COMPLIANCE AND HUMAN RIGHTS AT THE BMW GROUP.
Driving the right way.
The BMW Group’s corporate culture is characterized by clear responsibility, mutual respect, and trust. Lawful conduct, fair competition, and respect for human rights are integral to our business activities and an important condition for securing the long-term success of our company. Our primary goal is to avoid risks that could jeopardize the trust our customers, shareholders, business partners, and the general public place in the BMW Group. For this purpose, the BMW Group has established a Compliance Management System equipped with instruments and measures to help associates handle legal risks.
Lawful conduct and fair competition are vital to the long-term business success of the BMW Group. They create a basis of trust for our relations with customers and business partners.
BMW GROUP LEGAL COMPLIANCE CODE.
Our company-wide network.
The BMW Group Compliance Committee comprises the heads of the Legal Affairs/Patents, Corporate and Governmental Affairs, Corporate Audit, Group Reporting, Organizational Development, and Corporate HR departments, and is the highest authority in the BMW Group Compliance Organization. It manages and monitors the activities necessary to avoid non-compliance with the law, and reports on a regular basis to the Board of Management and Supervisory Board of BMW AG on all compliance-related issues at the BMW Group.
The BMW Group Compliance Committee Office is made up of 21 staff members based at the Group’s Munich headquarters. It lays the conceptual groundwork for the decisions of the BMW Group Compliance Committee and implements them accordingly. Its tasks are divided into “Group Compliance Programs” (design of prevention measures), “Group Compliance Operations” (support and mentoring of markets), and “Group Compliance Controls” (development and implementation of control measures). The BMW Group Compliance Committee Office is assigned to the Chairman of the Board of Management for organizational purposes.
The BMW Group’s Compliance Network comprises around 240 BMW Group Compliance Responsibles (heads of local units) and around 80 Local Compliance Officers (heads of local Compliance Functions). This international network is supported by Regional Compliance Managers based at headquarters in Munich within the “Group Compliance Operations” organization.
Compliance Management System.
The BMW Group Compliance Management System includes a large number of instruments to support compliance with legal requirements. These apply to all BMW Group units worldwide. Where additional compliance requirements exist in individual countries or business units (e.g. Financial Services), these are met by applying local or business-specific compliance regulations and instruments.
Tailored to the BMW Group’s specific risk situation, objectives, topics, and priorities for avoiding legal and reputational risks are defined and regularly updated. In this way, compliance is firmly anchored in the corporate culture, based on the BMW Group core values of responsibility, appreciation, trust, transparency, and openness.
The BMW Group Legal Compliance Code covers all aspects of legal compliance relevant to the BMW Group and provides an appropriate compliance framework for all associates. The BMW Group Code on Human Rights and Working Conditions outlines how the BMW Group promotes respect for human rights and implements the ILO core labor standards in its business activities. These codes apply to all locations worldwide and to all business areas, as well as dealings with co-workers, customers, suppliers, business partners, and public agencies. Internal regulations also define clear rules of conduct for associates in certain focus areas, e.g. corruption prevention, antitrust compliance, and data protection.
Training measures offered by the Compliance Academy enable associates to fulfil their personal responsibility for lawful conduct in their respective area of activity and, at the same time, reinforce the culture of integrity. Company-wide training on topics such as Compliance Essentials, Antitrust Compliance, and Corruption Prevention are offered both online and as classroom sessions.
Compliance Case Management coordinates compliance inquiries and tips from various contact points and develops appropriate measures. In particular, associates and external parties may contact the BMW Group Compliance Contact with compliance-related questions. The BMW Group also gives its associates the option of providing information regarding possible violations of the law within the company on an anonymous and confidential basis via the BMW Group SpeakUP Line.
For compliance reporting purposes, the entire BMW Group is surveyed at regular intervals to verify whether compliance obligations are being met. The BMW Group Compliance Committee regularly reports to the Board of Management and the Audit Committee of the Supervisory Board of BMW AG on the basis of these findings.
WORKING WITH BUSINESS PARTNERS TO AVOID COMPLIANCE RISKS.
The BMW Group is firmly committed to responsible and lawful conduct. We also expect this of our business partners.
Therefore, as part of the “BMW Group Business Relations Compliance” program, we implement a structured process of Compliance Due Diligence for selected business relationships with business partners. This is particularly relevant for BMW Group sales partners and certain service providers, such as sales intermediaries and consultants. On this basis, measures to avoid compliance risks are implemented with our business partners. These may include implementation of compliance training and specific monitoring activities.
The primary objective is to create a long-term, reliable basis for our business relations.
BMW Group Business Relations Compliance.
PROMOTING RESPECT FOR HUMAN RIGHTS AND FAIR WORKING CONDITIONS AT THE BMW GROUP.
The BMW Group takes its social and societal responsibility very seriously. Respect for human rights and fair working conditions are an integral part of our corporate culture. The BMW Group Code on Human Rights and Working Conditions confirms our commitment to comply with internationally recognized human rights and the core labor standards of the ILO, and aligns our due diligence process with the UN Guiding Principles on Business and Human Rights. Our focus is on topics and areas of activity where we can leverage our influence as a commercial enterprise, in addition to states’ and sovereign institutions’ obligations to protect human rights.
BMW Group Human Rights Code.
Helpline for compliance questions.
To avoid legal risks, associates may discuss any questions they have with their managers and the BMW Group departments responsible – in particular, the Legal Affairs, Corporate Audit, and Corporate Security departments.
The BMW Group Compliance Contact also serves as an additional point of contact for associates, customers, suppliers and other external parties on compliance-related matters. The same applies if deficiencies or other circumstances are identified that could lead to non-compliance with the law. Information may also be provided on an anonymous basis, if desired. The BMW Group assures informants that it will not take any steps to identify the source of information provided anonymously. This does not apply if the BMW Group Compliance Contact is used inappropriately.
The BMW Group Compliance Contact is available in German and English and can be reached as follows:
Phone: +49 89 382-60000 / Monday through Friday from 7:00 a.m. to 8:00 p.m. (CET)