Mercedes 2008 Annual Report Download - page 124

120
Our understanding of compliance and our principles. By the
term compliance, we understand the observance in all of our
business activities of applicable laws and regulations, of the rele-
vant internal guidelines and procedures, and of our own volun-
tary commitments.
We already formulated the Daimler Integrity Code in 1999. On the
basis of our corporate values – Passion, Respect, Integrity and
Discipline – this comprehensive code of conduct applies without
exception to our entire workforce. In the year 2003, we updated
the Integrity Code with the Principles of Social Responsibility and
supplemented it with the Code of Ethics.
The Integrity Code is supplemented and put into precise form with
specific Corporate Policies and Guidelines, which transfer the
principles of the Integrity Code with ethical or compliance rele-
vance into explicit guidelines for behavior, and serve as a key
aid to orientation in the complex field of business operations.
An overview of this multi-stage compendium of regulations is
depicted in the diagram on page 121.
In the year 2008, the Board of Management approved a new form
of policy management. This House of Policies brings together
all of the Group’s policies and guidelines and further facilitates
their understanding, because all of the policies and guide-
lines will soon be additionally accessible in a central database on
Daimler’s intranet. The corporate policy framework describes
the requirements placed on guidelines as well as the various duties
and responsibilities in the new system of policy management.
Further development of compliance organization. At the begin-
ning of 2008, Daimler AG took a further step to substantially
strengthen its self-monitoring function with regard to ethically
correct corporate management. Directly below the Board of
Management, the upgraded position of Chief Compliance Officer
was newly created at the level of senior vice president. In addition,
the Corporate Compliance department was merged with the
Legal Affairs department to form a new department under the
name of Legal & Compliance (LC). In order to strengthen the
sustained anchoring of compliance in all business units and central
functions, at the end of the year we also decided to establish
the Group Compliance Board (GCB), which replaces the previous
Compliance Committee.
An independent external advisor supports and advises the Super-
visory Board, the Audit Committee and the Board of Management
with compliance issues.
Systematic approach to the sustained fight against corrup-
tion. In the context of the Group-wide risk strategy, the compli-
ance risks relevant to Daimler are analyzed and evaluated. Based
on the results obtained, decisions are made on the key points
of the annual compliance program for the prevention and elimi-
nation of corruption.
To determine the necessary measures for the prevention of cor-
ruption, we carried out compliance reviews in sales companies
and business units in several countries, starting in 2006. In 69
sales companies and business units (thereof 22 in 2008), we also
established standardized monitoring systems which help to
secure legally and ethically correct conduct. The effectiveness
of these monitoring systems is assessed in audits carried out
by our Internal Auditing department. IT applications create trans-
parency and help us to maintain the processes and monitoring
mechanisms we have introduced.
In this context, we also appropriately expanded our worldwide
network of local compliance managers (LCM). They support the
local management with the maintenance of all the Group’s com-
pliance standards. We ensure they are independent of local
management by means of close organizational links with Corpo-
rate Compliance in Stuttgart. The local compliance managers
regularly report on the status and progress of the compliance
programs in their business units.
As part of the further development of the Legal & Compliance
department, the two existing global networks of local compliance
managers and legal staff were merged in July 2008. This has
enabled us to enhance our worldwide reach on the issue of com-
pliance: we have meanwhile named 85 local compliance man-
agers in 41 countries as competent contact persons in the respec-
tive companies.
Compliance