Daimler created a central compliance organization, known as Group Compliance, many years ago. It is integrated into the Board of Management's "Integrity and Legal Affairs" unit and is managed by Chief Compliance Officer Olaf Schick. 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 Audit Committee. Organizationally, the division is focused on Daimler's business units. Divisional Compliance Officers help the Mercedes-Benz Cars, Daimler Trucks/Vans/Buses and Daimler Financial Services business units to assume responsibility for compliance in daily business and take appropriate risk prevention measures. Furthermore, with our compliance organization we have taken into account the significance of the Asian market by appointing a Regional Compliance Officer for China and Northeast Asia in 2012. There are also local compliance contacts around the world to ensure that our standards are met.
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.
Compliance Key Aspects
Preventing and fighting corruption is a top priority for Daimler. However, compliance is not just limited to anti-corruption measures. Instead, compliance requires responsible conduct from every individual, in accordance with all significant laws, voluntary commitments and our internal policies.
To ensure and promote compliance, managers and employees receive extensive training in our global training program for integrity and compliance. This gives employees the tools for making right decisions in difficult situations while minimizing risks.
In 2013, we rolled out a web-based training about the understanding of our shared values and our ethical principles worldwide for more than 100,000 employees. Almost 40,000 additional employees from various management levels completed a comprehensive web-based training in 2014 about integrity, compliance and legal issues.
One area of focus, for example, is to show employees how to avoid damage to assets and the company's image that could arise from corruption, fraud, embezzlement, antitrust violations or money laundering offenses. We also explain the basic principles of our company and train our employees on such topics as environmental protection, labor standards and product safety.
Since March 2015 the German locations have had a central point of contact and advice for employees with questions on integrity. The "Infopoint Integrity" also helps with other questions and gives referrals to the right contact person.