Mercedes 2009 Annual Report Download - page 167

Corporate Governance |Compliance |163
Daimler places emphasis on sustainable compliance at all stages
of the value chain. In the form of sustainability guidelines,
we communicate to our suppliers that a maximum of integrity is
expected and that any form of corruption, bribery, blackmail
or embezzlement is strictly prohibited.
Standard processes and comprehensive compliance ser-
vices. We expect all of our employees to conform with applica-
ble rules and regulations: Executives have an additional special
responsibility because they are role models and thus multipliers
for correct behavior. The personal accountability of each individ-
ual member of staff or management in his or her area of respon-
sibility is not transferrable and is part of the day-to-day business
in the same way as other tasks.
The fundamental importance of compliance is also emphasized in
personnel processes. An employee can only be classified by a
superior as being of high potential or talented if he or she consis-
tently orients decisions and processes towards our guidelines.
In addition, the Board of Management has set compliance targets
for CEOs, CFOs, sales managers and after-sales managers in
units where there is an increased risk of corruption.
In addition to superiors and local contact persons, the Daimler
Group also has central departments for compliance matters. All
of the Group’s employees can contact the Compliance Consulta-
tion Desk (CCD) with specific questions on the prevention of active
corruption. And the most common questions and answers from
many years of providing compliance advice are accessible in a
structured form in the online database, QuISS.
In accordance with the Group’s policy of the “Zero Tolerance
Principle” and Group guidelines on disciplinary actions, there is
no tolerance for behavior that is against the law or contrary to
applicable regulations. The status and position of the affected
persons are irrelevant, because any misconduct is equally trea-
ted in accordance with the four principles of fairness, consisten-
cy, transparency and sustainability.
The contact point for accepting, documenting and processing
any suspected misconduct is the Business Practices Office (BPO).
Not only our employees but also external persons can report
suspicion of any misconduct through various channels – worldwide
and at any time on a confidential basis – if desired also anony-
mously. Employees are expected and executives are obliged to
report any potential serious violation of criminal law or of the
Daimler Integrity Code to the BPO. The protection of whistleblow-
ers is also regulated with binding effect.
Expansion of worldwide training and information provided
on compliance. The reach of our compliance training was sub-
stantially increased once again in 2009. More than 100,000
employees participated in the web-based code of conduct training,
which has been in place since 2009 and is to be attended each
year with a changing focus by all office staff worldwide. In order
to further deepen the corruption-related content of this training,
33,000 employees from sales companies and areas that perform
sales activities also attended web-based training on the preven-
tion of corruption. This is carried out every two years and is obliga-
tory. The range of compliance training also includes more than
130 presence courses worldwide with more than 4,400 partici-
pants.
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
Group’s entire executive staff receives additional information and
support via a quarterly compliance newsletter.
Corporate Guidelines
Site Guidelines
Integrity Code
Departmental Guidelines
Corporate
Values
Company Guidelines
Corporate Policies