Compliance is an indispensable element of the integrity culture at Daimler. Compliance with all relevant laws, voluntary commitments, and internal regulations and acting in accordance with ethical principles is a matter of course for us. Our top priority is to comply with all anti-corruption legislation, as well as to protect and promote fair competition. We have codified this in our Integrity Code. We strive to sustainably anchor integrity and compliance as integral parts in our value chain.
Compliance Management System (CMS) as a foundation. Our CMS is aligned to national and international standards, and supports us in ensuring compliant behavior in our daily business. We review the effectiveness of the system on a continuous basis, and adapt it in line with worldwide developments, changed risks, and new legal requirements. We thus continuously improve its efficiency and effectiveness. In 2014, we developed new processes for reviewing and observing international sanctions, and expanded the measures for the prevention of money laundering in the trade with goods and services as well as the measures for the prevention of financing terrorism.
Prevention of money laundering and financing terrorism. With a view to the further improvement of the Group-wide prevention of money laundering in the trade with goods and services, we have examined the increasing requirements in various countries and have initiated more extensive measures. In this context, the “Anti-Money Laundering Policy” entered into effect on August 1, 2014.This policy lays the foundation for Group-wide compliance with the respective national legislations. A center of competence supports the Chief Compliance Officer in his function as the anti-money laundering officer of Daimler AG for the central management, consulting, and coordination of money laundering prevention measures in the goods trade.
Review of sanction lists. Restrictions in the movement of capital and goods are instruments of international policy at both international and European levels. Daimler AG takes appropriate measures to ensure that the legal sanctions specified by the legislator are observed. With a view to effective and efficient implementation, we have introduced a worldwide system-based standard process for implementation of these requirements, which provides for an implementation phase.
Analysis of compliance risks. In 2014, we again performed a systematic risk analysis of all business units which included assessments in accordance with qualitative as well as quantitative indicators — such as the respective business model, the relevant environmental factors and the type of contractual relationships. The results of this analysis provide the basis for the risk controlling. Together with the business units we define measures for risk minimization with a key focus of our activities on sales companies in high-risk countries. The responsibility for implementing these measures and the supervisory duty lie with the respective members of management, who work closely together with the Group Compliance unit.
Reinforcing the worldwide structures. Our Compliance organization is divisionally oriented. This structure has proven itself and enables the effective support and advisory services to the business divisions by a divisional or regional Compliance officer, respectively. Moreover, local compliance partners around the world ensure that our standards are observed. We safeguard the independence of the divisional and regional officers from the business divisions through their direct reporting line to the Chief Compliance Officer, who in turn reports directly to the Board of Management member for Integrity and Legal Affairs as well as to the Chairman of the Supervisory Board.
We provide specific qualification training, which supports the Compliance staff in dealing with the frequently changing legal and regulatory situation. In addition, all new Compliance employees receive comprehensive introductory training in a practical Compliance seminar.
Whistleblower system. We use the Business Practices Office (BPO) as a valuable source of information on potential risks and specific violations of the rules. That is why it is an important instrument of good corporate governance that also serves to avert damage from our company.
Our whistleblower system receives reports of irregular conduct from employees and external parties worldwide around the clock, through different reporting channels, as well as anonymously — to the extent permitted under local law. A prerequisite for the acceptance of the system is that it is designed fairly, takes into consideration the principle of proportionality, and gives equal protection to whistleblowers and affected parties. We codified these criteria in a globally applicable corporate policy in 2013. In addition, in February 2012, we created the neutral mediator function in Germany, which is staffed by an independent attorney. The mediator also receives reports of rule violations, and is obligated to maintain confidentiality by the oath of professional secrecy. Of the 59 BPO cases, which were closed “with merit” in 2014, six were in the category of “Bribery.” The company responded with appropriate measures.
Information on criminal proceedings against Daimler AG is provided in the Annual Report for the 2014 reporting year. Proceedings against natural persons are generally not disclosed since convictions or resolutions under criminal law are not communicated to Daimler AG.
Collaboration with our business partners. Ethical conduct and compliance with regulations is an essential prerequisite for trusted collaboration with our business partners. In selecting our direct business partners, we make sure that they comply with the law and follow ethical principles. Depending on the risks we provide our business partners with target group-oriented trainings measures. In addition, we have formulated our expectations in the brochure “Ethical Business. Our shared responsibility.” If business partners fail to observe our standards, we retain the right to terminate the collaboration.
Our training programs
Training program 2014 Web-based training program Target group Number of participants Integrity@Work Employees worldwide with email access 21,796 of which Administrative employees (incl. level 5) worldwide: 20,003 Managers (level 4 and up) worldwide: 1,793 Integrity@Work procurement module Procurement employees worldwide with email access 1,389 of which Administrative employees in Procurement (incl. level 5) worldwide: 1,210 Managers in Procurement (level 4 and up) worldwide: 179 Integrity@Work antitrust law module Employees worldwide with email access 16,060 of which Administrative employees (incl. level 5) worldwide: 12,585 Managers (level 4 and up) worldwide: 3,475 All employees worldwide with email access 39,245 Classroom training Target group Number of participants Number of events Classroom training on antitrust law Managers and administrative employees worldwide 3,095 120 Classroom training on corruption prevention Managers and administrative employees worldwide 4,597 258 Classroom training on prevention of money laundering and financing of terrorism Managers and administrative employees in Germany 112 6 Classroom training for newly appointed and promoted employees incl. modules on Integrity and Compliance Managers (level 4) 401 28 Senior managers (level 3) 192 9 Integrity & compliance for students of Cooperative University Students of the Cooperative University in Germany 177 5 Total 8,574 426
Brochure “Ethical Business. Our shared responsibility.”
Brochure “Ethical Business. Our shared responsibility.”PDF file (2.7 MB)
Specialist dialog beyond company limits. We are frequently asked to share our experiences in the area of compliance. That is why we have decided to offer a practical seminar on compliance with the Daimler Compliance Academy. The first seminar was held in April 2014 in Germany. While previous external training programs were directed only at business partners and suppliers, for the first time, with the Academy we have now organized a seminar for compliance professionals from all industries. Another goal of the seminar is to create a platform for the exchange of experiences about compliance trends and challenges.