BMW 2014 Annual Report Download - page 185

185 STATEMENT ON CORPORATE GOVERNANCE
BMW Group Compliance Management System
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 and
Processes
Compliance
Contact and
SpeakUP Line
Compliance
Reporting
Compliance
Investigations
and Controls
Compliance Risk
Analysis
Annual
Report
Annual
Report
Annual
Compliance
Reporting
pliance Committee Office comprises ten employees and
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 (which is 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 the Compliance Management System are
initiated on the basis of identified requirements.
A coordinated set of instruments and measures is em-
ployed to ensure that the BMW Group, its representative
bodies, its managers and staff act in a lawful manner.
Particular emphasis is placed on compliance with anti-
trust legislation and the avoidance of corruption risks.
Compliance measures are supplemented by a whole
range of internal policies, guidelines and instructions,
which in part reflect applicable legislation. The BMW
Group Policy “Corruption Prevention” and the BMW
Group Instruction “Corporate Hospitality and Gifts”,
which were revised in 2014, deserve particular mention.
These documents deal with lawful handling of gifts
and
benefits and define appropriate assessment criteria
and approval procedures for specified actions.
Compliance measures are determined and prioritised
on the basis of a group-wide compliance risk assess-
ment covering all 331 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 com-
pliance
management team covering all parts of the
BMW Group, which oversees a network of more than
180 Compliance Responsibles.
The various elements of the BMW Group Compliance
Management System are shown in the diagram on the
left and are applicable for all BMW Group entities world-
wide. To the extent that additional compliance require-
ments apply to individual countries or specific lines
of business, these are covered by supplementary com-
pliance measures.
monitors activities necessary to avoid non-compliance
with the
law (Legal Compliance). These activities include
training, information and communication measures,
compliance 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-
related issues, including the progress made in refining
the BMW Group Compliance Management System, de-
tails of investigations performed, known infringements
of the law, sanctions imposed and corrective / preventa-
tive measures implemented. This ensures that the Board
of Management is immediately notified of any cases of
particular significance. 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-