Mercedes 2010 Annual Report Download - page 163

Corporate Governance | Compliance | 159
The highest expectations also of business partners. Correct
behavior is a precondition for a trusting partnership and coopera-
tion. We therefore expect our business partners to behave in full
conformance with applicable regulations. Anyone acting on
Daimler’s behalf must fulfill the highest ethical standards. To
minimize the risk of corruption, we therefore carry out a risk-based
integrity test with business partners who support Daimler with
sales transactions, and enter into contractual arrangements with
those partners, making clear our expectations in terms of adherence
to the law.
Standard processes support behavior that conforms to
applicable regulations. Compliance cannot be delegated.
Executives are role models and are the first points of contact for
their staff; they therefore bear special responsibility for correct
behavior. For this reason, the fundamental importance of compli-
ance is firmly anchored in our qualification programs for execu-
tives and junior managers, as well as in our talent-promotion activi-
ties. Only those employees who consistently orient their decisions
and processes towards applicable rules and regulations can be
given additional responsibility. In addition, we set specific compli-
ance targets for chief executives, heads of finance, sales manag-
ers and after-sales managers in units where there is an increased
risk of corruption. In the future, we will link the variable element
of executive remuneration more closely with compliant behavior.
Wide-ranging compliance activities. In addition to line manag-
ers and local contact persons, the Daimler Group also has head-
quarters departments for compliance matters. All of the Group’s
employees can contact the Compliance Consultation Desk with
specific questions on the prevention of corruption. And the most
common questions and answers with regard to compliance
advice are accessible in an online database. In accordance with
the Group’s policy of the “Zero-Tolerance-Principle” and the
corporate guidelines on disciplinary actions, there is no scope
for discretion in connection with behavior that is against the
law or contrary to applicable regulations.
The contact point for accepting, documenting and processing any
suspected misconduct is the whistleblower system, the Business
Practices Office (BPO). Not only our employees but also external
persons can report any indications of suspected misconduct
through various channels – worldwide and at any time on a confi-
dential basis – if desired also anonymously. Employees are
required and executives are obliged to report any concrete suspi-
cion of violations of criminal law or of the Daimler Integrity
Code to the BPO. The protection of whistleblowers is also regu-
lated with binding effect. Processing reported indications of
suspected misconduct was significantly accelerated in 2010 as
a result of process improvements. To enhance transparency,
we pass on all the significant reported indications of suspected
misconduct in anonymous form to the top management once
each quarter. As a result of case analyses, processes can be
altered if required so that future damage is avoided.
Expansion of worldwide training. Once again, more than
111,000 employees participated in the web-based training on
Daimler’s Integrity Code in 2010. In addition to the issue of
corruption prevention, we also covered the aspects of environmen-
tal protection, respect for human rights, dealing with conflicts
of interest and appearing in public. In addition, more than 21,000
employees from sales companies and sales departments passed
through the web-based training on the prevention of corruption.
The training includes more than 140 presence courses worldwide
with more than 3,500 participants from functions that are particu-
larly exposed to risk. Furthermore, the Group’s top management
level underwent a specific course of anti-corruption training.