BMW 2015 Annual Report Download - page 184

184
Compliance in the BMW Group
Responsible and lawful conduct is fundamental to the
success of the BMW Group. It is an integral part of
our corporate culture and the reason why customers,
shareholders, business partners and the general public
place their trust in us. The Board of Management and
the employees of the BMW Group are obliged to act
responsibly and in compliance with applicable laws and
regulations.
This principle has been embedded in BMW’s internal
rules of conduct for many years. In order to protect itself
systematically against compliance-related and
reputa-
tional risks, the Board of Management created a Com-
pliance
Committee several years ago, mandated to es-
tablish a worldwide Compliance Management System
throughout the BMW Group.
The BMW Group Compliance Committee comprises
the heads of the following departments: Legal Affairs,
Corporate and Governmental Affairs, Corporate Audit,
Group Reporting, Organisational Development and
Corporate Human Resources. It manages and monitors
activities necessary to avoid non-compliance with the
law. These activities include training, information and
communication measures, compliance controls and
following up cases of non-compliance.
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,
details of investigations performed, known infringements
of the law, sanctions imposed and corrective / preven-
tative 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
Compliance 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 Commit-
tee 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. Meas-
ures 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”
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
Company-wide Compliance
Network
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
168 STATEMENT ON
CORPORATE GOVERNANCE
(Part of Management Report)
168 Information on the Company’s
Governing Constitution
169 Declaration of the Board of
Management and of the
Supervisory Board pursuant to
§ 161 AktG
170 Members of the Board of
Management
171
Members of the Supervisory
Board
174 Work Procedures of the
Board of Management
176 Work Procedures of the
Supervisory Board
181 Disclosures pursuant to the Act
on Equal Gender Participation
182 Information on Corporate
Governance Practices
184 Compliance in the BMW Group
188 Compensation Report