Compliance instruments

Specific compliance instruments have been developed to protect DB Group, its employees and executives. This includes binding compliance directives, risk and process analyses, a compliance reporting system, training and communication measures, and a whistle-blower management system.

The DB Group Code of Conduct is the cornerstone of our CMS. It defines the standards and expectations about how our bodies, executives and employees should conduct themselves on a daily basis. It is supplemented by binding directives that specify applicable legal provisions governing natio­­nal and international business and contact with customers. It is essential that DB Senior Management leads by example. In the year under review, a high-ranking disciplinary committee was set up to sanction misconduct among Senior Management. It supplements the Compliance Committee, which deals with tip-offs regarding serious legal violations that are of major concern to the Group.

Compliance risk analyses are a key component of DB Group risk management and are conducted by the business units and service units. A Group-wide survey of compliance risks is conducted in accordance with governance requirements set by corporate management. The compulsory framework concept contains minimum requirements for planning and conducting the survey, as well as reporting and follow-up.

A compact compliance annual report provides the Management Board with information on compliance risks related to DB Group’s business activities.The report separately sets out the risk exposure of business units, service units and corporate management functions and highlights existing risk-reducing factors and countermeasures. The Management Board is also kept regularly informed during the year about the further expansion of the compliance program and any significant compliance cases. The CCO also reports on compliance issues at meetings of the Supervisory Board’s Audit and Compliance Committee.

We are continually optimizing our instruments so that we can achieve our compliance goals on a sustainable basis. As part of the “Initiative for a strong compliance organization,” particular emphasis was placed on two measures. Using several small films, the new compliance communication campaign highlights how important the principles described in our Code of Conduct are for all DB Group employees. In addition, a new mandatory training program was designed primarily for Senior Management in DB Group. This supplements the well-established compliance coaching run by the heads of the Group’s Compliance, Audit and Legal functions.

The compliance awareness plan takes a risk and needs-based approach, which determines the order in which all executives and employees are to be trained. By holding in-person events or conducting e-learning sessions, it is possible to train almost all managers and employees who either need to be trained or are exposed to medium and high risk, over a period of two to two and a half years. In the year under review alone, more than 39,000 executives and employees attended in-person events on preventing corrup­tion. The new e-learning modules developed during the previous year were also extensively used. Together with the e-learning modules developed specifically for DB Schenker and DB Arriva, about 81,000 e-learning units on preventing corruption were completed.

There is a Group-wide whistle-blower system to obtain information about potential violations of laws or internal regulations. The way in which submitted tip-offs are handled is regulated in detail. The processes implemented protect whistle-blowers. In addition to other measures, clearly de­fined requirements regarding the rigor and relevance of whistle-blowing tip-offs serve to take account of the interests of the persons concerned.

There are various ways of submitting a whistle-blowing tip-off. These include three trusted legal practitioners, who are legally bound to secrecy, and an ombudsperson, in addition to the compliance teams in the corporate management, business units and service units. There is also a Group-wide electronic whistle-blower system, which makes it possible to submit tip-offs anonymously. It can be used in 22 languages and is not just available to employees, but customers, suppliers and other stakeholders, too. In the year under review, tip-offs in the double-digit range were received through the whistle-blower system for instances of corruption.

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