BMW 2013 Annual Report Download - page 181

181 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
The Chairman of the BMW Group Compliance Com-
mittee keeps the Audit Committee 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 the Compliance Management System are in-
itiated on the basis of identified requirements.
A coordinated set of instruments and measures are
employed
to ensure that the BMW Group, its repre-
sentative bodies, its managers and its staff act in a law-
ful manner. Particular emphasis has been placed on
compliance with antitrust legislation and the avoidance
of corruption risks. Compliance measures are supple-
mented by a whole range of internal policies, guidelines
and instructions, which in part reflect applicable legisla-
tion. The BMW Group Policy “Corruption Prevention”
deserves particular mention: this document deals with
lawful handling of gifts and benefits and defines appro-
priate assessment criteria and approval procedures for
specified actions.
Compliance measures are determined and prioritised
on the basis of a group-wide compliance risk assessment
covering all 276 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 170 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
information and communication measures, com-
pliance controls and following up cases of non-com-
pliance.
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 comprises ten employees and
is allocated in organisational terms to the Chairman of
the Board of Management.