Mercedes 2010 Annual Report Download - page 162

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Compliance
Our understanding of compliance and our principles. Integ-
rity is one of our four corporate values. It is the foundation of our
actions and of our success as a globally active group of compa-
nies. We are convinced that financial success can only be sustain-
able if it is achieved legally and correctly. What does compliance
mean in this context? We understand it as adherence to all appli-
cable laws, rules and regulations and to our related internal
guidelines. We can only establish a sustained culture of compli-
ance if each individual internalizes the rules and accepts
responsibility. Correct business practice and sustainable growth
are closely interlinked, because in the long term, communities
of values are also communities of value creation. In 2010, we car-
ried out for the first time a survey on our Integrity Code and
our anti-corruption guidelines, in order to gain an overview of our
employees’ attitude and knowledge. The results of the survey
will help us to improve the quality of the guidelines and the related
processes.
Settlement with the US authorities. The investigations in the
United States of Daimler AG and three other companies of the
Group concerning possible violations of the Foreign Corrupt Prac-
tices Act were terminated on April 1, 2010. In the coming years,
Judge Louis Freeh, a former US federal judge and director of the
FBI, will regularly report to the US authorities on the effective-
ness of our compliance program in the role of our Compliance
Monitor. The Group fully supports the Monitor in carrying out
his tasks. On the other hand, the Monitor’s activities will help us
to improve the effectiveness and efficiency of our compliance
program.
Further development of compliance organization. In the third
quarter of 2010, the Supervisory Board decided to create a new
Board of Management position, Integrity and Legal Affairs, thus
further developing our compliance organization. The tasks of the
new Board of Management member include managing the global
legal and compliance organization, business ethics and the
sustained anchoring of integrity and compliance throughout the
Group. The Chief Compliance Officer is the head of the Group
Compliance department. In the future, he will report directly to
the Board of Management member for Integrity and Legal Affairs
and will regularly inform the Audit Committee of the Supervisory
Board of his activities.
Systematic compliance risk management. The Corporate
Compliance Operations department (CCO) defines the annual
anti-corruption program and supports its implementation
worldwide. In a systematic risk analysis, all companies and entities
of the Daimler Group are assessed and classified in terms of
their corruption risk. The crucial aspects include business
activities, the business environment, and country-specific evaluation
in a corruption awareness index developed by Transparency
International, an anti-corruption organization. Subsequently, we
implement an individually adapted program for the prevention of
corruption on the basis of risk assessments in the companies
and units.
The local compliance managers deployed worldwide are particu-
larly important as contact persons and as an interface to Corpo-
rate Compliance Operations. Approximately 90 specifically quali-
fied local compliance managers look after more than 180
companies and business units at our worldwide sites. They support
the local management with adherence to the anti-corruption
regulations and regularly report both within their business units
and to the Group’s headquarters.
In 72 sales companies and business units, we have also estab-
lished standardized control systems which help to secure correct
behavior in conformance with applicable regulations. The effec-
tiveness of the controls is assessed by our Internal Auditing
department and by the companies themselves in standardized
annual self-assessments. In order to minimize the risk of corrup-
tion, the existing standard process for reviewing transactions
with public authorities and government clients in countries with
an increased risk of corruption is being further developed.