BMW 2013 Annual Report Download - page 182

182
166 STATEMENT ON
CORPORATE GOVERNANCE
(Part of Management Report)
166 Information on the Company’s
Governing Constitution
167 Declaration of the Board of
Management and of the
Supervisory
Board pursuant to
§ 161 AktG
168 Members of the Board of
Management
169
Members of the Supervisory
Board
172 Work Procedures of the
Board of Management
174 Work Procedures of the
Supervisory Board
179 Information on Corporate
Governance Practices
180 Compliance in the BMW Group
185 Compensation Report
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 download
in German and English. In addition, translations into
eleven other languages are available (Dutch, French,
Italian, Japanese, Korean, Mandarin, 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 20,300 managers and staff worldwide have
received training in compliance basics since the intro-
duction 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 training
programme, which is documented by a certificate, is
mandatory for all BMW Group managers. Appro-
priate
processes are in place to ensure that all newly
recruited managers and promoted staff undergo com-
pliance training. In this way, the BMW Group ensures
full training coverage for its managers in com pliance
matters.
In addition to this basic training, in-depth training is
also provided to certain groups of staff on specific
compliance issues. This includes a training programme
(Compliance Advanced – Competition and Antitrust
Law), which was expanded in 2013 and is aimed at
em-
ployees who come into contact with antitrust-related
issues as a result of their functions within sales, pur-
chasing, production or development. Anti-trust law
training has also been mandatory for all BMW AG em-
ployees delegated to work abroad since the start of
2013. A total of 2,300 employees have already completed
this training. The relevant divisions also introduced
further measures and processes in 2013 to make em-
ployees who participate in meetings with competitors
sufficiently aware of anti-trust risks.
Additional Compliance Market Coachings have also
been implemented in local markets since late 2012.
These multi-day classroom seminars strengthen the
understanding of compliance in selected units and
enhance cooperation between the central BMW Group
Compliance Committee Office and decentralised
compliance offices. In 2013, market coaching was per-
formed for Financial Services and national sales
companies in Argentina, Brazil, China, Mexico and
Singapore.
In order to avoid legal risks, all members of staff are
expected to discuss compliance matters with their
managers
and with the relevant departments within
the BMW Group, in particular Legal Affairs, Corporate
Audit and Corporate Security. The BMW Group Com-
pliance
Contact serves as a further point of contact for
both employees and non-employees for any questions
regarding compliance.
Employees also have the opportunity to submit infor-
mation – anonymously and confidentially – via the
BMW Group SpeakUP Line about possible breaches of
the law within the Company. The BMW Group SpeakUP
Line is available in a total of 34 languages and can be
reached via local toll-free numbers in all countries in
which BMW Group employees carry out activities.
Compliance-related queries and concerns are docu-
mented
and followed up by the BMW Group Com-
pliance Committee Office using an electronic Case
Management System. If necessary, Corporate Audit,
Corporate Security, the Works Council and Legal
Affairs may be called upon to assist in the investigation
process.
Through the group-wide reporting system, Compliance
Responsibles throughout the BMW Group report on
compliance-relevant issues to the Compliance Commit-
tee on a regular basis, and, if necessary, on an ad hoc