DB Schenker Logistics

Transcription

1 Logistics DB Schenker Logistics Customer Information DB Schenker Logistics Sandra Wolski Corporate Risk Management & Compliance Essen June 2013

2 The code of conduct contains binding standards and the expectations we place on our day-to-day behavior Code of Conduct Corporate Social Responsibility Human Rights Child Labor and Forced Labor Equal Opportunities Occupational Health and Safety Environmental Protection Safety Cooperation Conduct toward our Competitors, Public Officials & Business Partners Corruption Behavior towards Public Officials Consultants / Agents / Brokers Competition and Cartel Law Donations / Sponsoring Conduct of all Employees Responsibility to our Owners Behavior in Public Confidentiality Avoiding Conflicts of Interest Invitations and Gifts Protection of Company Property Reporting Insider Trading Data Protection Money Laundering DB Schenker Logistics Sandra Wolski June

3 Integrity is the key success factor of our compliance program which is based on awareness and trust Integrity as Key Success Factor Core Compliance Topics Business success does not justify breaking the law. Compliance works together with the business units to ensure adherence to rules and regulations within the DB and DBSL Group. The DB Schenker Logistics Group has to adhere to a steadily growing number of national and international regulations. We can only prevent incidents if all employees in the business and organizational units act with integrity and comply with internal and legal requirements. Maintaining an adequate and efficient Compliance program is based on prevention, detection, and response. Our program is based on compliance awareness and mutual trust. We strive for continuous remediation and improvement of compliance related processes. Anti-Bribery / Corruption DB Group and DB Schenker Logistics will not condone corruption and unfair business practices by employees or third parties commissioned by us. Compliance to Anti-Bribery regulations and international standards is a principle for our actions Anti-Trust We abide by the applicable competition regulations. Compliance to Anti-Trust regulations is a principle for our actions Denied Party / Sanction List Since 2005 in-house procedures are in place and have constantly been developed to prevent DB Schenker Logistics from entering into or maintaining business relations with any person or legal entity considered as denied party according to international and national legislation emerging from UN resolution 1373/2001 and 1390/2002 Trade Embargos Trade Embargos are subject to continuous changes. Observing trade embargos and advising operations about the current embargoes is a core area of responsibility of DB Schenker Logistics Compliance DB Schenker Logistics Sandra Wolski June

4 Our compliance elements management system is based several core Compliance Structure and Program Compliance objectives and structures have been formulated in a Standard Operating Procedure for Compliance. The compliance organization formulates the program in order to achieve the compliance goals. Communication and Training Continuous communication and training measures support compliance awareness and culture. Business Partner Compliance Business partners are analyzed and bound to high standards of ethics and compliance (roll out started). Compliance Risk Assessment The compliance risk assessment is part of a holistic risk management process. Mergers and Acqusition Compliance Post Merger Integration Plans support the implementation of compliance standards in new entities. Auditing and Process Reviews InternalAudits and Process Reviews constantly improve the Compliance Management System. Customer Compliance A customer compliance process ensures that customer compliance needs are met. Whistleblowing / Case Management A global accessible call-center and online system can process hints and investigations (under development). Monitoring and Reporting Reporting processes on compliance incidents and KPI s are defined and constantly monitored. DB Schenker Logistics Sandra Wolski June

5 We promote compliance within our organization by face-toface workshops and comprehensive web-based trainings Example: e-learning Portal Compliance Trainings Mandatory e-learning modules Code of Conduct Integrity Anti-Trust Mandatory Code of Conduct discussions for each team with their line manager Additional face-to-face anti-trust workshops with expert attorneys for competition law from Deutsche Bahn and Schenker for key personnel Relevant target groups for the trainings are determined with respect to the employee s function New training concept with additional faceto-face ethics and compliance trainings by line managers is under development and will be rolled out in DB Schenker Logistics Sandra Wolski June