Mercedes 2015 Annual Report Download - page 179

186 D | CORPORATE GOVERNANCE | INTEGRITY AND COMPLIANCE
Compliance
Daimler acts in conformance with ethical principles and adheres
to all relevant legislation, internal rules and voluntary commit-
ments. We place the utmost priority on complying with all appli-
cable anti-corruption regulations and on maintaining and
promoting fair competition, as is set out in our Integrity Code.
Compliance management system (CMS)
Our CMS is based on national and international standards and
supports us in ensuring compliant behavior in our daily busi-
ness. We continually review the effectiveness of the system,
and we adjust it to worldwide developments, changed risks
and new legal requirements. In this way, we improve its efficiency
and effectiveness.
“Anti-Money Laundering Policy”
This policy is designed to prevent money laundering and the
financing of terrorism in the trade with goods. It forms the
basis for ensuring that legislation in various countries is com-
plied with throughout the Group. The Chief Compliance
Officer serves as the anti-money laundering officer of Daimler AG.
A center of competence supports the Chief Compliance Officer
with the management and coordination of money-laundering
prevention measures in the goods trade.
Consistent compliance with sanction lists
Daimler takes appropriate measures to ensure that the legal
sanctions specified by legislation are observed. Effective
and efficient implementation has been ensured here by the
intro duction of a global system-based standard process.
Systematic minimization of compliance risks
We systematically analyze and assess the compliance risks of
all our business units every year. The results of this analysis
form the basis of our risk management. One focus of our risk
minimization activities is on sales companies in high-risk
countries. The responsibility for implementing and monitoring
the associated measures lies with the management of each
company, which cooperates closely with the Group Compliance
department.
Effective compliance structures
Our Compliance Organization is structured along the lines of
our divisions. This structure enables us to offer effective
support and advice to the individual divisions. For this purpose,
the organization consists of divisional and regional compliance
officers. In addition, local compliance managers throughout
the world make sure that our standards are observed. The
divisional and regional compliance officers report directly to
the Chief Compliance Officer. This ensures the divisional and
regional compliance officers’ independence from the divisions.
The Chief Compliance Officer reports directly to the Member
of the Board of Management for Integrity and Legal Affairs and
to the Chairman of the Supervisory Board.
We offer target group-specific training courses within our inte-
grated training program in order to ensure compliance staff
members remain up to date on the continual changes made to
laws and regulations.
Whistleblower system BPO (Business Practices Office)
The BPO is the organization where Daimler employees and
external whistleblowers can report misconduct anywhere in
the world. The office is available to receive information around
the clock and – if allowed by local law – also anonymously.
This system enables us to learn about potential risks and specific
violations at an early stage and thus prevent damage to the
company and its reputation. Our globally valid corporate policy
in this area ensures a fair and sensitive approach that takes
into consideration the principle of proportionality and also gives
protection to both whistleblowers and affected parties. In
Germany, reports to the BPO can also be submitted via a “neutral
intermediary” – an independent attorney who, due to her oath
of professional secrecy, is obliged to maintain confidentiality.
Compliance at our business partners
We regard our business partners’ integrity and behavior in con-
formity with regulations as an indispensable precondition
for trusting cooperation. In the selection of our direct business
partners, we make sure that they comply with the law and
observe ethical principles. Within the framework of our integrated
training program, we also offer our business partners special
training courses on integrity and compliance in line with the
specific risks they face. We reserve the right to terminate our
cooperation with business partners who fail to conform to our
standards. For the expectations we place on our business
partners, see also w daimler.com/sus/obr.
Sharing experience of compliance in practice
We have designed the Daimler Compliance Academy as an
annual practical seminar that creates a platform for sharing
experience of compliance trends and challenges. The seminar,
which took place for the second time in 2015, is directed at
compliance professionals from all industries.
Antitrust law
Our Group-wide antitrust-compliance program, which is oriented
toward national and international standards, helps us to ensure
adherence to antitrust laws in our business operations. By assess-
ing qualitative and quantitative factors, we systematically
analyze the antitrust risks of all our business units. The results
of this analysis form the basis of our risk management and
of the definition of the measures to be taken to counteract any
risks related to antitrust law.
We help our employees to recognize situations that might
be critical from an antitrust perspective and to act in compliance
with regulations in their daily work by means of training
courses, as well as with written advice and practical examples.
Our employees also have access to an advisory hotline estab-
lished by the Legal department for questions on antitrust and
cartel matters. Our antitrust-compliance program defines a
binding Daimler standard on how matters of competition law
are to be assessed internally. In this context, we focus in par-
ticular on the strict standards of the European antitrust author-
ities and courts. Our standard is the basis for effective imple-
mentation of the program and allows us, guided and supported
by our Legal department, to ensure a uniform level of compli-
ance and advice throughout the Group. We regularly review our
antitrust-compliance program in order to continually adapt it
to worldwide developments, new legal requirements and changing
risks, and to constantly improve its effectiveness.