Mercedes 2008 Annual Report Download - page 125

Corporate Governance |Compliance |121
Corporate Compliance provides support with the selection of new
business partners by means of an appropriate preliminary audit
in a due diligence process. This due diligence process culminates
in clear recommendations made by the Legal & Compliance
department.
In order to improve the transparency of government transactions,
Daimler has implemented the Mandatory Consultation Process,
which standardizes the required monitoring mechanisms. This
enhances the efficiency and quality of processes to be carried
out by the Group in connection with government transactions.
Documentation is supported with a specially developed IT tool.
Comprehensive compliance services. A company with world-
wide operations like the Daimler Group cannot guarantee compli-
ance solely with a specialized headquarters department. It is
also necessary that each individual employee is aware of his or
her responsibility and behaves correctly. Executives have an
additional special role, because staff members base their behav-
ior on that of their superiors. The personal accountability of
each individual member of staff or management in his or her area
of responsibility is not transferrable and is part of the day-to-day
business in the same way as other tasks. Compliance is therefore
an integral and long-term component of Daimler’s corporate
culture.
Daimler provides its employees and executives with support in
the fulfillment of their compliance responsibilities in day-to-day
situations at all times. In addition to superiors and local contact
persons, the Daimler Group currently has two main central depart-
ments for compliance matters: the Compliance Consultation
Desk (CCD) and the Business Practices Office (BPO).
All of the Group’s employees can contact the Compliance Consul-
tation Desk with specific compliance questions. The most
common questions and answers on the issue of compliance are
accessible in the online database, QuISS. This allows all of our
employees to make use of the experience gathered over the past
three years at any time and in a structured form.
One of the tasks of the Business Practices Office, which has
offices in Germany and the United States, is to receive, document
and process complaints. This facility allows both Daimler employ-
ees and external persons to report any indications of possible
misconduct confidentially and, if desired, anonymously.
After recording the details of such complaints, representatives of
the Legal, Human Resources, Corporate Audit and Corporate
Security departments discuss the matter and instigate internal
investigations if necessary. In certain clearly defined cases,
the Business Practices Committee then makes a decision on the
basis of these investigations. The Business Practices Commit-
tee is composed of high-level executives from various areas of
the Group.
There is no tolerance at Daimler for behavior that is against the
law or contrary to applicable regulations. The possible conse-
quences of any misconduct discovered include appropriate mea-
sures for training and communication and the correction of
existing processes, as well as sanctions in accordance with the
Group’s policy of the “Zero Tolerance Principle” and the Group’s
guidelines on disciplinary actions. The status and position of the
affected persons are irrelevant, because all of our employees
are equally treated in accordance with the four principles of fair-
ness, consistency, transparency and sustainability.
Broad-based training and communication program. Since
2006, more than 22,000 employees worldwide have attended
training courses on compliance-relevant topics. We offer our
employees courses tailored to the needs of the various target
groups. In the year 2008, the scope of the courses was once
again significantly broadened through the provision of additional
e-learning modules.
We provide comprehensive information on the issue of compli-
ance via the Group’s internal media. The Board of Management
of Daimler AG regularly makes statements on compliance in
internal print and online media and at organized events, and empha-
sizes the importance of a functioning compliance program. The
issue of compliance was also dealt with in detail in a special edition
of our staff newspaper. This special edition had a print run of
more than 230,000.
Furthermore, the Group’s entire executive staff receives addition-
al information and support via a quarterly compliance newsletter.
Corporate Guidelines
Integrity Code
Code of Ethics
Local Guidance
Corporate
Values
Anti-Bribery Handbook
Corporate Policies