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.