Mercedes 2012 Annual Report Download - page 172

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Compliance is the sustained establishment of conduct
in conformance with rules. Our compliance-management
system is intended to ensure that Daimler and its employees
always conduct themselves in conformance with rules.
Complying with anti-corruption regulations as well as maintain-
ing and promoting fair competition have the highest priority
for the Daimler Group and serve as a benchmark for our staff
and management. To give further emphasis to this goal,
compliance and integrity are taken into consideration in our
executives’ annual target agreements and assessments
of target fulfillment. Particular attention is paid to individuals’
correct conduct in conformance with rules and ethics.
Worldwide establishment of divisional compliance organi-
zation. In order to effectively counteract the risks of our
divisions and markets, we have altered the structure of our
compliance organization in line with our divisions. Each
division is now supported by a compliance officer. In addition,
a regional compliance office was established in China in 2012,
reflecting the special importance of the Chinese market.
Furthermore, local compliance managers are active worldwide,
advising on matters of compliance and ensuring observance
of our compliance standards.
In order to guarantee their independence of the divisions,
the compliance officers for the divisions and the compliance
manager for the region of China and Northeast Asia report
to the Group Chief Compliance Officer. He is responsible for
the entire global organization and reports directly to the
Member of the Board of Management who is responsible
for “Integrity and Legal Affairs”.
Analysis of compliance risks. Dealing with risks responsibly
and assessing them effectively is a precondition for sustained
business success. We therefore evaluate and classify compliance
risks in a systematic risk analysis. We apply qualitative indi-
cators such as an assessment of the business environment
as well as quantitative indicators such as relevant shares
of revenue and the number of contractual partners. In line with
the risk assessment carried out in this way, measures are
then defined jointly with the business units to minimize the
recognized risks. Against this backdrop, for example, our sales
activities in countries with an increased risk of curruption
are subject to particularly intensive risk management. Res-
ponsibility for implementing the individual measures and the
monitoring duty lie with the management of each business
unit. This is supported by the Group Compliance department.
Further development of the compliance processes.
The focus of compliance activities in 2012 was on examining
our business partners in the sales process (sales business
partner due diligence). We apply high standards in the selec-
tion of our sales and business partners and expect them
to act in accordance with our compliance rules and ethical
principles. Based on a standardized risk assessment carried
out in advance, the divisions decide, in addition to the specific
risk factors, on the appropriate intensity for examining the
respective business partner. The divisions carry out the exami-
nation in their own responsibility and with support from the
Group Compliance department.
Stronger whistleblower system and Business Practices
Office (BPO). A functioning whistleblower system is an
important source for us to recognize risks and infringements
of rules. Information on possible serious infringements by
employees and external parties is passed on to the BPO. In 2012,
the management and employee representatives reached a
company agreement on the reorganization of the Daimler whis-
tleblower system. This agreement sets out a fair, transparent
process affording equal protection to whistleblowers and the
other persons involved. Furthermore, in addition to the existing
reporting channels, in Germany we have commissioned an
independent lawyer as a neutral mediator, who also accepts
information on violations of rules. Due to his professional
obligation to maintain confidentiality, it is assured that the
whistleblowers remain anonymous vis-à-vis Daimler.
Compliance training and communication. The regular
provision of information and targeted training courses supple-
ment and support the effective and sustained anchoring
of correct conduct at Daimler. We carry out face-to-face train-
ings for specific groups of employees as well as web-based
trainings. We also offer these trainings to our business partners
and sales partners, so that they can familiarize themselves
with our ideas of integrity and compliance. In those courses,
we train participants for example on the principles of cor-
ruption prevention and on competition law. Since 2010, we
have trained more than 100,000 employees in business
units and departments with a special risk situation using
web-based courses and presence events. The focus
was on employees in sales and sales-related functions.