Integrity and Compliance
A culture of integrity
Integrity is one of our four corporate values, which form the foundation of our business activities. We are convinced that doing business ethically brings us sustained success and is also good for society as a whole. As a group of companies with global operations, we accept responsibility and want to be a pioneer in terms of ethical business conduct. The further development and permanent establishment of such ethical conduct is an important task and therefore a component of the target agreements for Board of Management remuneration. Our business activities are also strongly guided by the ten principles of the UN Global Compact, of which Daimler is a founding member. We are also a member of the Global Compact LEAD Group.
In order to further develop a culture of integrity at the company, we also began conducting a continual dialogue with our employees in 2011. Integrity cannot be dictated from above; this is why the regular sharing of opinions on questions of integrity is an integral component of our everyday working life. We regularly address integrity issues in our internal media and make extensive integrity-related materials available on the intranet for use by all our business units.
The Integrity Code is a result of our dialogue with employees. The Code, which is based on a shared understanding of values agreed upon with our employees, lays out the principles for our everyday business conduct. Such principles include fairness, responsibility, mutual respect, transparency, openness, legal compliance and the honoring of rights. The Code is valid throughout the Group and is available in 23 languages. A guide has been prepared to support the application of the Code in everyday situations, providing answers to the most frequently asked questions.
Contact and advice center
In March 2015, we launched the “Infopoint Integrity” for the employees at our locations in Germany. The team offers advice on integrity-related issues in the daily work environment and puts employees in touch with the right contact partner if necessary.
Communicating with employees
By means of innovative dialog formats, our employees are encouraged to discuss the issue of integrity. For example, executives can use a toolbox to initiate discussions about integrity in their departments. Furthermore, more than 55,000 employees worldwide have participated in our online game “Monster Mission” since September 2014. The game increases employee awareness of the principles contained in the Integrity Code by simulating specific everyday work situations in which ethical behavior is required.
Extensive training program
The Integrity Code also forms the foundation of the range of training courses we offer. Our integrated training program is defined on the basis of an annual planning cycle that starts with a needs analysis, extends through the implementation of the program and ends with a feedback and monitoring process. Among other things, the program addresses the topics of integrity, compliance, data protection and antitrust law. Depending on the risk and the target group, we use classroom training or web-based training sessions. Our training measures help ensure that ethical and compliant behavior remain firmly and sustainably anchored within the Group. They also help employees deal with specific questions in their day-to-day business. Basic web-based training in integrity, compliance and legal issues is offered to our employees via the intranet. Every newly hired Daimler employee must complete this training session as part of a “Welcome Package” when they join the company. About 50,000 employees from various levels of the hierarchy participated in this training program in 2015.
Requirements for managers
Our Integrity Code also defines requirements for managers, who serve as role models and have a special responsibility for the culture of integrity. All training seminars for new managers therefore also include modules that address the topic of integrity. In addition, integrity and compliance are important criteria in the annual target agreements and in assessing the target achievement of our managers.
Advisory Board for Integrity and Corporate Responsibility
The Advisory Board consists of independent external experts from the fields of science, business, politics and journalism, and from non-governmental organizations. The Advisory Board regularly collects information on the company’s activities, conducts discussions with company representatives and monitors the integrity process at Daimler in a constructively critical manner.
We also promote discussions of issues of current importance to the company through our meetings with stakeholders. To this end, we organized a conference in 2015 under the heading of “Autonomous Driving, Law and Ethics.”
Daimler acts in conformance with ethical principles and adheres to all relevant legislation, internal rules and voluntary commitments. We place the utmost priority on complying with all applicable anti-corruption regulations and on maintaining and promoting fair competition, as is set out in our Integrity Code.
Compliance management system (CMS)
Our CMS is based on national and international standards and supports us in ensuring compliant behavior in our daily business. We continually review the effectiveness of the system, and we adjust it to worldwide developments, changed risks and new legal requirements. In this way, we improve its efficiency and effectiveness.
“Anti-Money Laundering Policy”
This policy is designed to prevent money laundering and the financing of terrorism in the trade with goods. It forms the basis for ensuring that legislation in various countries is complied with throughout the Group. The Chief Compliance Officer serves as the anti-money laundering officer of Daimler AG. A center of competence supports the Chief Compliance Officer with the management and coordination of money-laundering prevention measures in the goods trade.
Consistent compliance with sanction lists
Daimler takes appropriate measures to ensure that the legal sanctions specified by legislation are observed. Effective and efficient implementation has been ensured here by the introduction of a global system-based standard process.
Systematic minimization of compliance risks
We systematically analyze and assess the compliance risks of all our business units every year. The results of this analysis form the basis of our risk management. One focus of our risk minimization activities is on sales companies in high-risk countries. The responsibility for implementing and monitoring the associated measures lies with the management of each company, which cooperates closely with the Group Compliance department.
Effective compliance structures
Our Compliance Organization is structured along the lines of our divisions. This structure enables us to offer effective support and advice to the individual divisions. For this purpose, the organization consists of divisional and regional compliance officers. In addition, local compliance managers throughout the world make sure that our standards are observed. The divisional and regional compliance officers report directly to the Chief Compliance Officer. This ensures the divisional and regional compliance officers’ independence from the divisions. The Chief Compliance Officer reports directly to the Member of the Board of Management for Integrity and Legal Affairs and to the Chairman of the Supervisory Board.
We offer target group-specific training courses within our integrated training program in order to ensure compliance staff members remain up to date on the continual changes made to laws and regulations.
Whistleblower system BPO (Business Practices Office)
The BPO is the organization where Daimler employees and external whistleblowers can report misconduct anywhere in the world. The office is available to receive information around the clock and — if allowed by local law — also anonymously. This system enables us to learn about potential risks and specific violations at an early stage and thus prevent damage to the company and its reputation. Our globally valid corporate policy in this area ensures a fair and sensitive approach that takes into consideration the principle of proportionality and also gives protection to both whistleblowers and affected parties. In Germany, reports to the BPO can also be submitted via a “neutral intermediary” — an independent attorney who, due to her oath of professional secrecy, is obliged to maintain confidentiality.
Compliance at our business partners
We regard our business partners’ integrity and behavior in conformity with regulations as an indispensable precondition for trusting cooperation. In the selection of our direct business partners, we make sure that they comply with the law and observe ethical principles. Within the framework of our integrated training program, we also offer our business partners special training courses on integrity and compliance in line with the specific risks they face. We reserve the right to terminate our cooperation with business partners who fail to conform to our standards. For the expectations we place on our business partners, see also daimler.com/sus/obr.
Sharing experience of compliance in practice
We have designed the Daimler Compliance Academy as an annual practical seminar that creates a platform for sharing experience of compliance trends and challenges. The seminar, which took place for the second time in 2015, is directed at compliance professionals from all industries.
Our Group-wide antitrust-compliance program, which is oriented toward national and international standards, helps us to ensure adherence to antitrust laws in our business operations. By assessing qualitative and quantitative factors, we systematically analyze the antitrust risks of all our business units. The results of this analysis form the basis of our risk management and of the definition of the measures to be taken to counteract any risks related to antitrust law.
We help our employees to recognize situations that might be critical from an antitrust perspective and to act in compliance with regulations in their daily work by means of training courses, as well as with written advice and practical examples. Our employees also have access to an advisory hotline established by the Legal department for questions on antitrust and cartel matters. Our antitrust-compliance program defines a binding Daimler standard on how matters of competition law are to be assessed internally. In this context, we focus in particular on the strict standards of the European antitrust authorities and courts. Our standard is the basis for effective implementation of the program and allows us, guided and supported by our Legal department, to ensure a uniform level of compliance and advice throughout the Group. We regularly review our antitrust-compliance program in order to continually adapt it to worldwide developments, new legal requirements and changing risks, and to constantly improve its effectiveness.