Integrity, compliance and legal affairs

For Daimler, integrity, compliance and legal responsibility are inseparable from our daily business activities. We are convinced that only those who act responsibly can achieve sustained success over the long term. For us, this involves more than just obeying laws, as we also seek to align our activities with shared principles and values.

Organizationally established at the highest level

Because of their strategic significance, we have combined the responsibilities for integrity, compliance and legal affairs within a single Board of Management area. This Board of Management area supports the divisions and units in their efforts to ensure that those issues remain an integral component of their organizations. We view integrity and compliance as firm elements of our corporate culture and daily business activities that contribute to our company’s lasting success. The basis for this is our Integrity Code, which defines guidelines for our everyday business conduct, offers our employees orientation, and helps them make the right decisions even in difficult business situations. The Integrity Code is supplemented by other in-house principles and guidelines.

A culture of integrity

Integrity is one of the four corporate values that form the foundation of our business activities. For us, integrity means acting in accordance with ethical principles. We therefore aim we not only  to comply with all applicable laws, internal regulations and voluntary commitments, but also to live in accordance with our corporate values and not to shy away from making difficult decisions or addressing critical issues. We expect all of our employees and business partners to adhere to the principles of our culture of integrity out of a sense of conviction.

During the year under review, we focused in particular on the strategic further development of our culture of integrity, taking recent developments in society into account as well. Implementation of the measures we derived as a result will begin in 2019. In 2018, we also designed and conducted a pilot survey to assess the effectiveness of our integrity-related measures and develop them further on this basis. Another survey to be conducted in 2019 will build on our progress here and allow us to target our activities toward specific groups and continuously improve the programs we offer.

Integrity management organization

The task of Integrity Management is to support all departments with the promotion and further development of the culture of integrity at the Daimler Group. The unit’s experts for change management, corporate responsibility management, training, consulting and communication develop innovative and employee-focused approaches and formats that are designed to strengthen the culture of integrity. These experts also support disseminators throughout the Group with their integrity-related activities. The unit’s goal is to establish and maintain a common understanding of integrity in order to reduce risks and help ensure Daimler’s sustained success. The Head of Integrity Management reports directly to the member of the Board of Management responsible for Integrity and Legal Affairs.

Integrity Code

Our Integrity Code forms the foundation of our business conduct. It is based on a shared understanding of values, which we developed with our workforce in employee dialogs. It lays out the principles governing our everyday business conduct. These central principles include compliance with laws, as well as fairness, responsibility, mutual respect, transparency and openness. The Code is binding on all companies and employees of the Daimler Group and is available in 23 languages. A guide is available on the Group’s intranet to support the employees in their application of the Code in everyday situations, providing answers to frequently asked questions. (See daimler.com/documents/sustainability/integrity/daimler-integritycode.pdf)

Requirements for executives

Our Integrity Code also defines requirements for executives and managers, who are expected to serve as role models in terms of ethical behavior and to provide employees with orientation. For optimal support with the fulfillment of their responsibilities, they participate in a web-based Integrity@Work training program that includes a management module compulsory for all management staff. It explains in detail the role of executives and managers at Daimler with regard to integrity, compliance and applicable law. Furthermore, selected seminars designed to enhance the qualifications and skills of our management staff also include modules that focus on integrity.

Integrity and compliance requirements are important criteria for the target achievement of our executives. They are also part of the agreed objectives for the remuneration of the Board of Management. (See Remuneration Report)

Contact and advice center

Our “Infopoint Integrity” is available to our employees around the world as a central contact and advice center. The Infopoint team offers advice on integrity-related issues in the daily working environment and puts employees in touch with the right contact partner if necessary. A worldwide network of local compliance and legal contact persons is also available to our employees.

Communication measures

We conduct an ongoing open dialog with our employees in order to ensure that ethical behavior continues to be embedded in the company’s daily business. We regularly address integrity issues in our internal media and make a wide range of materials available to our business units – for example brochures, films and an app that provides information on integrity, compliance and legal affairs. We also place great value on face-to-face discussions. For this reason, we regularly conduct individually designed dialog sessions with employees at all levels of the hierarchy, as well as with external stakeholders. These sessions are held both in Germany and at our locations abroad.

We use various event formats to get employees to think about integrity by approaching the issue from different perspectives. At these events, we also increase the participants’ awareness of the importance of making ethical decisions. For example, we present case studies that enable employees to experience and discuss the relevance of integrity to daily business operations from various viewpoints. We also have a network of integrity contact persons who help the business units address specific issues in a targeted manner. One of the things we focused on in 2018 was dialog sessions that addressed the topic of technical integrity in the development departments of our various divisions. We are also providing more support to our business units with regard to ethical questions related to the responsible use and management of data and the challenges associated with data-based business models.

Compliance and legal responsibility

Value-based compliance is an indispensable part of our daily business activities at Daimler. For us, compliance means acting in accordance with laws and regulations. Our objective here is to ensure that all of our employees worldwide are always able to carry out their work in a manner that is in compliance with applicable laws, regulations, voluntary commitments and our values, as set out in binding form in our Integrity Code. Our compliance activities focus on complying with all applicable anti-corruption regulations, the maintenance and promotion of fair competition, adherence to legal and regulatory stipulations regarding product development (technical compliance), respect for and the protection of human rights, adherence to data protection laws, compliance with sanctions and the prevention of money laundering. Our compliance and legal organizations are designed to ensure that they can advise and support all of our corporate units worldwide with regard to their business operations, processes and services in order to minimize legal and business risks.

Our Compliance Management System (CMS) serves as the foundation

Our Compliance Management System (CMS) is designed to prevent inappropriate or illegal behavior by Daimler and its employees, and our culture of integrity serves as the foundation for this approach. The measures needed for this are defined by our compliance and legal affairs organizations in a process that also takes business requirements into account. Our CMS consists of basic principles and measures for the promotion of compliant behavior throughout the Group. It is based on national and international standards and is applied on a global scale at all units and majority holdings of Daimler AG. The systematic minimization of compliance risks is extremely important here, and for this reason we analyze and assess the compliance risks of all our business units every year. These analyses are based on centrally compiled information on all business units; specific additional details are taken into account if necessary. The results of the analyses form the basis of our risk management. More detailed information on the Daimler Compliance Management System can be found in the Non-Financial Report section of this Annual Report. (See Compliance)

In order to ensure an independent external assessment of our Antitrust Compliance Program, KPMG AG Wirtschaftsprüfungsgesellschaft audited the Compliance Management System for antitrust law in accordance with Audit Standard 980 of the Institute of Public Auditors in Germany. This audit, which was based on the principles of appropriateness, implementation and effectiveness, was already successfully completed at the end of 2016.

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