Integrity and Compliance

Daimler wants to do decent business, and in both senses of the word: We aim to be financially successful – but not at any price. We want to achieve our business success with decency, in other words, by respectable means. Integrity is therefore one of our four corporate values, which form the foundation for our business activities. We are convinced that doing business decently brings us sustained success, and is also good for society as a whole. As a group with global operations, we accept responsibility and want to be a pioneer in terms of ethical business conduct.

UN Global Compact. We orient our business conduct towards the principles of the Global Compact of the United Nations. Daimler is a founding member of this initiative by Kofi Annan and is a member of the LEAD Group. (See Corporate Governance Report)

Group-wide “Integrity Dialog” and revision of the Integrity Code. Our goal is to permanently establish integrity in our corporate culture. But ethical principles cannot simply be dictated. They must be put into practice on the basis of an inner conviction. Daimler therefore promotes integrity through a variety of measures and through continuous dialog on the subject. (See A matter of Integrity) Our new “Integrity Code” that we created in 2012 reflects the results of our Group-wide “Integrity Dialog”. The principles of behavior and guidelines for everyday conduct set out in the Integrity Code are therefore based on a shared understanding of values. (See Corporate Governance Report)

Creation of the Advisory Board . For the course we have set to achieve a culture of integrity at the Daimler Group, in addition to the numerous measures we have already taken, we also regard a view from outside as helpful. We have therefore established an »Advisory Board for Integrity and Corporate Responsibility« to support the integrity process at Daimler critically and constructively. We have been able to gain external personalities from various fields with valuable experience in questions of ethical conduct. (See A Matter of Integrity)

Integrity goes beyond what we at Daimler understand by compliance. Integrity is more than adherence to the law, internal rules and voluntary commitments. We understand integrity to include acting responsibly and in accordance with ethical standards, through which we not only secure our company’s success for the long term, but also create benefits for society.

Compliance is the sustained establishment of conduct in conformance with rules. Our compliance-management system is intended to ensure that Daimler and its employees always conduct themselves in conformance with rules. Complying with anti-corruption regulations as well as maintaining and promoting fair competition have the highest priority for the Daimler Group and serve as a benchmark for our staff and management. To give further emphasis to this goal, compliance and integrity are taken into consideration in our executives’ annual target agreements and assessments of target fulfillment. Particular attention is paid to individuals’ correct conduct in conformance with rules and ethics.

Worldwide establishment of divisional compliance organization. In order to effectively counteract the risks of our divisions and markets, we have altered the structure of our compliance organization in line with our divisions. Each division is now supported by a compliance officer. In addition, a regional compliance office was established in China in 2012, reflecting the special importance of the Chinese market. Furthermore, local compliance managers are active worldwide, advising on matters of compliance and ensuring observance of our compliance standards.

In order to guarantee their independence of the divisions, the compliance officers for the divisions and the compliance manager for the region of China and Northeast Asia report to the Group Chief Compliance Officer. He is responsible for the entire global organization and reports directly to the Member of the Board of Management who is responsible for »Integrity and Legal Affairs«.

Analysis of compliance risks. Dealing with risks responsibly and assessing them effectively is a precondition for sustained business success. We therefore evaluate and classify compliance risks in a systematic risk analysis. We apply qualitative indicators such as an assessment of the business environment as well as quantitative indicators such as relevant shares of revenue and the number of contractual partners. In line with the risk assessment carried out in this way, measures are then defined jointly with the business units to minimize the recognized risks. Against this backdrop, for example, our sales activities in countries with an increased risk of curruption are subject to particularly intensive risk management. Responsibility for implementing the individual measures and the monitoring duty lie with the management of each business unit. This is supported by the Group Compliance department.

Further development of the compliance processes. The focus of compliance activities in 2012 was on examining our business partners in the sales process (sales business partner due diligence). We apply high standards in the selection of our sales and business partners and expect them to act in accordance with our compliance rules and ethical principles. Based on a standardized risk assessment carried out in advance, the divisions decide, in addition to the specific risk factors, on the appropriate intensity for examining the respective business partner. The divisions carry out the examination in their own responsibility and with support from the Group Compliance department.

Stronger whistleblower system and Business Practices Office (BPO). A functioning whistleblower system is an important source for us to recognize risks and infringements of rules. Information on possible serious infringements by employees and external parties is passed on to the BPO. In 2012, the management and employee representatives reached a company agreement on the reorganization of the Daimler whistleblower system. This agreement sets out a fair, transparent process affording equal protection to whistleblowers and the other persons involved. Furthermore, in addition to the existing reporting channels, in Germany we have commissioned an independent lawyer as a neutral mediator, who also accepts information on violations of rules. Due to his professional obligation to maintain confidentiality, it is assured that the whistleblowers remain anonymous vis-à-vis Daimler.

Compliance training and communication. The regular provision of information and targeted training courses supplement and support the effective and sustained anchoring of correct conduct at Daimler. We carry out face-to-face trainings for specific groups of employees as well as web-based trainings. We also offer these trainings to our business partners and sales partners, so that they can familiarize themselves with our ideas of integrity and compliance. In those courses, we train participants for example on the principles of corruption prevention and on competition law. Since 2010, we have trained more than 100,000 employees in business units and departments with a special risk situation using web-based courses and presence events. The focus was on employees in sales and sales-related functions.

6.01

Members of Daimler AG‘s Advisory Board for Integrity and Corporate Responsibility
   
Name Function
   
Stefan Aust Journalist, publicist and author
Professor Kai Bussmann
 
Head of Economy & Crime Research Center, Martin-Luther-Universität, Halle-Wittenberg
Professor Helmut Holzapfel
 
Head of the Department for Integrated Traffic Planning and Mobility Development, University of Kassel
Renate Hornung-Draus
 
Managing Director of the German Employers‘ Association (BDA), Head of the Department of the European Union and European Social Policy
Professor Michael Kittner
 
Former Professor of Business, Labor and Social Law, University of Kassel and legal advisor for IG Metall
Professor Julian
Nida-Rümelin
Professor for Philosophy, Ludwig Maximilian University, Munich
 
Pierre Sané Board Member, UN Global Compact
Sylvia Schenk
 
Attorney in Frankfurt, Board Member of Transparency International Germany and German Olympic Academy
Professor Dr. rer.nat. Ernst Ulrich von Weizsäcker Environmental scientist, Climate expert and former Member of the Bundestag