BMW 2014 Annual Report Download - page 187

187 STATEMENT ON CORPORATE GOVERNANCE
Compliance with and implementation of the Legal Com-
pliance Code are audited regularly by Corporate Audit
and subjected to control checks by Corporate Security
and the BMW Group Compliance Committee Office. As
part of its regular activities, Corporate Audit carries out
on-site audits. The BMW Group Compliance Committee
also engages Corporate Audit to perform compliance-
specific checks. In addition, a BMW Group Compliance
Spot Check, a sample test specifically designed to identify
potential corruption risks, was carried out in 2014. Com-
pliance control activities are coordinated by the BMW
Group Panel Compliance Controls. Any necessary follow -
up measures are organised by the BMW Group Com-
pliance Committee Office.
It is essential that employees are aware of and comply
with applicable legal regulations. The BMW Group
does
not tolerate violations of the law by its employees.
Culpable violations of the law result in employment-
contract sanctions and may involve personal liability con-
sequences for the employee involved.
To avoid this, BMW Group employees are kept fully up -
to-date with the instruments and measures used by the
Compliance Management System via various internal
channels. As of 2014, all new staff receive a welcome
email underscoring the BMW Group’s special commit-
ment to compliance when they join the company. The
central means of communication is the Compliance
website within the BMW Group’s intranet, where em-
ployees can find compliance-related information and
access training materials in both German and English.
The website contains a special service area where various
practical tools are made available to employees to help
them deal with typical compliance-related matters. BMW
Group employees also have access on the website to an
electronically supported approval process for invitations
in connection with business partners and an evaluation
tool for independent assessment of the admissibility of
incentive schemes to promote sales.
In the same way that the BMW Group is committed to
lawful and responsible conduct, it expects no less
from its business partners. In 2012, the BMW Group
developed a new Business Relations Compliance pro-
gramme aimed at ensuring the reliability of its business
relations. Relevant business partners are checked and
e
valuated with a view to identifying potential compliance
risks. These procedures are particularly relevant for
relations with sales partners and service providers, such
as agencies and consultants. Depending on the results
of the evaluation, appropriate measures – such as com-
munication measures, training and possible monitoring –
are implemented to manage compliance risks. The
Business Relations Compliance programme has already
been introduced in 32 units since its launch and, over
the coming years, will be rolled out successively through-
out
the BMW Group’s worldwide sales organisation.
In 2014, the company also continued integrating com-
pliance clauses to protect contractual relationships into
dealer and importer contracts.
Compliance is also an important factor in safeguarding
the future of the BMW Group workforce. With this in
mind, the Board of Management and the national and
international employee representative bodies of the
BMW Group have agreed on a binding set of Joint Prin-
ciples for Lawful Conduct. In doing so, all parties in-
volved made a commitment to the principles contained
in the BMW Group Legal Compliance Code and to
trustful cooperation in all matters relating to compliance.
Employee representatives are therefore regularly in-
volved in the process of refining compliance measures
within the BMW Group.
In the interest of investor protection and to ensure that
the BMW Group complies with regulations relating
to potential insider information, the Board of Manage-
ment appointed an Ad Hoc Committee back in 1994,
consisting of representatives of various specialist
de-
partments, whose members examine the relevance of
issues for ad hoc disclosure purposes. All persons
working on behalf of the company who have access to
insider information in accordance with existing rules
have been, and continue to be, included in a corre-
sponding, regularly updated list and informed of the
duties arising from insider rules.