Targets and management approach

Compliance is an integral element of the corporate culture at DB Group. The Compliance Management System (CMS) is based on national and inter­national legal requirements and established standards, such as the Institute of Public Auditors (Institut der Wirtschaftsprüfer; IDW) auditing standard IDW PS 980 in Germany. DB Group also applies the directive of the Federal Government on corruption prevention in the German Federal administration. The CMS aims to ensure that compliance risks are identified at an early stage and appropriate countermeasures are implemented. We continuously monitor the effectiveness of our Compliance Management System and make any necessary adjustments. Compliance is one aspect of controlling within the Internal Control System (ICS). Intra-­Group auditors therefore review the CMS within DB Group as part of the ICS audits under the German Account­ing Law Modernization Act (Bilanzrechtsmodernisierungsgesetz; BilMoG). We also have our CMS checked externally.

DB Group compliance management is typified by a combination of cen­tralized and decentralized units at the operational and organizational levels. The Chief Compliance Officer (CCO) manages the further development of our CMS and reports directly to the Chairman of the Management Board. He is assisted in his duties by more than 200 employees responsible for compliance issues. Group management focuses its compliance work on centralized governance activities in particular, while operational responsibility is exercised in the business units and service units. Various event formats ensure that central and decentralized compliance officers can share their expertise and experiences in depth, such as the international conference held in the year under review.

Our compliance activities in DB Group focus on preventing corruption and corporate crime in the form of fraud and embezzlement, as well as consistently combating it.