BMW 2010 Annual Report Download - page 166

164
140 STATEMENT ON
CORPORATE GOVERNANCE
(Part of Management Report)
140 Information on the Company’s
Governing Constitution
142 Declaration of the Board of
Management and of the
Supervisory
Board pursuant to
§ 161 AktG
143 Members of the Board of
Management
144 Members of the Supervisory Board
147 Information on Work Procedures
of the Management Board and
Supervisory Board
154 Compensation Report
162 Information on Corporate
Governance Practices
163 Compliance in the BMW Group
Resources. It manages and monitors activities neces-
sary
to ensure compliance with the law (Legal Com-
pliance). These activities include training, information
and communication measures, following up cases of
non-compliance and implementing compliance re-
quirements.
The Compliance Committee reports regularly to the
Board of Management on all compliance-related issues,
including the progress made in setting up and develop-
ing the Compliance Organisation, details of investiga-
tions performed, known infringements of the law, sanc-
tions imposed and corrective /preventative measures
implemented. The BMW Group Compliance Committee
operates through the Compliance Committee Office,
which is allocated in organisational terms to the Chair-
man of the Board of Management.
The Chairman of the Compliance Committee keeps the
Audit Committee (i.e. a part of the Supervisory Board)
informed on the current status of compliance activities
within the BMW Group, both on a regular and a case-by-
case basis as the need arises.
The implementation of the BMW Group Compliance
Organisation began in 2008 and was completed in
November
2009. The BMW Group Compliance Organi-
sation comprises the entire set of measures taken to
ensure that the BMW Group, its representative bodies,
its managers and its staff act in a lawful manner. It is
supplemented by a whole range of internal principles,
guidelines and instructions, which in part reflect the
applicable law.
The various elements of the BMW Group Compliance Or-
ganisation are shown in the diagram on the right and are
applicable for all BMW Group entities worldwide. Tothe
extent that additional compliance requirements apply to
individual countries or specific lines of business, these are
covered by supplementary compliance measures.
The BMW Group Legal Compliance Code is at the core
ofthe Compliance Organisation. This document explains
the significance of legal compliance and provides an over-
view of the various areas relevant for the BMW Group.
The Legal Compliance Code is available both as a printed
brochure and to download in German and English. In
addition, translations into nine other languages (French,
Spanish, Italian, Portuguese, Russian, Mandarin, Japa-
nese, Thai and Korean) have been available since 2009.
Managers in particular bear a high degree of responsi-
bility
and must set a good example in the process of
preventing infringements. All managers are required to
inform the staff working for them of the content and
significance of the Legal Compliance Code and to make
them aware of legal risks. Managers must, at regular in-
tervals and on their own initiative, check compliance
with the law and communicate regularly with staff on
this issue. Any indication of non-compliance with the
law must be rigorously investigated.
More than 11,000 managers and staff have received train-
ing worldwide in essential compliance matters since
theintroduction of the BMW Group Compliance Organi-
sation. The training material is available on an internet-
based training platform in German and English and in-
cludes a final test. Successful participation in the training
programme, which is documented by a certificate, is
mandatory for all BMW Group managers. Appropriate
processes are in place to ensure that all newly recruited
managers and promoted staff undergo compliance
training.
In addition to this basic training, in-depth training is
alsoprovided to certain groups of staff on specific com-
Compliance Committee
Code of
conduct
Training
Implementation with
appropriate personnel
Compliance
contact
Reporting
Identification and
monitoring
Communi-
cation
Compliance
Committee Office
Compliance
Committee
BMW AG Board of Management
BMW AG Supervisory Board
Annual Status Report
Annual Status Report