Reebok 2015 Annual Report Download - page 164

GROUP MANAGEMENT REPORT – FINANCIAL REVIEW
Risk and Opportunity Report
160
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The Group’s compliance management system is based on the OECD Principles of Corporate Governance.
It refers to the OECD Guidelines for Multinational Enterprises and is designed to:
•
Support the achievement of qualitative and sustainable growth through good corporate governance
practice.
•Reduce and mitigate the risk of financial losses or damage caused by non-compliant conduct.
•Protect and further enhance the value and reputation of the Group and its brands through compliant
conduct.
•Preserve diversity by fighting harassment and discrimination.
Our Fair Play Code of Conduct, which is applicable globally and for all business areas, stipulates guidelines
for behaviour in everyday work and is available both on our website and on our intranet. The Code of
Conduct is the cornerstone of our compliance management programme which is founded on three pillars:
prevention, detection and response.
Prevention includes, for example, policies such as the Group’s Code of Conduct, the Group’s anti-bribery
and corruption policy or the Group’s privacy policy, training of employees or targeted compliance-related
communication by management or the Group Compliance department. In 2015, approximately 13,000
employees participated in our web-based Code of Conduct training, while around 14,000 employees
completed our web-based anti-bribery and corruption training.
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 or email service. The hotline (named ‘Fair Play hotline’) is available at all
times and can be called free of charge in over 60 countries worldwide. In case of reported or suspected
compliance violations, the Chief Compliance Officer or the Group Compliance department undertake the
required investigations.
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 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, our internal investigators and
the external operator of our Fair Play hotline. The Group Compliance department manages this web-based
reporting solution. In 2015, we recorded around 300 potential compliance violations. Appropriate sanction
mechanisms (ranging from warnings through to termination of employment) are used to react promptly
to 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.
DESCRIPTION OF THE MAIN FEATURES OF THE INTERNALCONTROL AND RISK
MANAGEMENTSYSTEM RELATINGTOTHE CONSOLIDATED FINANCIAL REPORTING
PROCESS PURSUANT TO § 315 SECTION 2 NO. 5 GERMAN COMMERCIALCODE
HANDELSGESETZBUCH – HGB
The internal control and risk management system relating to the consolidated financial reporting process
of the adidas Group represents a process embedded within the Group-wide corporate governance system.
It aims to provide reasonable assurance regarding the reliability of the Group’s external financial reporting
by ensuring Group-wide compliance with statutory accounting regulations, in particular the International
Financial Reporting Standards (IFRS) and internal consolidated financial reporting policies (Group Finance
Manual). We regard the internal control and risk management system as a process based on the principle
of segregation of duties, encompassing various sub-processes in the areas of Accounting, Controlling,