BMW GROUP LEGAL COMPLIANCE CODE - COMPLIANCE. DRIVING THE RIGHT WAY.
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BMW GROUP
LEGAL COMPLIANCE CODE.
COMPLIANCE. DRIVING THE RIGHT WAY.
PUBLISHED BY
Bayerische Motoren Werke
Aktiengesellschaft
BMW Group Compliance Committee Office
LCC-EN-EXT-202012
80788 Munich
Germany
© BMW AG, December 2020
DEAR COLLEAGUES,
It is essential for the success of our company to act responsibly and in
compliance with the law. We, the members of the Board of Management
of BMW AG, set extremely high standards for our own actions and those
of each and every employee of the BMW Group. This approach is integral
to our corporate culture and is the reason why customers, shareholders,
business partners and the general public place their trust in us. Even
isolated violations of legal regulations could cause enormous damage to
the BMW Group’s excellent reputation, which we work so hard each day
to uphold. As a consequence, each of you is obliged to act responsibly
and in compliance with the law.
We are aware that the increasingly international nature of business
and the large number and complexity of legal regulations increase the
risk of laws being broken. For that reason, the members of the Board of
Management have compiled this Legal Compliance Code. The Code is
applicable globally at all sites operated by the BMW Group. It is designed
to help you to identify legal risks and avoid any violations of the law.
My Board of Management colleagues and I request that you read the
Code carefully and adopt it as the binding standard for your conduct.
“The BMW Group is fully committed In this way, you will be making a vital contribution to the success of
to lawful and responsible conduct.” the BMW Group, both now and in the future. Because every single
employee matters.
Oliver Zipse, on behalf of the Board of Management of BMW AG
CONTENT
1. LAWFUL AND RESPONSIBLE CONDUCT 6
2. THE LEGAL FRAMEWORK – AN OVERVIEW 8
2.1. BMW Group products, services, customers and markets 8
2.2. The BMW Group and its competitors 10
2.3. Corruption prevention 12
2.4. Data protection 14
2.5. Mutual esteem and principle of non-discrimination 15
2.6. Safety at the workplace 15
2.7. Environmental protection 16
2.8. Protection of company assets 17
2.9. Transparency for investors 18
2.10. Fair treatment of contracting partners 20
2.11. Dealing with authorities 20
3. IMPLEMENTATION OF THE LEGAL COMPLIANCE CODE 21
4 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 5
1. LAWFUL AND
RESPONSIBLE
CONDUCT.
Responsible and lawful conduct is integral to
our corporate policies and forms the basis for
the long-term success of our company. The applicable laws provide the binding services. In many cases, the mere appearance Every employee can rely on this principle.
framework for the BMW Group’s wide-rang- of a violation of the law can be sufficient to This applies even in the event that manage-
The BMW Group takes its ecological and ing business activities around the world. It have an unfavorable effect on the public ment gives instructions to the contrary.
social responsibilities very seriously: It ac- is imperative for all employees to be familiar opinion and on the attitude of customers,
knowledges the ten principles of the United with and firmly committed to upholding shareholders or business partners. This Legal Compliance Code is designed to
Nations’ Global Compact and has signed a compliance with applicable legal regulations. highlight the range and focus of relevant
joint declaration on human rights and work- This is an important factor in defining the The BMW Group sells its products and ser- legal requirements for the BMW Group and
ing conditions with national and internation- BMW Group’s image in the eyes of the gen- vices worldwide, with sites in more than 40 to emphasize the binding nature of those
al employee representatives. Based on its eral public and, at the same time, helps to countries. Its global activities are subject to requirements. The principles set out in this
values and basic principles, the BMW Group create trust in the BMW Group’s products a wide range of national and international document apply to dealings with colleagues,
has created a corporate culture founded on and brands. This trust is absolutely essential legal regulations. customers, suppliers, business partners and
trust, mutual appreciation and tolerance. for the overall success of the company. public bodies alike.
By complying with applicable legal regula-
This Legal Compliance Code is aimed at Violations of the law, on the other hand, can tions, every employee acts in the interests of This Legal Compliance Code is applicable
compliance with legal requirements. The result in serious consequences for the com- the BMW Group. Legal prohibitions and ob- globally at all sites and for all divisions of
BMW Group takes the necessary measures pany, such as fines or compensation claims. ligations must be observed in all cases, even the BMW Group. In the event that additional
to ensure that its management bodies, mana- There is also the possibility that the BMW if this may not always appear expedient or business or national requirements apply,
gers and staff act lawfully (“legal compliance”). Group’s reputation could be damaged, thus make commercial sense from the perspective the Code may be supplemented by local
The entirety of these measures is referred seriously weakening the BMW Group’s posi- of the individual or the company. Wherever compliance programs.
to as “compliance management”. tion as a provider of premium products and there is any doubt, compliance with the law
must always take priority.
6 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 7
selective sales system. This means that only export control matters are treated as a key
BMW Group authorized sales partners and business activity across the BMW Group
branches are entitled to sell new vehicles. The worldwide.
sales and service structures employed within
the automotive industry are subject to specif- Financial services and insurance – generating
ic legal requirements in almost all markets. trust by providing advice on what customers
Along with dealer, agency and importer agree- really need.
ments, these requirements govern the relation- Many people place their trust in the services
ship between the BMW Group and its sales provided by the BMW Group Financial Services
partners and protect and foster competition segment – not only for vehicle financing, but
in compliance with antitrust laws. These laws also in other areas. Specific statutory and reg-
and requirements specifically prohibit meas- ulatory requirements are in place to protect
ures which are conducive to fixing prices with customers. The whole organization of the
dealers or which might encourage any such Financial Services segment and its internal reg-
price fixing arrangements. ulations are designed to ensure compliance
with these requirements. Implementation of
The BMW Group’s national and international these measures is continuously monitored
2. THE LEGAL FRAMEWORK – AN OVERVIEW. operations have tax, customs and export internally and is subject to review by external
control implications. auditors and the relevant regulatory banking
The BMW Group respects the applicable tax, and financial services agencies.
2.1. BMW GROUP PRODUCTS, SERVICES, customs and export control legislation as well
CUSTOMERS AND MARKETS. as reporting and publication regulations as Handling customer data carefully and in com-
part of its worldwide compliance. We comply pliance with the relevant statutory regulations
BMW Group vehicles are found servations relating to safety. When necessary, fully and in a timely manner with the legal ob- and contractual arrangements (e.g. data pro-
all over the world. we notify the relevant authorities without ligations in every country in which we operate. tection legislation and banking confidentiality
Our customers can rely on these vehicles meet- delay and undertake the measures required rules) is essential for a trusting relationship
ing all legal requirements, such as type approv- to ensure our customers’ safety. Our intra-Group business transactions are with our customers. In compliance with legal
al requirements (incl. emissions regulations) based on internationally recognized transfer requirements, we inform our customers in
and environmental laws. For this purpose, the We compete for customers on the basis pricing guidelines. We do not use artificial tax clear and comprehensible language about our
BMW Group monitors all relevant legal infor- of our products and services. structures intended for tax avoidance and re- own financial products, as well as third-party
mation worldwide and integrates the resulting Our products and services arouse emotions, ject the use of secrecy jurisdictions or so-called products we may sell as agents, such as securi-
technical specifications into vehicle develop- particularly through advertising. In our ad- “tax havens”, in accordance with the “EU list ties and insurance policies. In many countries,
ment. To secure type approval and certifica- vertising, we comply with the requirements of non-cooperative jurisdictions for tax purpos- this must be documented in specific detail. In
tion, we work closely with the relevant author- for transparency and accuracy of information es”. Furthermore, the BMW Group has imple- some cases, we are required to make enquiries
ities. The BMW Group has established suit- laid down in the laws relating to consumer mented a Tax Compliance Management System into customers’ personal circumstances and
able structures and processes to exercise its protection and fair competition. We provide in Germany in accordance with the require- prior experience with financial products.
responsibility for product compliance. our customers with the information they need ments of IDW PS 980. The adequacy of the
to make careful and informed decisions. system has been certified. The BMW Group We take measures to verify the identity and in-
Product safety is the basis for our thereby fulfills its social responsibility in the tegrity of our customers (know-your-customer
comprehensive product responsibility. The quality of our sales organization contributes areas of tax, customs and export control. principle) not only in order to combat money
BMW Group products are developed and ma- to our success just as much as the fascination laundering, but also in our own interests. This
nufactured under the strict governance of our of our products and services. The active exchange of information and the applies to all relevant BMW Group business
quality management systems. We monitor our To achieve premium standards of sales and awareness of every employee in every group units.
products in the market and follow up on ob- service, the BMW Group has adopted a division helps ensure that tax, customs and
8 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 9
2.2. THE BMW GROUP AND ITS COMPETITORS.
Fair competition is a fundamental prerequisite When working with supplier networks, we ensure Mergers and other types of transactions interpretation and assessment, requiring a
for achieving success through performance. all parties’ freedom to operate independently. may not be completed until they have been precise knowledge of the relevant legisla-
The BMW Group unreservedly acknowledges The development and production of vehicles reported to, and approved by, the relevant tion and of the procedures applied by the
the principles of the market economy and fair involves highly complex, labor-intensive antitrust authorities. authorities. BMW Group Legal Affairs must
competition. We pursue our corporate objec- processes, which require suppliers and always be consulted in any cases of doubt
tives solely on the basis of our performance development partners to work together in Non-compliance with antitrust regulations and on legal matters relating to transaction
and in compliance with the relevant fair com- networks. The way in which these networks has serious consequences. application procedures.
petition laws. We expect our competitors and are organized must not restrict the freedom Non-compliance with fair competition and
business partners to do the same. of the parties involved to select business part- antitrust regulations may have far-reaching More detailed information on the topic
ners or to determine terms and conditions. consequences, such as monetary penalties, of antitrust compliance can be found in
Agreements which impair fair competition prison sentences, heavy fines, skimming off the BMW Group Policy “Antitrust Com-
are strictly prohibited. The purchase and sale of entities serves to of profits and liability claims under civil law. pliance”, which applies to all entities of
The BMW Group competes with other auto strengthen the BMW Group’s competitive These areas are subject to a high degree of the BMW Group.
companies, not only in the sale of vehicles position.
and financial services, but also in vehicle The purchase and sale of business entities
development and the procurement of pro- are subject to merger controls.
duction materials. Whatever the situation,
the primary antitrust rule is to not make any
market-related agreements with competitors –
particularly with regard to prices, bids, terms
of business, production plans, sales quotas
or market share.
Any deliberate coordination of action restrict-
ing fair competition is prohibited, regardless
of whether it is based on an agreement or
informal discussions – even if these take
place unofficially. It is important to avoid
even the appearance of a violation.
Special care must be taken at conferences
held by industry associations and other
industry or sector meetings. The oppor-
tunities that arise at such events to meet
and hold discussions must not be used to
exchange confidential market or company
information to influence market conditions.
The same applies to the exchange of infor-
mation on market research and bench-
marking projects.
10 BMW GROUP LEGAL COMPLIANCE CODE
accepting or granting advantages in the
form of direct financial gratuities, but also
other advantages, benefits or favors (e.g.
invitations and gifts), which could affect
2.3. CORRUPTION the professional objectivity of the person in
PREVENTION. question. For that reason, monetary and non-
monetary benefits that go beyond customary
The BMW Group takes resolute action to and reasonable business practice must be
combat bribery and corruption. refused. The same applies to benefits for
Corruption is a global problem that causes associated persons, such as family members
tremendous economic damage. It hinders or close friends.
fair competition, since it does not generally
allow the best supplier to compete on an Non-compliance with these principles cannot
equitable basis. As a responsible company, be justified by the behavior of others with
the BMW Group takes a firm position on the excuse that “everybody does it”.
fighting corruption – and expects the same
from its business partners. To help its staff evaluate what is customary
and reasonable, the BMW Group sets value
The BMW Group’s global production and limits and defines other criteria. These as-
sales network encompasses very different sessment criteria apply, for example, both
legal systems and cultures. prohibited. These are usually smaller pay- into, or continued, on the basis of objective to extending and accepting benefits, such
This presents increased challenges for ments made to a public official to encourage criteria, e.g. quality, price, technical speci- as gifts, business hospitality and events. If
corruption prevention. For the BMW Group, them to perform or expedite an official fications and the reliability of the business higher-value benefits are involved, it is man-
challenges may arise, in particular, with re- process. partner concerned. Commercial and per- datory to obtain the prior approval of the
gard to corporate hospitality and gifts, cost sonnel decisions and advice or recommen- relevant manager.
coverage for speaking engagements, provi- Compliant behavior requires every employee dations from BMW Group employees must
sion of vehicles, shuttle services, discounts to separate private interests from those of not be influenced by private interests and More detailed information on the topic of
and allowances, incentive schemes, spon- the company. relationships, nor should they be motivated corruption prevention can be found in the
soring, donations (e.g. to charitable institu- Corruption frequently results from conflicts by tangible or intangible advantages. It is BMW Group Policy “Corruption Preven-
tions) and memberships. of interest, i.e. when professional activities important to avoid even the appearance of tion”, which applies to all entities of the
are affected by private interests. The BMW impropriety. BMW Group.
The basic principle is that such benefits for Group therefore urges all employees to avoid
business partners and journalists are only per- situations that may result in a conflict of The same applies in reverse: As a premium Transparent and reliable business relationships
mitted within appropriate limits. Extra care interest. Potential conflicts of interest should supplier, we convince our business partners are a key factor in corruption prevention.
must be taken with regard to public officials be discussed with the relevant manager, through our products and services – not by Accordingly, we also expect our business
and elected representatives: Civil servants, BMW Group Compliance Committee Office offering undue advantage. partners to take responsibility for preventing
judges, politicians and other representatives or legal department responsible. corruption. The BMW Group therefore imple-
of public institutions and members of parlia- Employees of the BMW Group must not accept, ments a structured process of Compliance
ment may not receive any form of gift, other Every order should be awarded to the best demand, offer or grant any personal advantage Due Diligence for selected business partners.
benefit or invitation that could compromise bidder – objective criteria must always form in conjunction with the activities they perform This is particularly relevant in the case of sales
their impartiality and are therefore unlawful. the basis for new business relationships. on behalf of the company. partners and certain service providers, such
So-called “facilitation payments” are also Business relations must always be entered Employees are not only prohibited from as agencies and consultants.
12 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 13
2.5. MUTUAL ESTEEM AND PRINCIPLE
OF NON-DISCRIMINATION.
The diversity and uniqueness of our employees ports national policies to overcome the ef-
drives the performance and innovative strength fects of past discriminatory practices.
of the BMW Group.
The BMW Group has a committed and com- All forms of workplace harassment, includ-
petent workforce. Each member of the work- ing sexual harassment, are strictly prohibited.
force is respected as an individual. Accord- Everyone has the right to be protected from
ingly, the way in which we work with each harassment, no matter if the alleged harasser
other is characterized by appreciation, mu- believes that his or her behavior is acceptable
tual understanding, openness and fairness. or whether the alleged victim would be capa-
ble of avoiding the harassment.
Discrimination and harassment
are not tolerated. It is every manager’s duty to set an example
No one shall be disadvantaged, favored or by their own behavior and to ensure that the
harassed as a result of ethnic origin, skin area for which they are responsible is free of
color, nationality, sex, religion or beliefs, dis- discrimination and harassment.
ability, age, veteran status, sexual orientation
or other characteristics that are protected by
2.4. DATA PROTECTION. law. For this reason, the BMW Group sup-
We strictly comply with data protection regulations.
The use of innovative information technologies raises many questions
concerning the right of individuals to determine how their personal 2.6. SAFETY AT THE WORKPLACE.
information may be used. We consider this right to be of immense
importance. The BMW Group takes data protection issues into account Occupational safety and health management We plan and operate our facilities in strict
when handling the personal data of its customers, employees and are top priorities at the BMW Group. compliance with safety regulations. This
business partners. The BMW Group Data Protection Officer provides Worker protection and occupational health reduces the risk of accidents and ensures that
support to the various departments in this respect. Personal details and safety provisions must be strictly ob- our systems operate smoothly. Managers
are only recorded, processed or used if this is permitted by law or if served to prevent health hazards. Safety at must be aware of their responsibility and
the person involved has given permission. We are committed to the work is a primary duty of each and every corporate duties with regard to safety at
principles of sparing use of personal data and transparency in data individual. Managers are important role the workplace. They must ensure that the
processing. This approach ensures a consistent and appropriate level models in this respect. employees who work in a facility are care-
of data protection throughout the BMW Group. fully selected and properly trained.
14 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 15
2.7. ENVIRONMENTAL PROTECTION. 2.8. PROTECTION OF COMPANY ASSETS.
The BMW Group takes responsibility for the environment. Innovation and brands must be protected. Individual responsibility in handling
Long-term success can only be achieved through sustainable Innovation, know-how and experience are confidential information.
business practices. Environmental law and animal welfare key to the BMW Group’s success in develop- When working with suppliers, development
regulations provide binding standards for the BMW Group ing and creating attractive products and partners, vehicle manufacturers, dealers or
in this area, which we also expect our suppliers to observe. services. To maintain our competitive edge, other business partners, it is essential that
All employees responsible for facilities and activities that can these innovations and capabilities must be we protect the BMW Group’s confidential
have an impact on the environment are aware of their special safeguarded against imitation by others. The information, know-how and business secrets.
responsibility for compliance with environmental and animal BMW Group’s brands, which are among Special care should be taken when exchanging
welfare legislation. They are supported in their work by the the most valuable in the world, must also information via electronic networks.
BMW Group Environmental Protection Officer and corres- be protected.
ponding network. Environmental regulations have an impact Data and other information which becomes
on all stages of a vehicle’s life. This starts with development In the field of engineering and design, the known to an employee while working for the
in the field of electromobility, for example, or ensuring the BMW Group uses the legal options available company may only be used as authorized.
safety of new and existing technologies, and continues with to protect innovations, primarily by securing Before disclosing any such information to
the selection, procurement and testing of materials, as well intellectual property rights (patents, design persons inside or outside the company, it is
as resource-efficient production processes, and ends with the patents, trademarks etc.). To this end, the the responsibility of each individual to ensure
environmentally responsible treatment of end-of-life vehicles. patents department needs to be informed that the recipient is entitled to receive such
about relevant innovations in the various data and information. Depending on the
fields throughout the BMW Group. significance of the information, additional
safety measures may be required, such as
confidentiality agreements or audits.
Responsible handling of third-party
intellectual property.
The confidential information and know-
how of third parties must be respected and
protected. We only use such knowledge if
we have obtained it by lawful means or if it
has been acquired from publicly accessible
sources. Third-party commercial property
rights (patents, designs and brands) must
be respected and may only be used with the
permission of the respective rights holder.
Company property must be respected
and protected.
Every employee is responsible for the 2.9. TRANSPARENCY
protection and correct usage of property FOR INVESTORS.
and other tangible assets belonging to the
BMW Group. Equipment and other items Transparency generates confidence out the company. All named employees must Corporate information that could affect
owned by the company (e.g. vehicles, tools, in the capital markets. therefore ensure that their contributions are the market price must be published by
spare parts, office supplies, documents, The BMW Group enjoys the trust of the in- correct and complete. the issuer without delay.
computers, data media, etc.) may only be vestors who finance its global activities. This In order to comply with its ad hoc notification
used for company purposes. They must confidence is based on the BMW Group’s Insider trading is prohibited – insider knowledge duties, BMW AG has established an ad hoc
be protected from loss, theft, damage or transparent financial reporting and equal imposes a particular obligation to maintain committee, which reviews information to
misuse. Employees are not permitted to treatment of investors. confidentiality and discretion. determine whether it could affect the market
remove any such item from the company’s Anyone with access to confidential informa- price and advises the Board of Management
premises without permission. The external financial reporting duties in- tion that could substantially influence the on matters relating to ad hoc disclosures. All
volved in the stock market listing of BMW AG market price of BMW AG shares or bonds employees of the BMW Group are required
Information technologies require special and the issuance of corporate bonds are wide- is considered an insider. Insider information to inform this committee via their managers,
safety awareness. ranging. The BMW Group provides clear and must not be disclosed or made available to if there is any indication that a particular
Electronic data processing is an indispens- reliable information in its annual reports and colleagues or third parties without authori- subject matter could significantly affect the
able part of our corporate infrastructure. In- at analyst conferences on matters relevant zation. The only exception to this rule is if market price of BMW securities.
terference with these systems could cause to the capital markets. As an example, the colleagues require the information for a spe-
production systems and sales processes to BMW Group discloses all transactions in- cific project. Under no circumstances may Transparency is absolutely essential
come to a standstill. All employees must ad- volving BMW AG shares entered into by per- insiders use their knowledge, either directly when issuing new securities.
here to the security regulations issued by the sons with senior management responsibili- or through third parties, for their own trad- All publications relating to new issues of
relevant IT department and play an active role ties (Directors’ Dealings). ing purposes or advise others to acquire or shares and bonds must be accurate and com-
in ensuring compliance. For example, email sell shares. This also means, for example, that plete. Prospectuses and company reports
attachments, applications (apps), internet Members of the Board of Management must an employee must not trade in the securities must contain all the information needed to
downloads and files obtained from other ensure that financial reports are accurate. in question, such as BMW AG shares, while make an assessment of the issuer and the
sources must not be opened or installed un- These reports are based on information in possession of insider information. issued securities.
til they have been checked. generated by various departments through-
18 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 193. IMPLEMENTATION OF THE LEGAL
COMPLIANCE CODE.
Compliance with the applicable laws is the they take compliance risks seriously and that
personal responsibility of each individual relevant information is of tremendous value
employee. in protecting the company. In their dealings
All BMW Group employees are required to with staff, managers are always open to dis-
adhere to this Legal Compliance Code and cussion and different opinions. When risks
adopt its principles as the binding standard are identified, they initiate the required
for performance of their day-to-day work changes and proceed in a transparent and
duties. This requires them to actively and prudent manner.
regularly inform themselves about existing
2.10. FAIR TREATMENT OF CONTRACTING PARTNERS. requirements and participate in available Staff and managers must know and adhere to
compliance training. the BMW Group’s internal regulations.
The commercial success of the BMW Group requires a fair balance of internal In many cases, internal BMW Group regu-
and external input. All managers must ensure that this Code is lations stipulate specific procedures that
The BMW Group must be able to respond in a flexible manner to changes in the observed in their area of responsibility. reflect current legislation and provide practi-
marketplace and in customer expectations. The company works with contracting All managers are required to inform their cal tips on how to prevent violations of the
partners in different areas to secure the resources and expertise this requires, staff of the content and significance of the law. Internal BMW Group regulations are
with contracts for work an established and effective tool for achieving this. Within Legal Compliance Code and to “sensitize” binding for all staff and managers. Each in-
this structure, the contracting partner performs a service for the BMW Group staff to the Code. Managers must do every- dividual is obliged to obtain information
autonomously on a performance-related basis. thing within their power to help staff to act about the regulations that are relevant for
lawfully. Any indications of violations of the his or her work duties.
law must be rigorously investigated. Mana-
gers must, at regular intervals and on their The BMW Group does not tolerate violations
own initiative, verify compliance with the of the law by its employees.
2.11. DEALING WITH AUTHORITIES. law and communicate regularly with staff Culpable violations of the law committed by
on this issue. This is the only way to ensure employees while working for the BMW Group
Cooperation with authorities must be based on mutual trust and consideration, that the principles set out in this Code will may result in sanctions or even termination
following the relevant procedural requirements. be followed on a day-to-day basis. of employment. If such violations of the law
The BMW Group strives to work with government bodies and other public authorities cause damages, this may also result in the
on the basis of full cooperation and transparency. We consider it important that the Managers promote a compliance culture based employee bearing personal liability and being
authorities adhere to legally established procedures for investigations and other of- on trust, transparency and appreciation. subject to any penalties or fines imposed by
ficial activities. It is an integral and legitimate aspect of the BMW Group’s dealings BMW Group managers serve as role models the courts or authorities.
with authorities that we exercise our procedural rights. In order to ensure this and, for values, integrity and compliance,and
where appropriate, to assist in discussions with regulatory and investigating au- especially avoid personal conflicts of interest
thorities, employees are required to confer with the legal department responsible. in doing so. They signal to their team that
20 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 21The BMW Group also offers its staff the op-
tion of submitting information relating to
possible violations of the law within the
company on an anonymous and confidential
basis via the BMW Group SpeakUP Line. The
same applies to risks and areas of weakness
that could potentially lead to non-compliance.
The BMW Group SpeakUP Line is available
The BMW Group provides a company-specific BMW Group Compliance Organization. implementation of the decisions of the BMW in more than 30 languages via a local toll-free
program of compliance instruments and In this function, they are instrumental in Group Compliance Committee. number in all countries where BMW Group
measures to support its staff. implementing compliance guidelines in their staff are employed.
The BMW Group has established a com- area of responsibility and report to the BMW BMW Group employees may reach out to
pliance management system, comprising Group Compliance Committee, the highest the BMW Group Compliance Contact Compliance with, and implementation of,
training and communications activities, authority in the BMW Group Compliance and BMW Group SpeakUP Line. this Code is monitored at regular intervals
individual counseling and management of Organization. In order to avoid violations of the law, all across the whole of the BMW Group.
compliance-related processes and controls. members of staff are entitled to discuss mat- Compliance with, and implementation of,
The scope and intensity of compliance ac- The BMW Group Compliance Committee ters with their managers, the BMW Group this Code is monitored regularly by Cor-
tivities is determined in a company-wide reports to the Board of Management. Compliance Committee Office or the legal porate Audit and is subject to the control
Compliance Risk Assessment, which is up- The BMW Group Compliance Committee department responsible. The BMW Group measures of Corporate Security and the
dated every year. manages and monitors compliance activi- Compliance Contact is also available to sup- BMW Group Compliance Committee Office.
ties within the BMW Group and regularly port employees and external persons. This process also requires documents and
Division heads and heads of National Sales informs the Board of Management about all IT systems to be reviewed on site, as well as
and Financial Services Companies form compliance-related issues. The BMW Group Telephone: +49 89 382-60000 employee interviews and site inspections.
a company-wide network of Compliance Compliance Committee Office lays the con- Email: compliance@bmwgroup.com
Responsibles, which plays a key role in the ceptual groundwork and handles operational
22 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 23COMPLIANCE.
DRIVING THE RIGHT WAY.
BMW Group Compliance.
For further information on compliance
at the BMW Group please refer to
www.bmwgroup.com/compliance
24 BMW GROUP LEGAL COMPLIANCE CODE BMW GROUP LEGAL COMPLIANCE CODE 25RESPONSIBILITY.
APPRECIATION.
We make consistent decisions and
stand behind them. This creates
freedom for entrepreneurship.
We are critical of ourselves and show
mutual respect, provide clear feedback
and recognize performance.
TRANSPARENCY.
We do not gloss over problems; we address
inconsistencies in a constructive manner.
We conduct ourselves with integrity.
TRUST.
OPENNESS.
We rely on each other.
It is the only way to be
fast and reach our goals.
We always look for opportunities
and act boldly in the face of change.
We grow from our mistakes.You can also read
