All employees are called upon to report compliance violations to their supervisor, Legal, HR or other relevant departments. A central reporting system (speak-up line) was set up, meaning employees can report compliance violations by telephone or via a web-based application, anonymously if desired. The reports received are individually reviewed by the GCO. If a compliance violation exists, corresponding corrective action is taken based on concrete action plans. If necessary, disciplinary measures are taken. These range from a simple warning up to the dismissal of the employee who violated a compliance rule. In 2009 and 2010, respectively, 14 and 21 compliance related reports were received via the speak-up line. In three cases each year, the accusation of a violation of our rules of conduct was confirmed. This resulted in the dismissal of two employees and labor law-related measures against four other employees.
In connection with the reports received during the reporting period, the control and monitoring processes were analyzed, training courses and process optimizations were initiated, and measures were taken to minimize risk. In 2010 we started improving our Compliance Risk Monitoring & Reporting system by developing a concept for Compliance-internal risk analysis and evaluation. This system will be implemented in 2011. A generic compliance program was developed as a model for implementing a compliance framework in the subsidiaries. It places basic organizational and systemic requirements on the local units. Implementation will start in 2011.
