BMW GROUP CODE OF CONDUCT.
Our company-wide network.
The BMW Group has established a company-wide Compliance Organization to educate associates about potential compliance risks and help ensure compliance with requirements at local and international level.
The Group Compliance Division, based at the Group’s Munich headquarters, designs and manages the Compliance Management System. Group Compliance is assigned to the Chairman of the Board of Management for organizational purposes. It includes the pillars “Program Design, Prevention”, “Operations”, and “Export Control, Anti-Money Laundering”, as well as “Compliance Audits, Internal Investigations”, and is in charge of the compliance topics antitrust compliance, corruption prevention, export control, anti-money laundering, fraud prevention, and human rights, while the topics data privacy and product compliance are allocated to other organizational units of the BMW Group.
The Group Compliance Division is supported by a company-wide Compliance Network of Ressort and Local Compliance Officers. They implement the Compliance Management System on the divisional level, in the business departments, and affiliated companies and, if necessary, supplement it at local or business-specific level.
Compliance Management System.
The BMW Group Compliance Management System includes a large number of preventive, monitoring, control, and response measures to support compliance with legal and ethical requirements. These apply to all BMW Group units worldwide. Where additional compliance requirements exist in individual countries or business units, these are met by applying local or business-specific compliance regulations and instruments.
The Code of Conduct transfers the corporate values of the BMW Group into essential maxims of action and creates transparency for employees and the public about the main areas of compliance. Based on this, the legal requirements for compliance issues are transferred and implemented into internal regulations and processes.
All employees are regularly informed through various internal communication activities. Compliance communication makes an important contribution towards establishing compliance in the corporate culture. Compliance training measures aim to enable BMW Group employees to fulfil their personal responsibility for lawful conduct in their respective area of activity. Compliance training is offered both online and in classrooms to meet the needs of different target groups.
Compliance investigations cover compliance audits without cause and risk-oriented priorities as well as notification reviews. These are ad-hoc audits, especially for reports of infringements within BMW Group compliance management topics. Additionally, internal investigations tend to clarify matters of particular relevance (based on directive from the Board of Management).
Compliance reporting is an essential element for informing the Executive Board, the Supervisory Board and its Audit Committee, as well as other internal stakeholders, about the Compliance Management System. The focus lies on its implementation and potential for further development, and to assess its adequacy and effectiveness.
In addition to the elimination of misconduct and illegal acts, further risk-reducing measures may be required, which may include appropriate personnel measures and sanctions in the case of individually reprehensible conduct. The spectrum of sanctions can cover the entire spectrum depending on the case.
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.
Respect for people and the environment.
BMW Group Code on Human Rights and Working Conditions.
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 serves as an additional point of contact for associates, customers, suppliers and other external parties.
The BMW Group Compliance Contact for compliance-related matters 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)
The BMW Group's reporting system is responsible for providing information on specific or potential legal violations by employees within the Group. Business partners, customers or other third parties also have the option of reporting information around the clock via various reporting channels if there is concrete evidence of violations of the rules. In this way, risks can be identified and addressed at an early stage and, if necessary, appropriate remedies can be provided.
Confidentiality and the protection of informants are paramount here. On request, information can also be provided anonymously. It is in line with our Group-wide procedure not to take any steps to identify an informant who reports anonymously.
In addition to managers, local compliance departments and employee representatives as traditional points of contact, BMW Group employees and external reporting persons have various reporting channels available.
BMW Group associates and external whistleblowers can always turn to their managers, local compliance function and the Works Council with their matters and concerns. Furthermore, BMW Group Compliance has set up dedicated channels for the reporting of information relating to potential compliance violations. To ensure this can be done easily and confidentially and to serve as reporting channels within the meaning of the German Whistleblower Protection Act, BMW Group Compliance has established a dedicated email inbox and, specifically, the BMW Group SpeakUP Line, as well as an ombudsperson.
Our reporting channels.
BMW Group employees and external informants can report cases of suspected non-compliance anonymously and confidentially via the BMW Group SpeakUP Line. The BMW Group SpeakUP Line is available throughout the day in a total of 34 languages in all countries in which the BMW Group operates via local, toll-free numbers [BMW GROUP SPEAKUP LINE ACCESS DATA]. Concerns may also be reported online.
The BMW Group has appointed an ombudsperson to advise on the system for reporting compliance concerns and ensure that reports from informants are forwarded to BMW Group Compliance. If preferred, this information can also be provided anonymously.
Our ombudsperson can be contacted as follows:
Dr Sibylle von Coelln
Telephone: +49 211 44 03 57 72
Fax: +49 211 44 03 57 77
HEUKING · VON COELLN
Rechtsanwälte PartG mbB
You provide your personal data voluntarily. You have the option to submit your report anonymously. If you voluntarily decide to provide your personal data and thus provide a non-anonymous report, we will process your information solely for the purpose of processing your report on the basis of Article 6 (1) LIT. C), F) of the GDPR. Further information on data protection and your rights can be found here.