Annual Report 2019

For us, technical compliance means adhering to technical and regulatory requirements, standards, and laws while taking into account the fundamental spirit of these laws and regulations as well as adhering to internal development requirements and processes. In order to address the specific risks associated with the product creation process, we combined the existing systems and additional measures and processes at the Daimler AG automotive divisions into a technical Compliance Management System (tCMS). The purpose of the tCMS is to safeguard legal and regulatory conformity during the entire product development and certification process and to provide orientation and guidance for our employees by defining specific values, principles, structures, and processes.

The tCMS is managed Group-wide by an independent governance body whose director reports directly to the Board of Management member for Integrity and Legal Affairs. This body consists of employees with expertise in various fields, such as development, legal affairs, integrity and compliance. In order to provide optimal support to the divisions, the independent governance body has a divisional structure. The governance body’s tasks include the design of the technical Compliance Management System and the provision of legal advice to the divisions.

We have also created dedicated expert units for technical compliance in the development departments at our vehicle-related divisions. Among other things, these units manage a network of technical compliance contact persons at development and certification departments. This network serves as a link between operating units and the compliance organization and also supports the development departments in matters of technical compliance. Complex questions regarding technical compliance are evaluated and then decided in an interdisciplinary process that takes into account technical, legal, and certification-relevant criteria. Our BPO whistleblower system is also available as a contact partner for reporting technical compliance violations.

During the year under review, the Daimler AG Board of Management adopted the tCMS policy. It describes key tCMS elements and defines the roles and responsibilities of all relevant functions. Process descriptions and rules of procedure for tCMS committees in Group companies in scope of application of the tCMS have been drawn up for relevant tCMS elements. The tCMS policy applies to all Group companies worldwide that conduct relevant development and certification activities.

We have made use of various communications measures such as “Tone from the Top” mailings and special training courses and dialog sessions in order to sensitize employees at development and certification units at all divisions to issues relating to technical integrity, compliance, and legal regulations in the product creation process.

Further information on communication and training: »Compliance«

The Technical Integrity initiative, as part of the tCMS, focuses on strengthening awareness of the importance of responsible behavior during the product creation process, particularly in situations where legal provisions may be unclear. Together with the relevant development departments, we have supplemented the provisions of the Integrity Code by formulating so-called commitment statements that support employees and offer them guidance for ensuring proper conduct in their daily activities. These principles have been discussed with employees at dialog sessions held around the world. Various communications measures regarding the commitment statements have been made known to all employees and were anchored in selected training courses.

We also conduct in-depth discussions on safeguarding technical compliance with business partners and selected suppliers. In October 2019, for example, we held a Supplier Dialog event with relevant suppliers. This event was attended by executives, technical compliance managers, and technical project managers from participating supplier companies. Among other things, the objective here was to make suppliers more aware of the regulatory framework, provide them with information on how Daimler safeguards technical compliance, and explain to them what we expect from our suppliers in this regard.

The effectiveness of our tCMS is monitored in the annual monitoring-process. Measures identified by this process will be considered in the improvement of the tCMS and are addressed for implementation.