Integrity

Compliance Management:
Complying with laws and regulations

Value-based compliance is an indispensable part of our daily business activities at Daimler. For us, compliance means acting in accordance with laws and regulations. Our objective here is to ensure that all of our employees worldwide always carry out their work in a manner that is in compliance with applicable laws, regulations, agreements with workers’ representative bodies, voluntary commitments, and our values, as set out in binding form in our Integrity Code.

The Daimler Compliance Management System

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Our compliance activities focus on complying with anti-corruption regulations, the maintenance and promotion of fair competition, the compliance of our products with technical and regulatory stipulations, respect for and the protection of human rights, adherence to data protection laws, compliance with sanctions, and the prevention of money laundering.

Our Compliance Management System (CMS) consists of basic principles and measures for the promotion of compliant behavior throughout the Group. The CMS is based on national and international standards and is applied on a global scale at Daimler AG and all Group companies. The CMS consists of seven elements that build on one another.

7.1 The Daimler Compliance Management System

Compliance values and goals

The objective of our CMS is, on the foundation of our culture of integrity, to promote compliance with applicable laws and policies within the company and on the part of its employees and to prevent inappropriate behavior. The measures needed for this are defined by our compliance and legal organizations in a process that also takes the company’s business requirements into account in an appropriate manner.

Compliance organization

Our compliance and legal organizations have set themselves the goal of ensuring Group-wide conformance with laws and regulations. Our compliance organization is structured in a divisional and regional manner, while our legal organizations are structured divisionally, regionally, and along the value chain. These structures enable us to provide optimal support and advice to our divisions.

A contact person is made available to each function, division, and region. In addition, a global network of local contact persons makes sure that our standards are met throughout the Group and also helps local management at Group companies implement our compliance program.

Involvement of company management

Our divisional and regional compliance managers report to the Chief Compliance Officer. This guarantees the compliance managers’ independence from the business divisions. The Chief Compliance Officer, the Vice President & Group General Counsel, and the Vice President Legal Product & Technical Compliance report directly to the Member of the Board of Management for Integrity and Legal Affairs and to the Audit Committee of the Supervisory Board.

They also report regularly to the Board of Management of Daimler AG on matters such as the status of the Compliance Management System and its further development, the status of the whistleblower system and, if necessary, on other topics. In addition, the Vice President & Group General Counsel regularly reports to the Antitrust Steering Committee and the Group Risk Management Committee, to which the Chief Compliance Officer and the Vice President Legal Product & Technical Compliance also report.

Compliance risks

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We systematically pursue the goal of minimizing compliance risks, and we analyze and assess the compliance risks of our Group companies every year. These analyses are based on centrally compiled information on the Group companies and take specific additional details into account as needed. The results of the analyses form the basis of our risk control.

Compliance program

Our compliance program comprises principles and measures designed to reduce compliance risks and prevent violations of regulations and laws. The individual measures, which are based on the knowledge gained through our systematic compliance risk analyses, focus on the following aspects:

The whistleblower system BPO

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The whistleblower system BPO (Business Practices Office) enables Daimler employees and external whistleblowers to report misconduct anywhere in the world. The BPO is available around the clock to receive information that is sent by e-mail or normal mail or by filling out a special form. An external toll-free hotline is also available in Brazil, the United States, Japan, and South Africa. Reports can be submitted anonymously if local laws permit this. In Germany, whistleblower reports can also be submitted to an external neutral intermediary in addition to the BPO.

The information provided to the BPO whistleblower system enables us to learn about potential risks and specific violations that pose a high risk to the company and its employees, and this in turn allows us to prevent damage to the company and its reputation. High-risk rule violations include, for example, offenses relating to corruption, breaches of antitrust law, and violations of Anti-Money Laundering regulations, as well as serious violations of binding technical provisions. Employees who wish to report violations that pose minor risks can approach their supervisor, their Human Resources department, the Group Security Office or their local employee representation.

A globally valid corporate policy defines BPO procedures and the responsibilities of the various departments and individuals in the organization. This policy aims to ensure a fair and transparent approach that takes into account the principle of proportionality for the affected parties, while also giving protection to whistleblowers. It also defines a standard for evaluating incidents of misconduct and making decisions about their consequences.

In an effort to increase trust in our whistleblower system and make it even better known within the Group, we have established a continuous communication process that includes the periodic provision of information to employees about the type and number of reported violations. We also supply information materials such as country-specific information cards. In addition, we have produced an instructional video and stage dialog events at selected locations as well.

In 2019, 59 new BPO cases were opened. A total of 44 cases in which 72 individuals were involved were closed “with merit.” In these cases, the initial suspicion was confirmed. Seven of these cases were in the category “Corruption,” while five related to “Technical compliance” and five concerned “Reputational damage.” Accusations of inappropriate behavior of employees toward third parties were confirmed in 13 cases. Four cases were categorized as “Damage exceeding 100,000 euros.” The remaining cases fell into other categories. With regard to those cases that are closed “with merit,” appropriate response measures are decided in line with the principles of proportionality and fairness. Personnel measures taken in the reporting year 2019 included the issuing of warnings and final warnings, as well as separation agreements and terminations.

Compliance on the part of our business partners

We also require our business partners to adhere to clear compliance requirements, because we regard our business partners’ integrity and behavior in conformity with regulations as a precondition for trusting cooperation. In the selection of our direct business partners, we therefore ensure that they comply with the law and observe ethical principles. In financial year 2019, we made full use of our globally standardized process for the effective and efficient examination of all new and existing business partners (Business Partner Due Diligence Process). Our continuous monitoring here is designed to ensure that we can identify possible integrity violations by our business partners. We also reserve the right to terminate cooperation with, or terminate the selection process for, any business partner who fails to comply with our standards. In addition, we work with our procurement units to continuously improve our processes for selecting and cooperating with suppliers.

Our global Daimler Supplier Sustainability Standards apply in this area. On the basis of these standards and our Integrity Code, we make available to each of our suppliers and sales partners a specific Compliance Awareness Module developed with their activities in mind. This module also contains provisions similar to those that can be found in the general Compliance Awareness Module for sales partners, which was introduced in 2016 and is designed to increase their awareness of compliance requirements.

Communication and training

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We offer extensive compliance training courses that are based on our Integrity Code. We conduct a training needs analysis at regular intervals, adjust and/or expand the training program, and subsequently carry out an evaluation.

All employees at Group companies can also participate in a web-based and target group-oriented training program consisting of several modules – a basic module, a module specifically for managers, and expert modules on subjects such as antitrust law, data protection, technical compliance, benefits in kind for employees, and function-specific topics in areas such as procurement and sales. Our training activities in 2019 focused on, among other things, web-based courses on technical compliance and antitrust law, expert seminars lasting several days on the topic of data compliance, webinar series on preventing money laundering, and new web-based modules for suppliers and business partners.

Office employees are required to complete those modules relevant to their role and function. We assign the associated modules to them automatically or in a centralized process. These training modules are assigned when an employee is hired, promoted or transferred to a position that involves an increased risk. This approach ensures that personnel changes are properly addressed. In general, the program must be repeated approximately every three years. Factory employees can complete the web-based training program voluntarily.

The web-based training courses are supplemented by classroom training sessions that are conducted by central or local trainers. We provide our internal trainer network with modular training documents and materials for methodical implementation, such as a trainer guideline and explanatory videos that can be used in a target group-specific manner and in accordance with the risks associated with the participants’ jobs. In 2019 a total of approximately 117,600 employees from diverse levels of the hierarchy participated in classroom-based and web-based training programs.

We also offer our employees in the compliance and legal organizations courses that address legal changes and changes to compliance regulations; these courses are taught by experts in the respective fields. In addition, new employees at our integrity, compliance, and legal organizations receive a comprehensive introduction in the course of an onboarding program.

We also offer information and qualification measures to individuals who perform supervisory and management functions, including new members of the Supervisory Board of Daimler AG. Among other things, the onboarding program for new Supervisory Board members provides information about the antitrust compliance program and technical compliance management. In 2019, new members of the supervisory boards of Group companies were also provided with information on various issues relating to compliance, data protection, and integrity. In addition, these new supervisory board members participated in a “Know Your Responsibilities” onboarding program to make them more aware of compliance-related topics (for example anti-corruption policies) and the aspects of integrity at the Group companies.

New members of the executive management of Group companies are given a compact overview of key aspects of corporate governance via the Corporate Governance Navigator, which is a module that provides information on their tasks and responsibilities, contact partners, and points of contact that deal with central issues addressed by the Integrity and Legal Affairs division and adjacent units. The module thus supports such executives in their new role.

All of these training measures contribute to the permanent establishment of ethical and compliant behavior at the company and also help our employees deal with specific issues that can occur at work.

The same is true of the Daimler app for integrity, compliance, and legal affairs. The app is available to all employees with a company-owned device. Among other things, the app enables mobile access to practical information on subjects such as corruption prevention, antitrust law, technical integrity, and data protection, with additional topics being added as required.

Within the framework of our training program, we also offer our business partners special modules on integrity and compliance (including corruption prevention). These courses are offered as web-based training or classroom training sessions. Daimler informs its business partners about the courses and invites them to participate.

7.2 Training in 2019 – Web-based training
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Target group

Number of participants

Basic Module – Integrity@Work (basic knowledge about integrity, corruption prevention, antitrust law, data protection, whistleblower system)

Administrative unit employees in controlled Daimler entities with e-mail address

19,002

thereof

 

administrators worldwide:

18,206

managers worldwide:

796

Management Module – Integrity@Work

Managers worldwide

1,512

Expert Module – Antitrust

Administrative unit employees in controlled Daimler entities with e-mail address

7,433

thereof

 

administrators worldwide:

5,079

managers worldwide:

2,354

Expert Module – EU General Data Protection Regulation

Administrative unit employees in controlled Daimler entities with e-mail address

8,851

thereof

 

administrators worldwide:

7,647

managers worldwide:

1,204

Expert Module – Integrity & Compliance@MS

All employees and managers at Mercedes-Benz Cars Marketing and Sales including controlled Daimler entities

17,755

thereof

 

administrators worldwide:

16,644

managers worldwide:

1,111

Expert Module – Integrity & Compliance@Truck, Bus & Van

All employees and managers at Marketing and Sales Truck, Bus and Van including controlled Daimler entities

15,203

thereof

 

administrators worldwide:

14,033

managers worldwide:

1,170

Expert Module – Integrity & Compliance@DFS

All employees and managers at Marketing and Sales at Daimler Financial Services

207

thereof

 

administrators worldwide:

1

managers worldwide:

206

Expert Module – Technical Compliance & Integrity@Cars and Vans

All employees and managers at Research & Development (R&D) and Mercedes-Benz Cars, Development Vans and parter units ITC and VAN/FT

20,161

thereof

 

administrators worldwide:

17,935

managers worldwide:

2,226

Expert Module – Technical Compliance & Integrity@Trucks

All employees and managers at development, product and platform management at Daimler Trucks

2,623

thereof

 

administrators worldwide:

2,301

managers worldwide:

322

Expert Module – Technical Compliance & Integrity@Buses

All employees and managers at development Daimler Buses

1,137

thereof

 

administrators worldwide:

996

managers worldwide:

141

Expert Module – Integrity & Compliance@Procurement

All employees and managers in purchasing functions worldwide

703

thereof

 

administrators worldwide:

653

managers worldwide:

50

Total

 

94,587

7.3 Training in 2019 – Face-to-face training courses
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Target group

Training sessions

Participants

Antitrust law

Managers and administrators worldwide

208

5,382

Corruption prevention

Managers and administrators worldwide

911

14,460

Module on Integrity and Compliance for newly appointed and promoted managers

Managers

10

291

Senior managers

6

256

technical Compliance Management System training

R&D employees Mercedes-Benz Cars, Vans, Trucks and Buses worldwide

42

1,804

Module on Technical Integrity

Managers from the development departments worldwide

8

703

Data Compliance qualification for Local Compliance Officers

Local Compliance Officers and Local Compliance Managers

6

166

Total

 

1,191

23,062

Monitoring and improvements

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Every year, we review the adequacy and effectiveness of our Compliance Management System and adapt it to global developments, changed risks, and new legal requirements. We also monitor important core processes during the year on the basis of key performance indicators (KPIs) that include process duration and quality. To determine these indicators, we check, among other things, whether formal requirements are met and the content is complete. In addition, we analyze the knowledge gained through independent internal and external assessments.

We use these activities as a basis for defining any required improvement measures, which are implemented by the responsible Group companies and then monitored on a regular basis. The relevant management bodies continuously receive reports on these monitoring activities.

Main topics for compliance management

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Eliminating corruption, preventing antitrust violations, ensuring product compliance with technical regulations and regulatory provisions, combating money laundering and the financing of terrorism, ensuring compliance with sanctions, and observing data protection legislation – we implemented our Compliance Management System (CMS) in order to address exactly these issues, which are extremely important to us. Our Group-wide approach to respecting and upholding human rights is also based on our CMS.

Anti-corruption compliance

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Daimler has committed itself to fighting corruption in its business activities. Along with complying with all applicable laws, this also involves adhering to the rules of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (1997) and the United Nations Convention against Corruption (2003). As a founding member of the UN Global Compact, Daimler also seeks to ensure that not only the company itself but also its business partners act in accordance with the principles of the UN Global Compact. The most important goals here are to fight corruption around the world in order to enable fair competition, eliminate the damage corruption does to society, and thus improve conditions for everyone.

Our anti-corruption compliance program is based on our comprehensive Compliance Management System. The program is globally valid and primarily consists of an integrated risk assessment process that takes into account internal information such as a unit’s business model and external information such as the Corruption Perceptions Index from Transparency International. The results of our risk assessment analyses form the basis of risk-based measures for avoiding corruption in all business activities (e.g. reviews of business partners and transactions) and measures to ensure that special care is taken in contacts with authorities and public officials. Our risk-minimization measures focus in particular on sales companies in high-risk countries and business relationships with wholesalers and general agencies worldwide.

The responsibility for implementing and monitoring measures lies with each Group company’s management, which cooperates closely with the specialist units within the Integrity and Legal Affairs division. Companies exposed to a high corruption risk are supported by an independent Local Compliance Officer who assists the responsible management team with the implementation of the anti-corruption compliance program.

Daimler places the same strict requirements on all of its activities around the world. In addition, we continuously improve our methods and processes and use a variety of communication and training measures to make our employees around the world more aware of the importance of fighting corruption.

In order to ensure an independent external assessment of our Anti-Corruption Compliance Program, KPMG AG Wirtschaftsprüfungsgesellschaft audited the Compliance Management System for anti-corruption in accordance with the 980 standard of the Institute of Public Auditors in Germany. This audit, which was based on the principles of appropriateness, implementation, and effectiveness, was already successfully completed at the end of 2019.

Antitrust compliance

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Our Group-wide Antitrust Compliance Program is oriented to national and international standards for ensuring fair competition. The program establishes a binding, globally valid Daimler standard that defines how matters of antitrust law are to be assessed. The Daimler standard is based on the standards of the underlying European regulations and takes into account established legal practice at European antitrust authorities, as well as the rulings of European courts. The objective of the Daimler standard is a uniform level of compliance and advice in all countries and thus compliance with all local and international antitrust laws.

By means of an advisory hotline, guidelines, and practical support, we help our employees around the world to recognize situations that might be critical from an antitrust perspective and also to act in compliance with all regulations. This is particularly important when employees deal with competitors, cooperate with dealers and general agencies, and participate in trade association committees. In addition to Daimler’s Legal department and its specialist advisers, the Group’s global divisions can turn to local legal advisers, who also ensure that our standards are consistently upheld.

The results of our annual compliance risk analysis serve as the basis for the formulation of measures that address antitrust risks. The responsibility for designing and implementing measures lies primarily with each Group company’s management, which is also responsible for monitoring the effectiveness of the measures employed. Within the framework of its Group management responsibilities, Daimler AG monitors the executive management bodies of the respective Group companies. As a result, managers at Group companies cooperate closely with the Integrity and Legal Affairs division, which also provides information on how to implement compliance measures effectively. Units that face a higher potential risk in particular must also systematically assess the adequacy and effectiveness of locally implemented antitrust compliance measures at regular intervals. In addition, our Legal and Corporate Audit departments conduct monitoring activities at our divisions, as well as random audits, in order to determine whether antitrust laws and internal standards are complied with. This helps us continuously improve the effectiveness of our Antitrust Compliance Program and adapt it to global developments and new legal requirements. The associated methods and processes are being constantly refined and improved.

We utilize a variety of training and communication measure to make our employees aware of the importance of competition and antitrust laws and issues. Such measures during the year under review included both classroom courses and online training courses; the latter are mandatory for staff above a certain hierarchical level. Training in 2019 focused on the topics of “Contact with competitors in general” and “Antitrust cooperations.” Training courses held abroad or at international Group companies are independently organized and conducted by local legal departments as required.

In order to ensure an independent external assessment of our Antitrust Compliance Program, KPMG AG Wirtschaftsprüfungsgesellschaft audited the Compliance Management System for antitrust law in accordance with the 980 standard of the Institute of Public Auditors in Germany. This audit, which was based on the principles of appropriateness, implementation, and effectiveness, was already successfully completed at the end of 2016.

Technical compliance

For us, technical compliance means adhering to technical and regulatory requirements, standards, and laws while taking into account the fundamental spirit of these laws and regulations as well as adhering to internal development requirements and processes. In order to address the specific risks associated with the product creation process, we combined the existing systems and additional measures and processes at the Daimler AG automotive divisions into a technical Compliance Management System (tCMS). The purpose of the tCMS is to safeguard legal and regulatory conformity during the entire product development and certification process and to provide orientation and guidance for our employees by defining specific values, principles, structures, and processes.

The tCMS is managed Group-wide by an independent governance body whose director reports directly to the Board of Management member for Integrity and Legal Affairs. This body consists of employees with expertise in various fields, such as development, legal affairs, integrity, and compliance. In order to provide optimal support to the divisions, the independent governance body has a divisional structure. The governance body’s tasks include the design of the technical Compliance Management System and the provision of legal advice to the divisions.

We have also created dedicated expert units for technical compliance in the development departments at our vehicle-related divisions. Among other things, these units manage a network of technical compliance contact persons at development and certification departments. This network serves as a link between operating units and the compliance organization and also supports the development departments in matters of technical compliance. Complex questions regarding technical compliance are evaluated and then decided in an interdisciplinary process that takes into account technical, legal, and certification-relevant criteria. Our BPO whistleblower system is also available as a contact partner for reporting technical compliance violations.

During the year under review, the Daimler AG Board of Management adopted the tCMS policy. This describes key tCMS elements and defines the roles and responsibilities of all relevant functions. Process descriptions and rules of procedure for tCMS committees in Group companies within the scope of application of the tCMS have been drawn up for relevant tCMS elements. The tCMS policy applies to all Group companies worldwide that conduct relevant development and certification activities.

We have made use of various training and communications measures such as “Tone from the Top” mailings and special training courses and dialog sessions in order to sensitize employees at development and certification units at all divisions to issues relating to technical integrity, compliance, and legal regulations in the product creation process.

The Technical Integrity initiative, as part of the tCMS, focuses on strengthening awareness of the importance of responsible behavior during the product creation process, particularly in situations where legal provisions may be unclear. Together with the relevant development departments, we have supplemented the provisions of the Integrity Code by formulating so-called commitment statements that support employees and offer them guidance for ensuring proper conduct in their daily activities. These principles have been discussed with employees at dialog sessions held around the world. Various communications measures regarding the commitment statements have been made known to all employees and anchored in selected training courses.

We also conduct in-depth discussions on safeguarding technical compliance with business partners and selected suppliers. In October 2019, for example, we held a Supplier Dialog event with relevant suppliers. This event was attended by executives, technical compliance managers, and technical project managers from participating supplier companies. Among other things, the objective here was to make suppliers more aware of the regulatory framework, provide them with information on how Daimler safeguards technical compliance, and explain to them what we expect from our suppliers in this regard.

The effectiveness of our tCMS is monitored in the annual monitoring process. Measures identified by this process are considered in the improvement of the tCMS and are addressed for implementation.

Data compliance

Connectivity and digitalization will have a major impact on mobility in the future. The responsible handling and protection of data that is created and stored by digital systems is a top priority at Daimler.

The regulatory requirements relating to data protection have become significantly more stringent in recent years, mainly as a consequence of the implementation of the European Union’s General Data Protection Regulation (GDPR). We are addressing the increased requirements within the framework of our Group-wide Data Compliance Management System (Data CMS), which along with our data vision and our data culture is a fundamental component of our overarching Data Governance System. Our new Data Protection Policy EU and our Global Data Protection and Information Policy form the basis for the handling of employee, customer, and business-partner data in a sustainable manner in accordance with all legal requirements.

The Data CMS, which combines all Group-wide measures, processes, and systems for ensuring data protection compliance, is based on the existing Daimler Compliance Management System (CMS). The Data CMS supports the systematic planning, implementation, and monitoring of compliance with data protection requirements. Such measures include programs that help ensure compliance with the GDPR and local data protection laws, as well as various communication and training measures and measures for product-related data protection activities.

In 2017 we created the Data Compliance unit to set up the Data Compliance Management System. This unit defines the individual elements of the Data CMS and manages its implementation throughout the Group. To this end, the Chief Compliance Officer submits data compliance reports on a regular basis to the Board of Management member of Daimler AG for Integrity and Legal Affairs, and also provides information on relevant developments in his quarterly reports to the Board of Management.

At the same time, the Chief Officer Corporate Data Protection performs the tasks required by law to ensure compliance with data protection rules. Here the Chief Officer Corporate Data Protection works with a team that monitors compliance with applicable data protection laws and the Daimler Data Protection Policy. In addition, the Chief Officer Corporate Data Protection handles complaints regarding data protection and is also responsible for issuing mandatory reports to supervisory authorities and consulting privacy impact assessments. The Chief Officer Corporate Data Protection is independent and reports directly to the Board of Management member for Integrity and Legal Affairs.

Since the end of 2018, we have been realigning the previous network of local data protection coordinators and merging this network into our global compliance network. This process will be completed by the end of 2020. We specifically prepare Local Compliance Officers and Local Compliance Managers for their new tasks in the field of data compliance and support them with training courses and consultation.

A key component of the Data CMS is the Data Compliance Risk Assessment, which is a systematic process conducted by the Data Compliance unit each year in order to identify, analyze, and evaluate data compliance risks at Daimler. The assessment is performed for both Group companies and corporate departments. The analyses are based on centrally compiled information on all units at the Group; specific additional details are taken into account in line with the given risk assessment. The results of the analyses form the basis for managing and minimizing risks in a targeted manner.

Employees are instructed to report all potential data protection incidents internally via the Information Security Incident Management Process. Criminal violations of data protection rules are addressed by the whistleblower system BPO (Business Practices Office), which can also be used by external stakeholders who wish to report violations of laws or internal regulations.

We document and evaluate the implementation of defined data compliance measures within the framework of a monitoring and reporting process. For example, our compliance organization conducts an annual evaluation to assess the adequacy and effectiveness of our Data CMS. We document in our compliance reporting system any areas where action needs to be taken, and we also monitor the implementation of the associated measures. If necessary, the compliance organization will make adjustments to the Data Compliance Management System on the basis of the knowledge gained from the evaluation, while also taking into account changes to the risk situation and new legal requirements.

Anti-financial crime compliance

Money laundering and the financing of terrorism pose considerable sociopolitical risks. For this reason, the prevention of money laundering and the implementation of anti-money laundering measures have been defined as central compliance goals in our Integrity Code. In its core business, the global production and sale of vehicles, Daimler AG and its Group companies conduct their operations in accordance with the provisions of the German Money Laundering Act (GwG) which apply to “distributors of goods.” As a result, we are required to implement Group-wide and thus worldwide measures to prevent and combat money laundering and the financing of terrorism (Anti-Money Laundering – AML – and Counter Terrorist Financing – CTF – policies).

The Chief Compliance Officer officially serves as the Group Anti-Money Laundering Officer of Daimler AG in its role as a distributor of goods. The Chief Compliance Officer reports directly to the Board of Management and also serves as the point of contact for regulatory authorities, law enforcement agencies, authorities responsible for the prevention, investigation, and elimination of potential threats, and Germany’s Financial Intelligence Unit. In his capacity as the Anti-Money Laundering Officer, the Chief Compliance Officer has sufficient authority and means to perform his duties.

Daimler AG and its Group companies pursue an integrated compliance approach in all areas of the Group and around the world. This approach takes the form of a central Group unit, “Anti-Financial Crime,” and ensures that checks against sanctions lists are always carried out before Anti-Money Laundering measures are implemented. This integrated approach links prevention of the circumvention of supranational and national sanctions with measures to prevent and combat money laundering, the financing of terrorism, organized crime, and other corporate crime. This is important, as these risks can not only have a negative impact on society; they can also cause long-term damage to our reputation, as well as financial damage that can negatively affect our Group companies and our shareholders and stakeholders.

The Anti-Financial Crime specialist unit assists the Anti-Money Laundering Officer by acting as the Group organization for ensuring that Daimler AG and its Group companies comply with the provisions of the GwG across all divisions in their role as distributors of goods. The unit is also responsible for the Group-wide Sanctions Compliance program. As a central Group organization, the specialist unit therefore also brings together under one roof our two Centers of Competence for Preventing and Combating Money Laundering and the Financing of Terrorism and the Center of Competence for Sanctions Compliance.

The Daimler AG Sanctions Compliance Program, which is valid for all Group companies, includes systematic reviews of compliance with sanctions lists by all units, divisions, and companies worldwide. More specifically, such reviews check whether the names of affected natural or legal entities can be found on any sanctions list around the globe. We therefore check both supranational sanctions lists such as those published by the United Nations and the European Union and national sanctions lists from various countries, in particular the United States. As required by law, such reviews are conducted for customers and business partners, for example in sales and procurement, as well as for employees and strategic cooperation partners. Checks against sanctions lists, which are performed in close cooperation with the Export Control department, take data protection law provisions into account.

Measures to combat money laundering and the financing of terrorism are defined for Daimler Mobility AG (DMO) and the Group companies that belong to it by a separate framework divisional guideline that also serves as a basis for the policies at DMO companies. An independent network of local Anti-Money Laundering (AML) Officers has also been established for the individual Group companies allocated to DMO.

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Legal proceedings against companies within the Daimler Group are assessed as significant if they represent a particular financial and/or reputational risk for Daimler. Information about significant legal proceedings against companies within the Daimler Group is provided in the Annual Report for the reporting year 2019 as well as in the relevant quarterly reports.

These reports also contain information on governmental information requests, inquiries, investigations, administrative orders and proceedings as well as litigation relating to environmental, capital-market, criminal, antitrust and other laws and regulations in connection with diesel exhaust emissions.

Provider/Privacy

Daimler AG Mercedesstraße 120
70372 Stuttgart
Germany
Tel.: +49 711 17 0
E-Mail: dialog@daimler.com

Represented by the Board of Management: Ola Källenius (Chairman), Martin Daum, Renata Jungo Brüngger, Wilfried Porth, Markus Schäfer, Britta Seeger, Hubertus Troska, Harald Wilhelm

Chairman of the Supervisory Board: Manfred Bischoff

Commercial Register Stuttgart, No. HRB 19360
VAT registration number: DE 81 25 26 315