BMW 2015 Annual Report Download - page 185

185 STATEMENT ON CORPORATE GOVERNANCE
deserve particular mention: these documents deal with
lawful handling of gifts and benefits and define appro-
priate assessment criteria and approval procedures for
specified actions.
Compliance measures are determined and prioritised on
the basis of a group-wide compliance risk assessment
covering all 346 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 compliance manage-
ment
team covering all parts of the BMW Group, which
oversees a network of more than 200 Compliance Respon-
sibles.
The various elements of the BMW Group Compliance
Management System are shown in the diagram on the
previous page and are applicable for all BMW Group
entities worldwide. To the extent that additional com-
pliance requirements apply to individual countries or
specific lines of business, these are covered by supple-
mentary
compliance measures.
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 nine other languages are avail-
able 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
com-
municate regularly with staff on this issue. Any indication
of non-compliance with the law must be rigorously in-
vestigated.
More than 31,500 managers and staff worldwide have
received
training in essential compliance matters since
the introduction of the BMW Group Compliance Man-
agement System. The training material is available on
an Internet-based training platform in German and
English and includes a final test. Successful completion
of the training programme, which is documented by a
cer tifi cate, is mandatory for all BMW Group managers.
Appropriate processes are in place to ensure that all
newly recruited managers and promoted staff undergo
compliance training. In this way, the BMW Group
en-
sures full training coverage for its managers in com-
pliance matters.
In addition to this basic training, more in-depth training
is also provided to certain groups of staff on specific
compliance issues. Since early 2014, a total of 1,900 em-
ployees at BMW AG branches received further training
as anti-money-laundering measures were upgraded.
Antitrust law training was also expanded in 2013, tar-
geting employees who come into contact with antitrust-
related issues as a result of their functions within sales
and marketing, purchasing, production or develop-
ment. Around 10,100 employees have already com-
pleted this training. The relevant divisions also imple-
mented and stepped up further antitrust compliance
measures and processes in 2015 to make employees
who participate in meetings with competitors or work
with suppliers or sales partners sufficiently aware of
antitrust risks.
Additional compliance coaching has also been imple-
mented for international sales and financial service loca-
tions. 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 com-
pliance offices. In 2015, market coaching was conducted
in Belgium, Denmark, Finland, Italy, Norway, Portugal,
Spain and Sweden.
In order to avoid legal risks, all members of staff can
discuss compliance matters with their managers and
with the relevant departments within the BMW Group,
in particular Legal Affairs, Corporate Audit and Cor-
porate Security. The BMW Group Compliance Contact
serves as a further point of contact for both employees
and non-employees for any questions regarding com-
pliance.
Employees also have the opportunity to submit informa-
tion – anonymously and confidentially – via the BMW