BMW 2011 Annual Report Download - page 177

177 STATEMENT ON CORPORATE GOVERNANCE
access to insider information in accordance with exist-
ing rules have been, and continue to be, included in a
corresponding, regularly updated list and informed of
the duties arising from insider rules.
(BMW Group Compliance Spot Checks) specifically
designed to identify potential risks of corruption have
been carried out since the beginning of 2011.
Compliance control activities are managed by the
BMW
Group Panel Compliance Controls on the basis
of a group-wide assessment of compliance risks.
It is essential that employees are aware of and comply
with applicable legal regulations. The BMW Group does
not tolerate violations of law by its employees. Culpable
violations of law result in employment-contract sanc-
tions and may involve personal liability consequences
for the employee involved.
In order to avoid this, the BMW Group’s employees are
kept fully informed of the instruments and measures
used by the Compliance Organisation via various
inter-
nal channels. The central means of communication is the
Compliance website within the BMW Group’s intranet
where employees can find compliance-related informa-
tion and also have access to training materials in both
German and English. Employees can use the website to
access frequently asked questions (and answers) on
compliance-related issues. The website contains a special
service area where various practical tools and aids are
made available to employees, which help them deal with
typical compliance-related matters. BMW Group
em-
ployees also have access on the website to an electron-
ically
supported approval process for invitations in
connection with business partners.
Compliance is also an important factor in terms of safe-
guarding the future of the BMW Group’s workforce.
With this in mind, the Board of Management and the
national and international employee representative
bodies of the BMW Group signed a set of Joint Principles
for Lawful Conduct in 2009. In doing so, all parties in-
volved gave a commitment to the principles contained
in the BMW Group Legal Compliance Code and to
closely cooperating in all matters relating to compliance.
In the interest of investor protection and in order to
ensure that the BMW Group complies with regulations
relating to potential insider information, as early as
1994 the Board of Management appointed an Ad hoc
Committee consisting of representatives of various
specialist departments whose members examine the
relevance of issues for ad hoc disclosure purposes. All
persons working on behalf of the enterprise who have