With the following measures, the Executive Board has implemented a compliance management system designed to address the company’s relevant risk exposure: An external compliance agent has been appointed who reports directly to the Executive Board. A newly created internal coordination body will support the external function. The employees have received the contact data of the external compliance agent thus allowing and encouraging a direct approach.
This is also being put into practice. In view of the already well-established trustful communication between employees, superiors and the external compliance agent the Executive Board took the conscious decision to refrain from implementing a special whistleblowing unit.
In order to determine the risk situation as relates to „Compliance“, the Executive Board first had a risk analysis of potential compliance risks carried out by an auditing company. This analysis comprised the risks of the company as well as the risks of the individual group companies. The implementation of a compliance guideline obligatory for all employees was a significant step. This guideline has been and will be communicated through face-to-face training (train-the-trainer approach). The external compliance agent will check compliance on a random basis and provide the relevant reports to the Executive Board.
Furthermore, depending on the importance of the respective matter, certain reporting lines have been established to make sure that the Executive Board and/or the next subordinate management tier are informed about significant matters and, in particular, potential compliance risks. In addition thereto, clearance rules for certain kinds of measures and legal transactions have been implemented. This is to ensure that important or risky measures or legal transactions are only carried out after having obtained the approval of the Executive Board and/or the next subordinate management tier. Adherence to the reporting line provisions and clearance rules has to be documented.