Integrity and compliance

Integrity

Strategy and concepts

A corporate culture of integrity

The automotive industry is in a state of radical change. New fields of business are developing and new technologies are raising new questions – both ethical and legal. Moreover, the COVID-19 pandemic has led to profound changes all over the world. In such times of change and uncertainty, value-based action matters more than ever.

The Mercedes-Benz Group will remain successful in the long run only if it lives up to its economic, social and environmental responsibility. Stakeholders also expect this from the Group.

Integrity is therefore a central element of corporate culture for the Mercedes-Benz Group and, as an enabler, it is also an integral part of the Group’s sustainable business strategy. For the Group, this does not only mean complying with applicable laws and regulations; the Mercedes-Benz Group also conducts its activities on the basis of shared principles, which particularly include fairness, responsibility, respect, openness and transparency.

Integrity in daily business activities

GRI 2-23/-24

At the Mercedes-Benz Group, integrity, compliance and legal affairs are combined into a single Board of Management division. The “Integrity and Legal Affairs” division supports all corporate units in their efforts to embed, these topics in daily business activities.

The Integrity Management & Corporate Responsibility unit works to promote and enhance integrity within the Mercedes-Benz Group and create a shared understanding of integrity. The goal is to avoid possible risks that can arise due to unethical behaviour and thus to contribute to the company's long-term success. The Head of Integrity Management & Corporate Responsibility reports directly to the member of the Board of Management responsible for Integrity and Legal Affairs.

Corporate principles and the Integrity Code

GRI 2-23/-24

The Mercedes-Benz Group encourages and enables its employees to consistently uphold its corporate principles. The Integrity Code, which is valid throughout the Group, provides them with guidance because it serves as the shared standard of values, defines the guidelines for all conduct and helps the company make the right decisions.

The Integrity Code is binding on all employees of the Mercedes-Benz Group and the Group companies. Employees from a variety of units all over the world helped to formulate the Integrity Code. It is available in ten languages and includes, among other things, regulations concerning corruption prevention measures, upholding human rights, data management and compliance with technical product requirements. Employees can view the Integrity Code on the employee portal, along with details on how it should be applied and other key information such as FAQs, points of contact and contact persons.

The Mercedes-Benz Group has also formulated a special set of requirements for managers in the Integrity Code. In particular, it expects managers to serve as role models through their ethical behaviour and thus offer guidance for employees.

The key element of the Integrity Code is represented by five principles, which provide orientation and are to be actively applied by all employees:

1. The Mercedes-Benz Group is profitable and committed to people and the environment.
2. The Mercedes-Benz Group acts responsibly and respects the rules.
3. The Mercedes-Benz Group addresses issues openly and stands for transparency.
4. Fairness and respect provide the foundation of collaboration.
5. The Mercedes-Benz Group practises diversity.

The Mercedes-Benz Group maintains an exchange of knowledge and open dialogue with its employees to ensure that integrity remains anchored in day-to-day business in the long term. It also regularly addresses the topics of integrity, compliance and legal affairs in its internal media. During the reporting year, the Group revised the content of the Code of Conduct to include topics such as animal welfare issues. The revised Code of Conduct was communicated to employees in early 2023.

Measures

Information, dialogue and training

GRI 2-26

The Mercedes-Benz Group established its Infopoint Integrity in 2015 in order to promote a culture of integrity at the company. Infopoint Integrity is the central point of contact for questions concerning ethical behaviour. Infopoint Integrity works together with specialists including experts in the fields of legal and HR issues, data protection, compliance, diversity and sustainability. It either provides direct support or connects employees with the appropriate contact partners. During the reporting year, the Mercedes-Benz Group restructured cooperation and activities in the Integrity Network. The Integrity Network is made up of representatives from the business units and serves as a shared communication platform, with the aim of embedding integrity in everyday business life. The focus in 2022 was on establishing this realignment. The Integrity Management controls the Integrity Network and provides the representatives with content, tools and dialogue formats as needed.

The “Integrity Network” met in July 2022 in the context of the “Annual Integrity Meeting” – with representatives of the Board of Management and the business units, among others. This event also served as the kick-off for the “Integrity Experience”. This is the name given to a package of measures developed by Integrity Management in collaboration with the business unit Production & Supply Chain Management. The aim of the Integrity Experience is to support and promote integrity in the business units. The measures are modular and can be individually tailored. The building blocks for various integrity topics such as trust, error culture and speak-up are designed to help employees reflect on their own actions and can be linked to the existing culture and transformation initiatives in the respective business units. The Integrity Experience is scheduled to run at least until the end of 2023. In addition, the Mercedes-Benz Group offers new formats for network representatives. This includes, for example, the “Integrity Network Exchange”, where members can share their experiences, knowledge and practical examples via a digital platform. Employees can find out about the activities of this network on the employee portal in the “Integrity Network Community” and sign up for activities.

Employees can also access the Integrity Toolkit via the employee portal. The Toolkit contains formats for dialogue events, tools for self-reflection, case studies and
further information about the topic of integrity.

The Group sets great particular emphasis on direct discussions, and once again conducted a variety of dialogue events with employees at all levels of the hierarchy and
with external stakeholders. These dialogue events were conducted virtually because of the protective measures in force due to the Covid-19 pandemic.

In addition, the employees in administrative areas at Mercedes-Benz Group AG and Group companies regularly complete a mandatory web-based training course about integrity that is based on the Integrity Code. Because managers serve as role models, they perform an especially
important task with regard to compliance, integrity, legal matters and sustainability. In order to help them as much as possible to carry out this role, the training programme
also includes a special mandatory management module.

Employee survey

The results of the 2021 employee survey on Integrity & Compliance have been incorporated into various follow-up measures. The managers of the Mercedes-Benz Group are responsible for the implementation. To support them in their task, the Integrity Management & Corporate Responsibility unit offered webinars in the reporting year. These webinars presented the results of the survey, provided more detailed explanations and featured tools for possible follow-up activities. 

The culture of integrity within the Mercedes-Benz Group is to be reassessed in 2023.

Effectiveness and results

Effectiveness of the management approach

GRI 3-3

The success of the Mercedes-Benz Group largely depends on a permanent commitment to integrity and is part of the foundation of the sustainable business strategy. The Integrity Management & Corporate Responsibility unit, as an advisor and impulse generator in the business units, strengthens individual responsibility with regard to integrity. Insights into the integrity activities in the various business units are provided by the representatives of the Integrity Network in the form of half-yearly reports. The development progress of the “Integrity Experience” as an overarching measure is also visible there. The results and findings are channelled into further committees.

The Mercedes-Benz Group works consistently on its understanding of integrity, develops it further on an ongoing basis and regularly reviews itself. An important indicator here is the feedback from the Integrity Network.

Since 2012, the Group’s own integrity management has been intensively monitored by the external Advisory Board for Integrity and Sustainability and developed further on the basis of its input.

Results

With the realignment of the Integrity Network in the reporting year, the personal responsibility with regard to integrity was strengthened in the business units. The digital platforms initiated by Integrity Management were well received by the network partners, and the opportunities for mutual exchange and sharing of practical examples were increasingly used.

Mercedes-Benz Corporate Audit regularly conducts audits in various Mercedes-Benz entities worldwide. Corporate Audit works in accordance with the professional standards and the code of ethics of the Institute of Internal Auditors (IIA). Accordingly, the audits of Corporate Audit also take integrity aspects into account.