Deutsche Post DHL Group – Our Compliance Definition
Compliance management at Deutsche Post DHL Group comprises rules, standards and processes intended to ensure laws and policy requirements are observed within the Group.
By emphasizing a value and risk-oriented approach, our compliance management promotes correct behavior and the social legitimacy of our mission.
Compliance is embedded consistently in the Group at the global, regional and country level.
The law and our Code of Conduct as well as other internal policies require Deutsche Post DHL Group's management and employees to comply with the applicable regulations. As one of the leading global companies in its industry, Deutsche Post DHL Group is also faced with increasing demands from its investors, customers, business partners and employees. In order to address potential compliance challenges and risks, we have established the Deutsche Post DHL Group CMS.
To foster compliance, Deutsche Post DHL Group implemented its Group-wide Anti-Corruption and Business Ethics Policy as early as in 2009 which prohibits improper, unethical or illegal action and promotes the performance of due diligence on major sub-contractors, joint venture partners and careful evaluation of our representatives, agents and consultants providing important elements of our services.
The Competition Compliance Policy (also introduced in 2009) contains rules on how to compete fairly and openly in the marketplace.
Our managers serve as role models. We expect them to lead by example in both behavior and values, foster both the corporate culture and the principles of Deutsche Post DHL Group in everything they do, and communicate these values to our business partners. Through targeted communication and regular training, we help our employees and business partners to both understand and adhere to our compliance policy and rules. We also encourage our employees to be alert to compliance violations and to report them through various internal channels, including our dedicated Compliance Hotline. Compliance is thus an integral part of our corporate culture and is lived out at all levels of the Group; its cornerstone is the Group's Code of Conduct.
Compliance is a management responsibility and is thus overseen by all management bodies within the Group. Responsibility for designing the compliance management system lies with the Chief Compliance Officer, who reports directly to the Chief Financial Officer. The Chief Compliance Officer is assisted by the Global Compliance Office, which establishes Group-wide standards for compliance management and supports the corresponding activities of the divisions.
Each of the four operating divisions has a Compliance Officer who can draw on additional local resources and regularly presents a report to the divisional Board of Management. The activities and the content of the reports drawn up by both the divisional Compliance Officers and the Global Compliance Office are incorporated into the quarterly update reports to the Board of Management as well as the annual report to the Finance and Audit Committee of the Supervisory Board.
The continuous assessment and evaluation of our company-specific risk profile in an integral part of our compliance management system; the system focuses on antitrust and competition law, bribery and corruption, as well as fraud and embezzlement for purposes of self-enrichment.
Based upon the assessment of Deutsche Post DHL Group's compliance risks, principles and measures were introduced to curb compliance risks (e.g., business partner screening) and thus to avoid compliance violations. The Group is highly selective in its choice of qualified and ethical business partners. The Deutsche Post DHL Group Anti-Corruption and Business Ethics Policy contains criteria when to perform due diligence on sub-contractors, joint venture partners, representatives, agents and consultants providing important elements of our services. A Supplier Code of Conduct has been established in co-operation with Corporate Procurement to ensure that our suppliers and vendors understand Deutsche Post DHL Group's expectations for those who are acting on the Group's behalf.
The Compliance Program also includes measures to identify and deal with compliance violations (incident management).
Each employee affected and relevant third parties are informed of Deutsche Post DHL Group's Compliance Program so that they can understand and meet their functions in the CMS sufficiently. A specific online training program was developed to educate relevant target groups regarding the Group's general integrity standards as well as more specific topics such as corruption and competition law aspects.
The structure of the compliance organization, the Compliance Program tailored to Deutsche Post DHL Group's needs, and additional measures to avoid compliance risks are derived from the results of the compliance risk analysis and compliance audits.
Any compliance violations discovered are also used to continuously develop and improve the compliance system. This enables Deutsche Post DHL Group to ensure that its integrity and Compliance Program is sustainable.