and employees. Our employees complete regular data privacy management lessons through a series of classes in our GV Academy training platform. These classes are mandatory and assigned to employees on an annual basis.
In addition, we offer clear and accessible mechanisms for data subjects to raise concerns about data privacy. Subject access request procedures can be accessed using the privacy policies on our retail brands' websites. These mandate certain protections to ensure third parties do not access any individual's data without their consent. And the ultimate responsibility to keep our data secure belongs to our Group DPO.
Protecting human rights across all organizations
We are dedicated to protecting human rights across our Product Value Chain; it is of utmost importance and aligns with our Ethics and Compliance programs. It also supports GrandVision's role as a responsible corporate citizen that contributes to the global human rights agenda. We establish policies, commitments and actions to safeguard human rights and manage the risk of noncompliance across our entire value chain. Our three most relevant areas are:
- Health and safety in production and manufacturing sites
Read the 'Strategic sourcing and product procurement' and 'Manufacturing and dedicated production lines' sections for more information.
- Labor rights across all operations
Read the 'Strategic sourcing and product procurement' and 'Our inclusive, diverse and ethical work environment' sections for more information.
- Data privacy and security
Read more in the 'Data compliance' paragraph in this section.
We also implemented an annual risk management cycle to identify key risks and developments, which are addressed in an ongoing process. During our annual budgeting process, country management and central functional teams also conduct risk assessments. They update key risks based on these assessments and an evaluation of the outcomes of the risks that have already been identified. Compliance risks are included in our assessment.
In 2020, we conducted a human rights due diligence exercise to identify and reassess salient human rights issues. These are people at risk of the most severe negative impact through our activities and business relationships. We analyzed our current policies, actions and commitments. Based on the outcome, we planned further steps and actions to tackle uncovered human rights risks and opportunities. We began remediating existing impacts and strengthening key elements of our company policies and processes, internal and external communications and stakeholder engagement.
Read more about our due diligence exercise in the 'Strategic sourcing and product procurement' section of this report.
Preventing bribery across all operations
GrandVision remains committed to preventing bribery across all of our operations. This is in line with our Ethics and Compliance programs, as well as being a responsible corporate citizen that contributes to the global human rights agenda.
To accomplish this, we established policies and commitments, and take actions to safeguard the respect of international anti-corruption and anti-bribery regulations.
Our Code of Conduct and Supplier Code of Conduct are published online at GrandVision.com. They describe our commitment and expectations to all employees, suppliers, contractors and competitors to refrain from offering, promising or giving any bribe to GrandVision employees, representatives or agents, whether directly or indirectly.
Our Supervisory Board oversees our overall performance, which includes policies such as our Code of Conduct and compliance with all applicable laws, including anti-corruption and anti-bribery regulations.
A dedicated compliance officer for our Whistleblower Policy ensures there is an effective reporting process in place if bribery may occur. Read more about 'Our Whistleblower Procedure' in this section.
Additionally, our employee and supplier Codes of Conduct include anti-bribery clauses. Please see the 'Strategic sourcing and product procurement' section for more information. This type of compliance risk is also included in our annual risk management cycle. For more information, read the 'Risk Management' section of this report in the 'Corporate Governance' chapter.
Our transparent and responsible tax strategy
For GrandVision, giving back to local economies is part of our role as a responsible corporate citizen. We embed tax implications into business processes when and where they originate. These even appear in the smallest shifts of business operations, from new products, services, digitalization or use of technology, which can have implications on our national and international tax positions. Our tax strategy is designed to navigate all these complexities and ensure we pay the right amount of tax to comply with all legislations.
We developed our tax strategy to align with our corporate values of integrity, trust and openness, and by including input from our wide variety of stakeholders. For instance, how we communicate about our tax affairs is further shaped by societal demands for transparency.
We are also progressing our tax strategy execution by developing a GrandVision Tax Network and further tax-enhancing company systems such as Enterprise Resource Planning and other technologies. GrandVision’s tax strategy is supported by a Tax Control Framework that allows us to effectively manage and control our tax positions.
We report on our tax risks and the tax strategy execution to the Audit Committee and the Supervisory Board. The committee is also the governance body responsible for approving GrandVision’s tax strategy. Any concerns of deviation from our tax strategy and principles can be reported through our Whistleblower Procedure. It is available online at GrandVision.com and can be used by employees and contractors, customers, suppliers, business partners and the general public.
While we do not actively engage with policy makers on this topic, being clear about our tax approach in our Annual Report provides an opportunity for us to underline the importance of a transparent tax policy at GrandVision.
The principles of our tax strategy are to:
- remain compliant at all times
- pay the correct amount of taxes across the value chain in the jurisdictions where we have a presence, and in accordance to where value is created
- reflect tax implications from business activity accurately in company records in real time at an entity level
Our tax policy
GrandVision’s tax strategy lets us pursue a transparent and responsible tax policy across all countries where we operate. It aligns the long-term interests of all of our stakeholders, shareholders as well as governments and communities. The policy also helps us realize our tax goals.
For more information, you can find our tax policy online at GrandVision.com.
Our tax transparency successes
At GrandVision we pursue a transparent and responsible tax strategy across all countries where we have a presence. This is an important part of our goal to be a responsible corporate citizen as well as our contribution to local economies.
Thanks to ongoing improvements to these responsible business practices, we improved our Tax Transparency score, and we successfully achieved a position in the top 10% of participants in the Dutch Annual Tax Transparency Benchmark by the VBDO (Association of Investors for Sustainable Development). The 2020 ranking included 77 Dutch listed companies.
Tax Control Framework
We ensure compliance with tax regulations through our GrandVision Tax Control Framework. It allows us to effectively monitor, control and manage Group-wide tax positions. It also creates awareness of possible tax exposures and helps us to report our tax positions, such as how to effectively comply with country-by-country obligations.
We also maintain strong working relations with tax authorities, which we manage through collaborative working arrangements (horizontal monitoring) in countries where this is possible. For example, we regularly collaborate with tax authorities in The Netherlands and the U.K. During 2020, our continuous engagement with tax authorities in various countries and consistent tax strategy compliance proved extremely valuable at the first outbreak of the COVID-19 pandemic.
Our framework enables our GrandVision global tax network to monitor and manage KPIs, including the timely and correct filing of quarterly VAT, Transfer Pricing obligations, country-by-country reporting regulations, effective tax rate (ETR) and our position in tax transparency benchmarks.
Our approach to tax also considers the work of our independent GrandVision Internal Audit function, which provides assurance and validation of the overall internal control frameworks, including the Tax Control Framework.
GrandVision's four tax pillars
Our contribution to socio-economic development
At GrandVision, the taxes we pay contribute to socio-economic development.
Taxes contributed by segment (x €1000)
Total Income Tax in EUR
of which income taxes segment G4
of which income taxes segment Other Europe
of which income taxes segment Americas & Asia
of which income taxes corporate
In 2020, GrandVision reported EUR 54 million in current and deferred income tax.
Our effective tax rate (ETR)
Effective tax rate (income tax as % of pre-tax results)
At GrandVision we use the ETR indicator to gain insight into our relative tax contributions, which divides income tax by total pre-tax results. In 2020, the ETR indicator was not comparable with previous years due to different weights of the profits and losses in the markets we operate in and the relevant tax rates due to the COVID-19 pandemic.
In addition to income tax, GrandVision generates funds for communities through other taxes and levies such as VAT, local employee taxes and social securities. Today, we believe it is more important than ever to be transparent about tax. We are further progressing on our transparent approach to tax and are currently taking steps to implement external reporting of GrandVision's total tax contributions per segment or on a country basis.
In 2020, GrandVision paid and has borne taxes exceeding the total of about EUR 627 million. The total includes corporate income taxes (about EUR 58 million), as well as taxes paid and borne on behalf of customers and employees such as VAT (about EUR 226 million), wage taxes (about EUR 154 million), and social security (about EUR 187 million). We are proud of this, and want our stakeholders to understand what we contribute through tax payments to the communities where we are based, and why we do this.
As an international company operating in more than 40 countries, GrandVision is exposed to a variety of tax risks and uncertain tax positions. An example of a tax risk to potentially materialize is, for instance, when the company has deviating viewpoints on the interpretation of law as opposed to tax authority.
We established our Tax Control Framework to maintain up-to-date insights into these tax risks.
In 2020, we continued to conduct the same review of tax risk management cycles as in previous years. GrandVision follows the 'more-likely-than' principle in regards to its tax risk appetite and for making decisions on tax matters.
This review covered the complete risk spectrum, which begins with risk identification and ultimately to uncertain tax positions in financial reporting, and reporting to the Supervisory Board and Audit Committee.
Due to the nature of our retail industry, core business and international profile, GrandVision may experience key tax risks and uncertainties in areas of indirect taxes, such as VAT and taxes and levies within the scope of cross-border transactions.