Mercedes 2009 Annual Report Download - page 166

162
Our understanding of compliance and our principles. In the
year under review, we further developed our compliance culture,
which requires and fosters correct behavior. By the term compli-
ance, we understand the compliance of Daimler’s activities with
all applicable laws, rules and regulations. In this context, it is
also necessary to adhere to the internal directives and guidelines
by which the Daimler Group is managed or to which we have
voluntarily committed.
We already formulated the Daimler Integrity Code in 1999. This
comprehensive code of conduct reflects our corporate value
integrity and applies without exception to our entire workforce.
The Integrity Code is supplemented and put into precise form
with guidelines, which are available at a central location in a data-
base on our employee portal and which serve as a key aid to
orientation in our daily business. An overview of this multi-stage
compendium of regulations is depicted in the diagram on page 163.
Further development of compliance organization. A culture of
compliance must be anchored wherever business is conducted
and organized. In order to embed compliance even more firmly in
all divisions and in the central functions, in 2009 we established
the Group Compliance Board, which is the highest level of our com-
pliance hierarchy and reports directly to Daimler’s Board of
Management and reflects its structure. This board deals with all
of the Group’s material compliance issues.
In addition, since 2006 an independent external advisor has sup-
ported and advised the Supervisory Board, the Audit Committee
and the Board of Management with compliance issues.
The Chief Compliance Officer reports directly to the Chairman
of the Board of Management and regularly provides information
to the Audit Committee of the Supervisory Board.
The Corporate Compliance Operations department (CCO) defines
the annual anti-corruption program and supports its implementa-
tion worldwide. In the context of further developing the Legal &
Compliance department, the existing global networks of local
compliance managers and the Legal Affairs department have
been merged. Meanwhile, we have approximately 90 local com-
pliance managers, who support 150 companies and business
units. They assist the local management in observing anti-corrup-
tion regulations and regularly report on the status and progress
of the compliance program in their business entities. The local
compliance managers are specifically qualified. We secure their
independence by means of an appropriate agreement with the local
management and by means of the direct reporting lines to the
Legal & Compliance department.
Systematic compliance risk management. Within the frame-
work of a systematic risk analysis, all companies and entities
of the Daimler Group are assessed and classified in terms of their
corruption risk. The crucial aspects include business activities
and the business environment. On the basis of the risk assessment,
appropriate actions are assigned to the organizational units.
This constitutes the compliance program to avoid and combat
corruption.
In 71 sales companies and business units, we have also estab-
lished standardized monitoring systems which help to secure
legally and ethically correct conduct. The effectiveness of
these monitoring systems is assessed by our Internal Auditing
department and by the companies themselves in annual self
assessments.
Irrespective of a unit’s risk classification, CCO provides Group-
wide support with the selection of new sales partners by carrying
out an integrity test. This process culminates in clear recommen-
dations made by the Legal & Compliance department.
In order to improve the transparency of government transactions,
Daimler has implemented a standardized working process in
sales companies and business entities where there is an increased
risk of corruption. This ensures that the relevant documentation
and approval requirements are fulfilled.
Compliance