BMW 2014 Annual Report Download - page 186

186
170 STATEMENT ON
CORPORATE GOVERNANCE
(Part of Management Report)
170 Information on the Company’s
Governing Constitution
171 Declaration of the Board of
Management and of the
Supervisory Board pursuant to
§ 161 AktG
172 Members of the Board of
Management
173
Members of the Supervisory
Board
176 Work Procedures of the
Board of Management
178 Work Procedures of the
Supervisory Board
183 Information on Corporate
Governance Practices
184 Compliance in the BMW Group
189 Compensation Report
The BMW Group Legal Compliance Code is the corner-
stone of the Group’s Compliance Management System,
spelling out the Board of Management’s commitment
to compliance as a joint responsibility (“tone from the
top”). This document, which was revised and expanded
in 2014, explains the significance of legal compliance
and provides an overview of the various areas relevant
for the BMW Group. It is available both as a printed
brochure and for download in German and English. In
addition, translations into eleven other languages are
available in the BMW Group intranet.
Managers in particular bear a high degree of responsi-
bility and must set a good example with regard to pre-
venting infringements. Managers throughout the BMW
Group acknowledge 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 make them aware
of
legal risks. Managers must, at regular intervals and
on
their own initiative, verify 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 25,400 managers and staff worldwide have re-
ceived training in essential compliance matters since the
introduction of the BMW Group Compliance Manage-
ment System. The training material is available on an In-
ternet-based training platform in German and English
and includes a final test. Successful completion of the
training programme, which is documented by a certificate,
is mandatory for all BMW Group managers. Appropriate
processes are in place to ensure that all newly recruited
managers and promoted staff undergo compliance train-
ing. In this way, the BMW Group ensures full training
coverage for its managers in compliance matters.
In addition to this basic training, more in-depth training
is also provided to certain groups of staff on specific
compliance issues. In 2014, a total of 1,900 employees at
BMW AG branches received further training as anti-
money laundering measures were upgraded. Antitrust
law training was also expanded in 2013, targeting
em-
ployees who come into contact with antitrust-related
issues as a result of their functions within sales and
marketing, purchasing, production or development. A
total of 3,900 employees have already completed this
training. The relevant divisions also implemented further
measures and processes to make employees who par-
ticipate in meetings with competitors sufficiently aware
of antitrust risks.
Additional compliance coaching has also been imple-
mented for international sales and financial service lo-
cations
in local markets. 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 2014, market
coaching was conducted in Canada, China and the UK.
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 informa-
tion – 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 are engaged in activities.
Compliance-related queries and concerns are docu-
mented and followed up by the BMW Group Compliance
Committee Office using an electronic Case Managem
ent
System. If necessary, Corporate Audit, Corporate
Security, the Works Council and legal departments 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
basis. This includes reporting on the compliance status
of the relevant entities, on identified legal risks and
incidences of noncompliance, as well as on corrective /
preventative measures implemented.