Integrity and compliance
Strategy and concepts
A corporate culture of integrity
The automotive industry is undergoing 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.
We are convinced that the Mercedes-Benz Group will only remain successful in the long run if we fulfil not only our financial responsibilities but also our responsibility to society and the environment. Our stakeholders also expect us to act in such a manner.
Integrity is therefore a central element of our corporate culture and, as an enabler, it is also an integral part of our sustainable business strategy. For us, this involves more than just obeying laws and regulations. We also align our actions with shared principles, which particularly include fairness, responsibility, respect, openness and transparency.
Integrity in our daily business activities
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 of our corporate units in their efforts to embed these topics in our daily business activities.
Our Integrity Management unit works to promote and enhance integrity within our company and create a shared understanding of integrity. The goal is to avoid possible risks due to unethical behaviour and thus contribute to our company’s long-term success. The Head of Integrity Management reports directly to the member of the Board of Management responsible for Integrity and Legal Affairs.
Corporate principles and the Integrity Code
The Mercedes-Benz Group encourages and enables its employees to consistently uphold its corporate principles. They are given orientation by our Integrity Code, which is valid throughout the Group, because it serves as our shared standard of values, defines guidelines for our conduct and helps us make the right decisions; ethical behaviour is especially important in situations where the regulations are unclear or can be interpreted in different ways.
Our Integrity Code is binding on all employees of Mercedes-Benz Group and our controlled Group companies. Employees from a variety of corporate units all over the world have helped to formulate the Integrity Code. It is available in twelve languages and includes, among other things, regulations concerning corruption prevention, upholding human rights, the handling of data, product safety and compliance with technical regulations. The Integrity Code is available for our employees in the Enterprise Rules Database as well as on the intranet, along with all of the further key information concerning its application, including FAQs, points of contact and contact persons.
We have also formulated a special set of requirements for our managers in our Integrity Code. We expect them in particular to serve as role models through ethical behaviour and thus to offer guidance to our employees.
The key element of our Integrity Code consists of our five corporate principles. They provide orientation and are to be put into practice by all of our employees:
- We are profitable and are committed to people and the environment.
- We act responsibly and respect the rules.
- We address issues openly and stand for transparency.
- Fairness and respect are the foundation of our collaboration.
- We practice diversity.
We conduct knowledge sharing and an open dialogue with our employees to ensure that integrity will remain embedded in our company’s daily business over the long term. For example, during the reporting year we continued to regularly inform employees about our Integrity Code and its significance for our daily business activities. We have also regularly addressed the topics of integrity, compliance and legal affairs in our internal media.
Information, dialogue and training
We established the Infopoint Integrity in 2015 in order to promote a culture of integrity at the company. The Infopoint Integrity is the central point of contact for the workforce and employees of the Group companies when they have questions concerning acting with integrity. The Infopoint works together with experts for legal and HR issues, data protection and compliance, as well as diversity and sustainability. It either provides direct support or connects employees with the appropriate contact partners.
A global network of local contact persons for enquiries regarding integrity, compliance and legal issues is also available to our employees. The local contact persons evaluate the enquiries that are made and, if necessary, initiate the appropriate measures.
We expanded cooperation and activities in the Integrity Network during the reporting year. The Integrity Network consists of employees from the individual companies, divisions and functional divisions of the Group and serves as a joint platform for sharing knowledge and information with the aim of developing and implementing concrete measures. Among other things, local teams of multipliers have been established, and that has expanded the reach of the integrity-related measures. In order to strengthen and standardise cooperation, we have launched an Integrity Newsletter, and we also organise international multiplier dialogue events on a regular basis.
During one of these dialogue events, for example, it became clear that some employees do not fully understand what the word “integrity” actually means in all situations. In order to address this area of action, the Integrity Network collected around 200 statements from employees in which they explained what integrity means for them in daily situations. The statements were made available to all employees via the Integrity Toolkit on the intranet and served as the basis for the creation of a new Integrity Toolkit tool known as “Our integrity statements”. Employees can also create their own personal integrity statement there. Different teams can use the various descriptions as a basis of discussion for developing concepts for and features of a common culture of integrity at the Group.
The network has also designed and realised numerous additional programmes ranging from dialogue events and content and inspiration for management communication to training courses, in order to permanently embed the topic of integrity into daily business operations.
Employees can access the Integrity Toolkit via the intranet. The Toolkit contains formats for dialogue events, tools for self-reflection, case studies and further information about the topic of integrity. An additional workshop method was added to the Toolkit during the reporting year. Here, employees and managers were able to expand their knowledge about the Integrity Code in a workshop with the motto “Our Integrity Code — using our corporate principles to ensure we do the right thing”. Concise short formats have also been added, including an Integrity Calendar. All of these measures are designed to help intensify the focus on integrity in daily business operations.
We set great store by face-to-face discussions, and once again conducted a variety of dialogue events with employees at all levels of the hierarchy and with external stakeholders. All of these dialogue events were held virtually because of the protective measures in force due to the covid-19 pandemic. We also developed the Integrity Case Collection during the reporting year. All employees can use this collection of case studies to learn how to behave responsibly in situations that are unclear, share ideas about “proper behaviour” and thus enter into the dialogue. An additional area of focus in 2021 involved the challenges hybrid forms of working present in terms of ethical behaviour. In order to be able to offer forms of assistance here, all of the Integrity Toolkit’s formats were modified in line with requirements relating to mobile and hybrid forms of working.
The employees in administrative areas at Mercedes-Benz Group AG and controlled Group companies regularly attend a mandatory web-based training about integrity that is based on the Integrity Code. Because managers serve as role models, they perform an especially important task with regard to integrity, compliance and legal matters. In order to support them as much as possible in their role, the training programme also includes a special mandatory management module.
In the past we used a separate survey to analyse the way our employees view our culture of integrity, but in 2021 we integrated this analysis into our employee survey. Among other things, the survey results are also directly relevant to our management remuneration system.
Effectiveness and results
The effectiveness of our management approach
The success of Mercedes-Benz Group largely depends on a permanent commitment to integrity. That’s why we are consistently working on our understanding of integrity and refining it further. Moreover, we continually review our own actions. Surveys such as the Employee Survey play a key role here. The feedback we receive from our employees serves as a yardstick as well as a compass. We find out where we stand with regard to our culture of integrity, and the findings enable us to develop and implement specific measures.
Since 2012 our integrity management has been extensively supported by the external Advisory Board for Integrity and Sustainability and further developed on the basis of its ideas. During the reporting year, a workshop was once again held with external stakeholders at the Sustainability Dialogue. The topic of discussion here was “Ethical decision-making and Artificial Intelligence”.
The results of the 2021 Employee Survey show that our culture of integrity is more firmly embedded throughout the company than was the case after the last survey, which was conducted in 2018.
The employee survey also revealed that the more open “speak-up” culture is now being further extended and maintained throughout the Group. In other words, our employees are able to talk about sensitive issues in a more open manner. Equally important for us, we also learned from the survey that in comparison with the survey results from 2018 our employees work in an environment based to a greater extent on trust, because only in such an environment can topics be discussed constructively.
In order to implement the measures that were derived from the results reports, we restructured the Integrity Toolkit in the reporting year and adjusted its contents. “Multipliers” from various divisions were trained in order to support managers with follow-up activities relating to integrity and compliance. In addition, the Integrity Network has addressed the findings of the employee survey in order to initiate additional measures for the individual divisions and functions.
Mercedes-Benz Corporate Audit regularly carries out audits in various Mercedes-Benz entities worldwide. Corporate Audit works in accordance with the professional standards and code of ethics of the Institute of Internal Auditors (IIA). Thereby Corporate Audit also takes into account aspects of integrity.
During the reporting year, the trade magazine “Der Compliance Manager” took a close look at the codes of conduct of the DAX-40 companies and evaluated them in depth. Our Integrity Code received top marks in this assessment. This confirms that we have created a good basis for our understanding of integrity within the company.