The basis for our compliance program and ongoing risk control is a group-wide, systematic risk analysis in all business units. Qualitative and quantitative factors are evaluated, such as the corresponding business model, relevant general conditions and the type of contract party relationships.
Another key component of our compliance program is reviewing the integrity of our business partners. We use these reviews to identify risks around the world and respond with our partners appropriately to potential problems. We feel that acting with integrity and complying with the rules is an absolute must for trusting cooperation that succeeds for the long term.
We define measures along with our business units to minimize risks. This includes, for instance, a comprehensive information and training program on integrity and compliance. One focal area of our activities is on sales companies in high risk countries. Our goal is to promote compliance while preventing misconduct, particularly corruption.
Our BPO (Business Practices Office)
whistleblowing system helps us to protect the company from damage. It is a useful source of information for potential risks and specific rule violations. The BPO receives tips on misconduct from employees and external parties around the world. In order for the system to gain acceptance, it must be designed fairly, follow the principle of proportionality and protect whistleblowers and affected persons alike. We defined these criteria in a globally applicable corporate policy in 2013. Whistleblowers can contact the BPO 24/7 using various reporting channels and, if permitted under local laws, they can remain anonymous. Since February 1, 2012, we have also had the Neutral Intermediary
office in Germany, staffed by an independent attorney. The Neutral Intermediary also receives tips about rule violations and is professionally sworn to confidentiality as an attorney.