Targets and management approach

Compliance is an integral element of the corporate culture at DB Group. The Group Management Board approved an initiative for a strong compliance organization aimed at further developing the Compliance Management System used in DB Group to keep it at the cutting edge and to develop effective compliance practices for the long term. The topic of compliance has been made even more visible in this context as it has been embedded in the Strong Rail strategy.

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 CMS and make any necessary adjustments. Compliance remains a component of the internal control system (ICS), even after its revision in the year under review. 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. The CCO is assisted in his duties by more than 250 employees responsible for compliance issues. Corporate management focuses its compliance work on centralized governance activities in particular, while operational responsibility is exercised in the business units and service units.

Various formats ensure that central and local compliance officers can engage in extensive dialog. In 2020, the digital dialog formats for this were made more robust. This includes revising the Compliance Cockpit, the central working platform for all employees in compliance functions.

The impact of the Covid-19 pandemic led to further emphasis on compliance during the year under review, as demonstrated, for instance, by a new focus on risk analysis and advice from compliance officers regarding a change in processes due to the pandemic. A key area was the proper use of third-party funds. There were also a greater number of questions about how to handle donations, which were answered.

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