BMW 2011 Annual Report Download - page 175

175 STATEMENT ON CORPORATE GOVERNANCE
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Compliance in the BMW Group
Responsible and lawful conduct is fundamental to the
success of the BMW Group. This approach is an integral
part of our corporate culture and is the reason why cus-
tomers,
shareholders, business partners and the general
public place their trust in us. The Board of Management
and the employees of the BMW Group are obliged to
act responsibly and in compliance with applicable laws
and regulations.
This principle has been embedded in BMW’s internal
rules of conduct for many years. In order to ensure to
protect itself systematically against compliance-related
and reputational risks, the Board of Management cre-
ated a Compliance Committee back in 2007, mandated
to establish a worldwide Compliance Organisation
throughout the BMW Group.
The BMW Group Compliance Committee comprises
the heads of the following departments: Legal Affairs,
Corporate and Governmental Affairs, Corporate Audit,
Group Reporting, Organisational Development and
Corporate Human Resources. It manages and monitors
activities necessary to avoid non-compliance with the
law (Legal Compliance). These activities include training,
information and communication measures, following
up cases of non-compliance and implementing compli-
ance requirements.
The BMW Group Compliance Committee reports regu-
larly to the Board of Management on all compliance-re-
lated issues, including the progress made in developing
the BMW Group Compliance Organisation, details of
investigations performed, known infringements of the
law, sanctions imposed and corrective /preventative
measures implemented. The decisions taken by the BMW
Group Compliance Committee are drafted in concept,
and implemented operationally, by the BMW Group
Compliance Committee Office. The BMW Group Com-
pliance Committee Office is allocated in organisational
terms to the Chairman of the Board of Management.
The Chairman of the BMW Group Compliance Com-
mittee 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 Board of Management keeps track of and analyses
compliance-related developments and trends on the
basis of the Group’s compliance reporting and input
from the BMW Group Compliance Committee. In order
to augment the effectiveness of the BMW Group
Com-
pliance Organisation, the Board of Management decided
in autumn 2010 to supplement existing compliance
requirements in the BMW Group with a range of addi-
tional measures. In 2011, the emphasis of activities
undertaken has been the assessment of risks group-
wide,
additional measures to avoid cases of corruption
and the introduction of regionally structured compliance
management.
The BMW Group Compliance Organisation 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 policies, guidelines and instruc-
tions, which in part reflect applicable legislation.
The various elements of the BMW Group Compliance
Organisation are shown in the diagram stated below and
are applicable for all BMW Group entities worldwide.
To the extent that additional compliance requirements
BMW Group Compliance Organisation
Legal Compliance
Code and Regulations
Compliance
Instruments and
Measures of
the BMW Group
Board of Management BMW AG
BMW Group Compliance Committee
BMW Group Compliance Committee Office
Compliance Operations Network
of all BMW Group
Compliance Responsibles
Supervisory Board BMW AG
Compliance
Communication
Compliance
Training
Compliance
Governance &
Processes
Compliance
Contact &
SpeakUP Line
Compliance
Reporting
Compliance
Investigations &
Controls
Compliance Risk
Analysis
Annual
Report
Annual
Report
Annual
Compliance
Reporting Run