Bilfinger Compliance System
At Bilfinger, compliance is a key component of successful management and good corporate governance. With this in mind, we have revised our compliance system. It is now in line with increased global requirements and international standards.
Revised compliance rules are in place on a Group-wide basis since January 1, 2017. A Code of Conduct details the general principles of our behavior. Corresponding Group guidelines contain concrete instructions on the issues of integrity, competition and dealing with business partners.
Communication and Training
With Bilfinger Compliance Communications, a platform that was introduced in 2012, employees worldwide can ask questions via telephone or intranet in their native language. These questions will then be answered by the compliance team. The system can also be used to report compliance incidents (anonymously, if desired). Internal whistleblowers are protected against any reprisals; the voluntary disclosure of one’s own misconduct is to the advantage of the employee concerned.
Persons outside the company such as customers, suppliers, subcontractors or service providers can also report misconduct via Bilfinger Compliance Communications. These reports also remain anonymous if desired.
The new compliance rules have been distributed to all employees in a total of 22 languages. Their introduction was accompanied by a communications campaign and by face-to-face trainings. It is also being supported by a newly-developed e-learning program.
We have strengthened our compliance organization on a personnel level. The Chief Compliance Officer of the Group, the Compliance Officers who report to him in the first-tier operating companies as well as the Compliance Managers deployed both centrally and decentrally all handle compliance-relevant processes. The compliance team works together closely with the Executive Board, Executive Managements and senior managers, reviews situations in which there is uncertainty and helps all employees to comply with internal requirements. The Chief Compliance Officer is supported in the design and further development of the compliance system by a Compliance Committee, which convenes regularly and is composed of the heads of Legal, Internal Auditing and Human Resources.
Adherence to Compliance Regulations
The control systems we have implemented to ensure that compliance regulations are adhered to include routine and special audits by Internal Auditing. As part of our monitoring of business relationships, we pay particular attention to the use of third parties in connection with order acquisition.
Thanks to the immediate reporting of serious cases and the Chief Compliance Officer’s quarterly reports, the Executive Board, the Audit Committee of the Supervisory Board and the Plenum of the Supervisory Board are given detailed updates on developments in the compliance area.
We actively pursue information on compliance violations through our own investigations, by notifying the relevant authorities and cooperating with them to achieve a full resolution. Any misconduct that is discovered will result in personnel consequences for those involved and will lead to preventive organizational measures. The internal findings gained from reporting, the comparison with other systems and the evaluations from external specialists all lead to the ongoing development and improvement of our compliance system.