Mercedes 2006 Annual Report Download - page 134

118
Compliance at DaimlerChrysler
118
Compliance is firmly anchored at DaimlerChrysler. By the term
compliance, we understand the conformity of DaimlerChrysler’s
activities with applicable laws and regulations, as well as with the
ethical and moral principles that the DaimlerChrysler Group
is guided by or to which we have voluntarily committed ourselves.
We already formulated the DaimlerChrysler Integrity Code in 1999.
This comprehensive Integrity Code was expanded in 2003 with
the Principles of Social Responsibility, and was supplemented with
the Code of Ethics. The Code of Ethics is oriented towards the
Board of Management as well as persons with special responsibility
for the contents of financial disclosure, and can be seen at
www.daimlerchrysler.com/corpgov_e.
Our goal is to institutionalize all activities that aim to safeguard
this compliance. In addition, the issue of compliance is to be
firmly anchored at DaimlerChrysler as an important pillar of our
entrepreneurial actions.
Integrity Code put into more concrete form. In the year 2006,
the Integrity Code was supplemented by specific Corporate
Policies & Guidelines, which transfer the principles of the Integrity
Code with ethical or compliance relevance into concrete
guidelines for behavior. The new Corporate Policies & Guidelines
are intended to prevent corruption, to protect Group property,
to more clearly regulate our approach to donations, to ensure the
selection of responsible business partners, and to avoid
conflicts of interest.
An “Anti-Bribery Handbook” has been prepared to support
the implementation of the new Corporate Policies & Guidelines.
It supplements the Policies and Guidelines and puts them
into a concrete form with background information, examples
and illustrative questions and answers. These documents
and additional information on the issue of compliance and its
organization are available on the Group’s intranet.
Starting out from our corporate values – Passion, Respect,
Integrity and Discipline – the Integrity Code gives details of the
key compliance elements that apply to all of our employees.
This hierarchical approach is intended to ensure the
consistency of all behavioral standards. An overview of the
system of regulations is shown in the chart on page 119.
The organization of compliance at DaimlerChrysler. In order to
ensure compliance with all applicable laws as well as with the
relevant principles that we have voluntarily accepted, we already
started to set up a worldwide compliance organization at the
end of 2005. We established the Compliance Committee as
a direct representative of the Board of Management on all
compliance issues. It is composed of high-ranking and experienced
executives from the departments Legal, Corporate Audit,
Finance & Controlling, Sales, Procurement and Supply, and Human
Resources, and generally meets every six weeks.
The Compliance Committee approves and controls the imple-
mentation and execution of our Ethics & Compliance Program.
It monitors and secures the integration of compliance aspects
in the Group’s business and personnel processes. In addition, the
Compliance Committee approves all of the Group’s guidelines.
Also at the beginning of 2006, we created the new department
Corporate Compliance Operations (CCO). This department has
the tasks of developing the Group-wide compliance organization,
coordinating the implementation of the measures decided upon
by the Compliance Committee, and ensuring that the relevant
guidelines are adhered to. In this function, the head of CCO, who
reports to the Chairman of the Board of Management, regularly
informs the Compliance Committee and the Supervisory Board’s
Audit Committee about all of the department’s activities.