Implementing an effective compliance management system (CMS) is the responsibility of the Executive Board, which is supported by a Group-wide compliance organization. This organization consists of compliance officers at all levels of the corporate structure and reports directly to the Compliance Board, which consists of the Chief Executive Officer, Chief Financial Officer, Chief Human Resources Officer and Group Head of Legal.
Acting as direct points of contact for employees on-site, local compliance officers support the implementation and continuous improvement of the compliance management system. Their main focus is on communication measures, training and the processing of compliance reports. Serious violations are reported through a mandatory compliance reporting process. This specifies how reports are to be passed from the compliance officers of the functional and local organizational units to the Group Compliance Officer and on to the Compliance Board.