Reebok 2014 Annual Report Download - page 163

Group Management Report – Financial Review
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2014
Risk and Opportunity Report
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adidas Group
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2014 Annual Report
Prevention includes, for example, training such as the web-based Code of Conduct training (which
is mandatory for all employees worldwide), general data protection training and an anti-trust
training programme (for employees who are exposed to customers and competitors) incorporating
web-based training and face-to-face training workshops.
To ensure timely detection of potential infringements of statutory regulations or internal guidelines,
we have implemented whistleblowing procedures which allow employees to either report concerns
over wrongdoing/potential compliance violations internally (e.g. directly to their supervisor, to the
Chief Compliance Officer or other Compliance Officers, the relevant HR manager or the Works
Council) or externally via an independent, confidential reporting hotline and email service. The
hotline (Fair Play hotline) is available around the clock, seven days a week and can be called
free of charge in over 60 countries worldwide. In addition, our Group Internal Audit and Profit
Protection departments conduct regular audits and investigations to detect potential incidents of
non-compliance. In case of reported or suspected compliance violations, ad hoc investigations may
be undertaken as well.
Appropriate and timely response to compliance violations is essential. Therefore, we have
established a global network of local Compliance Officers reporting directly to the Chief Compliance
Officer of the Group as dedicated contact persons to whom complaints and information concerning
compliance violations can be reported. We track, monitor and report potential incidents of
non-compliance worldwide using a web-based reporting solution, which can be accessed by all
Compliance Officers across the Group. Appropriate sanction mechanisms (including termination
of employment) are used to react promptly to possible compliance violations. Insights gained from
the investigation of past violations are used to continuously improve the compliance management
system.
The Chief Compliance Officer regularly reports to the Executive Board on the further development
of the compliance programme and on major compliance cases, which are also reported to the Audit
Committee. Further, he reports to the Audit Committee at one of its meetings at least once a year
concerning the contents and the further development of the compliance programme.
see Glossary, p. 258