BMW 2012 Annual Report Download - page 167

167 STATEMENT ON CORPORATE GOVERNANCE
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
Trainings
Compliance
Governance and
Processes
Compliance
Contact and
SpeakUP Line
Compliance
Reporting
Compliance
Investigations
and Controls
Compliance Risk
Analysis
Annual
Report
Annual
Report
Annual
Compliance
Reporting Run
framework for dealing with gifts, hospitalities and other
benefits in compliance with the law and
defines appro-
priate value limits and approval procedures
for specified
actions.
Compliance measures are determined and prioritised
on the basis of a group-wide compliance risk assessment
covering 250 business units and functions worldwide
within the BMW Group. The assessment of compliance
risks is updated annually. Measures are realised with
the aid of a regionally structured compliance manage-
ment
team covering all parts of the BMW Group and
overseeing more than 200 Compliance Responsibles.
The various elements of the BMW Group Compliance
Organisation are shown in the diagram on the left and
are applicable for all BMW Group entities worldwide.
To the extent that additional compliance requirements
apply to individual countries or specific lines of busi-
ness, these are covered by supplementary compliance
measures.
The BMW Group Legal Compliance Code is the corner-
stone of the Group’s Compliance Organisation, spelling
out the Board of Management’s acknowledgement of
the fact that compliance is a joint responsibility (“Tone
from the Top”). This document, which explains the
significance of legal compliance and
provides an over-
view of the various areas relevant for the
BMW Group,
is available both as a printed brochure and to down-
load in German and English. In addition,
translations
into eleven other languages are available (French, Italian,
Japanese, Korean, Mandarin, Dutch, Polish, Portuguese,
Russian, Spanish and Thai).
Managers in particular bear a high degree of responsi-
bility and must set a good example in the process of
preventing infringements. Managers throughout the
BMW Group accept this principle by signing a written
declaration, in which they also undertake to inform
staff working for them of the content and significance
of the Legal Compliance Code and to make staff aware
of legal risks. Managers must, at regular intervals 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 16,500 managers and staff have received
training worldwide in essential compliance matters
since the introduction of the BMW Group Compliance
Organisation. The training material is available on an
internet-based training platform in German and English
and includes a final test. Successful participation in
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. Measures
to improve compliance systems are initiated on the ba-
sis of identified requirements.
A coordinated set of instruments and measures are em-
ployed to ensure that the BMW Group, its representative
bodies, its managers and its staff act in a lawful manner.
Particular emphasis has been placed on compliance
with antitrust legislation and the avoidance of corrup-
tion risks. Compliance measures are supplemented by
a whole range of internal policies, guidelines and
in-
structions, which in part reflect applicable legislation.
The BMW Group Policy “Corruption Prevention” de-
serves particular mention: this document sets out the