BMW 2015 Annual Report Download - page 186

186
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 Manage-
ment 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
in-
cidences of non-compliance, as well as on corrective /
pre-
ventative measures implemented.
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 Com-
mittee also engages Corporate Audit to perform com-
pliance-specific checks. In addition, four BMW Group
Compliance Spot Checks, sample tests specifically
de-
signed to identify potential corruption risks, were carried
out in 2015. Compliance control activities are coordi-
nated
by the BMW Group Panel Compliance Controls.
Any necessary follow-up measures are organised by the
BMW Group Compliance 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. Cul-
pable violations of the law result in employment-con-
tract sanctions and may involve personal liability conse-
quences 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
c entral means of communication is the Compliance
website within the BMW Group’s intranet, where em-
ployees
can find compliance-related information and
have access to 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 mat-
ters. Since mid-2015, BMW Group employees have also
had access to an IT system, which helps them verify
legal admissibility and approve and document benefits,
especially in connection with corporate hospitality.
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 devel-
oped a new Business Relations Compliance programme
aimed at ensuring the reliability of its business relations.
Relevant business partners are checked and evaluated
with a view to identifying potential compliance risks.
These procedures are particularly relevant for relations
with sales partners and service providers, such as agen-
cies and consultants. Depending on the results of the
evaluation, appropriate measures – such as communica-
tion measures, training and possible monitoring – are
implemented to manage compliance risks. The Business
Relations Compliance programme has already been in-
troduced in 37 units since its launch and, over the com-
ing years, will be rolled out successively throughout
the
BMW Group’s worldwide sales organisation. In 2015, the
Company also continued integrating compliance clauses
to protect contractual relationships into dealer and im-
porter 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 in-
ternational employee representative bodies of the BMW
Group have agreed on a binding set of Joint Principles
for Lawful Conduct. In doing so, all parties involved
made a commitment to the principles contained in the
BMW Group Legal Compliance Code and to trustful co-
operation in all matters relating to compliance. Employee
representatives are therefore regularly involved 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 Management
appointed an Ad Hoc Committee back in 1994, consist-
ing of representatives of various specialist departments,
whose members examine the relevance of issues for
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