Integrity and Compliance

Compliance Management

We use Compliance Management to steer responsible action

GRI 103-1

Value-based compliance is an indispensable part of our daily business activities and is firmly embedded in our corporate culture. Daimler is strongly committed to responsible conduct. We expect our employees to comply with laws, regulations, and voluntary self-commitments, and to put our corporate values into practice. We have defined these expectations in a binding form in our Integrity Code.

Compliance values and objectives: What we strive for

The central objectives of our compliance activities are respect for and protection of human rights, compliance with corruption prevention regulations, the maintenance and promotion of fair competition, the compliance of our products with technical and regulatory requirements, adherence to data protection laws, compliance with sanctions, and the prevention of money laundering and the financing of terrorism.

Through our Compliance Management System (CMS) we aim to promote compliance with laws and policies at our company and to prevent misconduct. 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.

Setting priorities: Our Compliance Management focuses on the following topics

Below we explain how we are pursuing our main objectives, what laws and policies provide us with orientation in this regard, and what measures we are specifically implementing:

We combat corruption

GRI 205-1/-2/-3

Daimler has committed itself to fighting corruption — because corruption is harmful to fair competition, society, and our Group. Our corruption prevention measures extend beyond compliance with national laws. We also adhere 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 , we actively contribute to ensuring that not only we ourselves but also our business partners act in accordance with the principles of the UN Global Compact.

Our Corruption Prevention Compliance Program is based on our Group-wide CMS. An important element of this program is the integrated risk assessment. When we assess possible risks, we take into account internal information (e.g. a unit’s business model) as well as external information such as the Corruption Perception Index of Transparency International. We see increased corruption risks in the area of sales activities in high-risk countries as well as in our business relations with authorized dealers and general agents worldwide. The results of the risk assessment serve as our basis for implementing targeted corruption prevention measures that are oriented toward the risk faced by the division or country in question. These measures aim to prevent corruption in all of our business activities. For example, we take a critical look at our business partners and transactions and are especially careful in our interactions with government authorities and officials. In this way we want to avoid any appearance of corruption and bribery from the very start.

The management of each Group company is responsible for implementing and supervising the measures. In this task, the management cooperates closely with the specialist units within the Integrity and Legal Affairs division. Within the framework of its Group management responsibilities, Daimler AG monitors the management activities of each respective Group company. Companies exposed to an increased corruption risk are supported by an independent Local Compliance Officer, who assists the respective management with the implementation of our Corruption Prevention Compliance Program.

In addition, we regularly assess the effectiveness of our measures and are continuously enhancing our methods and processes. Moreover, we offer a variety of communication and training measures to make our employees worldwide aware of the importance of corruption prevention. In order to ensure an independent external assessment of our Corruption Prevention Compliance Program, KPMG AG Wirtschaftsprüfungsgesellschaft audited the Compliance Management System for corruption prevention 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 successfully completed at the end of 2019.

We promote fair competition

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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 distributors, and participate in trade association work. In addition to Daimler AG’s central Legal department and its specialist counsels, 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. 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. Within the framework of its Group management responsibilities, Daimler AG monitors the management activities of the respective Group company. 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. To supplement this, 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 communication and training measures to make our employees aware of the importance of competition and antitrust laws and issues. During the reporting year, the corresponding training courses, which are mandatory for managers of hierarchy level and up, were conducted in an adjusted digital form in response to the covid-19 pandemic. The focus in 2020 was on contact with competitors as well as on cooperations. The local legal departments of foreign Group companies independently organized and conducted additional specific training courses.

In order to ensure an independent external assessment of our Antitrust Compliance Program, KPMG AG Wirtschaftsprüfungsgesellschaft audited the Compliance Management System Antitrust 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 successfully completed at the end of 2016.

We want to safeguard compliance with technical and regulatory requirements

For us, technical Compliance means adhering to technical and regulatory requirements, standards, and laws. In doing so, we take into account the fundamental spirit of these laws and regulations and we adhere to internal development requirements and processes. Our objective is to identify risks within the product creation process (product development and certification) at an early stage and to implement preventive measures. For this purpose we have established a technical Compliance Management System (tCMS) in our automotive divisions. Its objective is to safeguard compliance with all legal and regulatory requirements throughout the entire product development and certification process. The tCMS defines specific values, principles, structures, and processes in order to provide our employees with guidance and orientation, especially with regard to challenging questions on how to interpret technical regulations.

We have also created dedicated expert units for technical Compliance in the development departments in our vehicle-related divisions. Among other things, these expert units manage a network of technical Compliance contact persons within development and certification departments. This network serves as a link between operating units and the compliance organization, that 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 (tCMS committees).

The tCMS is managed group-wide by an independent governance function whose director reports directly to the Board of Management member for Integrity and Legal Affairs. This governance function consists of employees with expertise in various fields, such as development, legal affairs, integrity, and compliance. The governance function is organized by division. It develops the tCMS and provides the divisions with legal advice.

In 2019 the Daimler AG Board of Management adopted the tCMS policy. This policy has since then applied to all Group companies that conduct relevant development and certification activities. It summarizes key elements of the tCMS and defines the roles and responsibilities of all relevant functions. We have developed process descriptions for key elements of the tCMS; the rights and obligations of the tCMS committees are defined in rules of procedure.

Our Whistleblower System BPO is also available as a contact partner for reporting technical Compliance violations, such as infringements of technical provisions or environmental protection regulations.

We have made use of various training and communications measures in order to sensitize our employees at development and certification units in all divisions to issues relating to integrity, compliance, and legal regulations in the product creation process. Among other things, they include special training and management workshops as well as “tone from the top” mailings. In these e-mails, the management teams of the development and certification units explain their expectations regarding ethical conduct to all of the employees in the respective area of responsibility. In addition, they provide information about current compliance issues and about supportive points of contact that the employees can turn to.

To ensure technical Compliance within our supply chain, we also raise the awareness of our business partners, and in particular of our suppliers, regarding the importance of technical Compliance and we communicate our specific requirements in the form of information guidelines, for example. We also engage in dialogs with selected business partners whose scopes of delivery are especially relevant for technical Compliance. In these discussions we communicate how we at Daimler ensure technical Compliance and clearly state what we expect of our business partners.

One element of the tCMS is the Technical Integrity initiative, which helps us to further develop the culture of integrity at the product development units and anchor this culture for the long term.

To complement the Integrity Code, the Technical Integrity Management has worked together with the relevant development units to formulate the “Speak Up” and “Judgment Calls” commitment statement. These principles provide employees with a basis for a shared understanding of responsible behavior in the product creation process, especially in case of unclear legal framework conditions. Moreover, they provide guidance in the employees’ daily work. In 2020 these commitment statement were were communicated by target-specific target group-specific communication measures and online training courses.

In 2020 the development units extensively analyzed the results of the online employee survey “Big Picture Integrity 2019.” The Technical Integrity Management supported them in this task. The results were presented in the in steering committees and were also communicated to the employees and discussed with them. This was used as a basis for identifying fields of action and specifying target-specific measures that the development units implemented by themselves until the end of 2020.

The effectiveness of our tCMS is monitored in the annual monitoring process. The improvement measures identified here are considered and addressed.

In order to ensure an independent external assessment of our tCMS, KPMG AG Wirtschaftsprüfungsgesellschaft audited the tCMS with focus on emissions in accordance with the 980 standard of the Institute of Public Auditors in Germany. This audit with focus on emissions was based on the principles of appropriateness, implementation, and effectiveness, and was successfully completed at the end of 2020.

We handle data responsibly

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 is a top priority at Daimler.

The regulatory requirements relating to data protection have become significantly more stringent in recent years. The strict requirements of the General Data Protection Regulation (GDPR) are valid not only in the European Union but also beyond it. Meanwhile, many countries all over the world that are relevant to Daimler’s business operations have tightened up their local data protection laws. We are addressing the increased regulatory requirements by means 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.

The Data CMS, which combines all Group-wide measures, processes, and systems for ensuring data protection compliance, is based on the existing Daimler CMS. The Data CMS supports the systematic planning, implementation, and monitoring of compliance with data protection requirements.

You can find detailed information about data compliance in the chapter on data responsibility.

We combat money laundering and take precautions against violations of economic sanctions

Money laundering and the financing of terrorism cause tremendous damage — to the economy and society in equal measure. Even an accusation of money laundering can compromise our reputation and have financial consequences for us as well as our shareholders and stakeholders. 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.

We produce and sell motor vehicles worldwide and offer our customers appropriate services as well as suitable financing and mobility solutions. As a result, 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 well as the regulations that apply to financing and leasing companies. For example, we have taken measures throughout the Group to prevent and combat money laundering and the financing of terrorism.

To this end, Daimler AG has developed a two-pillar model that takes into account the different requirements that distributors of goods and financing and leasing companies have to meet. The first pillar for preventing money laundering encompasses the Group companies of Mercedes-Benz AG and Daimler Trucks AG as distributors of goods; the second pillar pertains to the financing companies that are part of Daimler Mobility AG. In this process, the Group Anti-Money Laundering Officer for the distribution of goods reports to the Board of Management member for Integrity and Legal Affairs, whereas the Group Anti-Money Laundering Officer for the anti-money laundering law group Daimler Mobility reports to the Board of Management member for Finance & Controlling. The strategic interaction between the two pillars is ensured by the Anti Financial Crime Committee, which meets three times per year. This committee brings together the Group Anti-Money Laundering Officers and their deputies from both pillars as well as other key stakeholders for compliance and criminal law issues in order to share information.

Daimler AG has appointed the Chief Compliance Officer to officially serve as the Group Anti-Money Laundering Officer for the first pillar of the company’s core business of vehicle sales and services related to the distribution of goods. The company has also appointed a deputy to the Group Anti-Money Laundering Officer and notified the authorities of their appointment. The Chief Compliance Officer reports directly to the Board of Management member responsible for money laundering prevention and is also responsible for anti-money laundering measures at all Group companies involved in the distribution of goods. Moreover, he serves as the point of contact for regulatory authorities, law enforcement agencies, authorities responsible for the investigation, prevention, and elimination of potential threats, and Germany’s Financial Intelligence Unit.

In order to effectively combat and prevent money laundering, Daimler AG and its Group companies involved in the distribution of goods have created the Anti Financial Crime (AFC) central Group unit. This specialist unit supports the Group Anti-Money Laundering Officer by means of an integrated compliance approach. Before we implement measures to prevent money laundering, we check current sanctions lists. On the one hand, these measures enable us to prevent people from evading supranational and national sanctions; on the other, they allow us to combat money laundering, the financing of terrorism, organized crime, and other types of corporate crime.

The AFC specialist unit helps the Group Anti-Money Laundering Officer perform all of his tasks. For example, it ensures compliance across divisions at Daimler AG and all of its Group companies involved in the distribution of goods and is responsible for Group-wide standards and processes pursuant to the German Money Laundering Act. In addition, it is responsible for the Group-wide Sanctions Compliance Program. As a central Group organization, this 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. These are managed by a locally responsible employee in the respective Group companies.

The Sanctions Compliance Program is valid for all Group companies. Among other things, it involves the systematic checking of sanction lists. Business with people, companies, and organizations on these lists is illegal and a punishable offence. As stipulated by law, we compare these lists with the data from customers, employees, strategic cooperation partners, and business partners from areas such as procurement and sales. In doing so, we check both supranational sanctions lists such as those published by the United Nations and the European Union as well as national sanctions lists from various countries, in particular the United States. Checks against sanctions lists, which are performed in close cooperation with the Export Control department, take data protection provisions into account.

The second pillar for preventing money laundering at the Daimler Group consists of the anti-money laundering unit of the Daimler Mobility Group, which combines the Group companies that are part of the Mobility division. It implements the standards of the German Money Laundering Act, in particular those for banks, financial companies, and financial service providers of the Daimler Mobility Group. To this end, Daimler AG has, under the direction of the Daimler Mobility AG Board of Management member for Finance, officially appointed a Group Anti-Money Laundering Officer and a deputy and notified the supervisory authorities of their appointment. Both of these individuals function as contact persons for the corresponding authorities and for local units involved in preventing money laundering and the financing of terrorism.

Another important function for the prevention of money laundering at Daimler Mobility AG is performed by the anti-money laundering@DMO Group Office. On the basis of Daimler Mobility AG’s policy for preventing money laundering and the financing of terrorism, this office implements the regulations of the German Money Laundering Act at the Group companies, develops uniform measures for the prevention of money laundering, and conducts corresponding checks. These activities are performed in close coordination with the compliance organization of the Daimler Group and the AFC specialist unit for the distribution of goods.

The Daimler Compliance Management System: How we are pursuing our goal of compliant behavior

GRI 103-2

Our CMS consists of basic principles and measures that ensure compliant behavior throughout the company. The CMS is based on national and international standards and is applied on a global scale at Daimler. The CMS consists of seven elements that build on one another.

27 | The Daimler Compliance Management System

The Daimler Compliance Management System (Graphic)

The compliance organization: How we embed compliance within the Group

Our compliance organization is structured divisionally, regionally, and along the value chain. As a result, it can provide effective support — for example, by means of guidelines and advice. Contact persons are available to each function, division, and region. In addition, a global network of local contact persons makes sure that our compliance standards are met with. The contact persons also help the management at the Group companies implement our compliance program at the local level.

Moreover, the Daimler Compliance Board provides guidance regarding overarching compliance topics and monitors activities to see whether our compliance measures are effective. The Board’s mission is to react promptly to changes in business models and the business environment, deal with regulatory developments, and continuously enhance the CMS. The Compliance Board consists of representatives of the compliance and legal affairs departments, generally meets four times a year, and is headed by the Chief Compliance Officer.

How we involve the company’s management

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 CMS and its further development, as well as the Whistleblower System BPO.

In addition, the Vice President & Group General Counsel regularly reports to the Antitrust Steering Committee and the Group Risk Management Committee. The Chief Compliance Officer and the Vice President Legal Product & Technical Compliance also report to the Group Risk Management Committee.

The structure of the reporting lines safeguards the Compliance Officers' independence from the business divisions.

Compliance risks: How we systematically identify risks

GRI 205-1

We examine and evaluate our Group companies and corporate departments systematically each year in order to minimize compliance risks. In this process we use, for example, centrally available information about the Group companies, such as revenue, business models, and relations with business partners. If necessary, other locally sourced information is supplemented. The results of these analyses are the foundation of our compliance risk control.

GRI 206-1

GRI 419-1

We assess legal proceedings against companies of the Daimler Group as being significant if they represent a particular financial and/or reputational risk.

Information about significant legal proceedings against companies of the Daimler Group is provided in the Annual Report 2020 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 markets, criminal, antitrust, and other laws and regulations.

Compliance program: The specific measures that we implement

Our compliance program comprises principles and measures that are designed to minimize compliance risks and prevent violations of laws and regulations. The individual measures, which are based on the knowledge gained through our systematic compliance risk analyses, focus among other things on: continuously raising awarenes for compliance, the systematic tracking of information received regarding misconduct and on the formulation of clear standards for the behavior of our business partners. We address these points in greater detail in a later section.

Working together for a fair partnership: The Whistleblower System BPO

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The Whistleblower System Business Practices Office (BPO) enables all employees, business partners, and third parties to report misconduct anywhere in the world. The Whistleblower System BPO is available around the clock to receive information, which can be sent by e-mail or normal mail or by filling out a special form. External toll-free hotlines are also available in Brazil, Japan, South Africa, and the United States. Reports can also be submitted anonymously if local laws permit this. In Germany, whistleblower reports can also be submitted to a neutral external intermediary in addition to the Whistleblower System BPO.

The information provided to the Whistleblower System BPO enables us to learn about potential risks to the company and its employees and thus to prevent damage to the company and its reputation. A globally valid corporate policy defines BPO procedures and the corresponding responsibilities. This policy aims to ensure a fair and transparent process 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.

If the initial risk-based assessment of an incident categorizes it as a low-risk rule violation, the BPO hands the case over to the responsible unit — for example, the HR department, Corporate Security or Corporate Data Protection. The respective unit investigates the incident and deals with the case on its own authority. Examples of low-risk rule violations include theft, breach of trust, and personal enrichment valued at less than €100,000 — if the violation does not fall into the category of corruption.

If the BPO’s risk-based initial assessment categorizes an incident as a high-risk rule violation, the BPO hands the case over to an investigation unit. The BPO provides support for the subsequent investigation until the case is closed. Examples of high-risk rule violations include offenses related to corruption, breaches of antitrust law, and violations of anti-money laundering regulations, as well as violations of binding technical provisions or violations in connection with environmental regulations.

In an effort to constantly increase trust in our whistleblower system and make it even better known to our employees, we use a variety of communication measures. For example, we provide information materials such as country-specific information cards, pocket guides, and instructional videos. We also regularly inform employees about the type and number of reported violations and make case studies available on a quarterly basis.

A total of 53 new cases were opened in 2020. Overall, 42 cases, in which 66 individuals were involved, were closed “with merit.” In these cases, the initial suspicion was confirmed. Of these cases, six were in the category “Corruption,” two were in the category “technical Compliance,” and eight were in the category “Reputational Damage.” In eleven cases, accusations of inappropriate behavior of employees toward third parties were confirmed. Seven cases were categorized as “Damage over €100,000.” The remaining cases fell into other categories. With regard to those cases that are closed “with merit,” the company decides on appropriate response measures in line with the principles of proportionality and fairness. The personnel measures taken in the reporting year 2020 included (written) warnings, separation agreements, and (extraordinary) terminations.

We carefully select sales partners and suppliers

We expect not only our employees to comply with laws and regulations. We also require our sales partners and suppliers to adhere to clear compliance requirements, because we regard integrity and conformity with regulations as a precondition for trusting cooperation.

In the selection of our direct sales partners and in our existing sales partnerships, we therefore ensure that our partners comply with the law and observe ethical principles. To determine this, we use a globally uniform, risk-based Sales Business Partner Due Diligence Process. During the reporting year, we checked all of the new and existing sales partners to see that they fulfilled these requirements. Our continuous monitoring in this area is designed to ensure that we can identify possible integrity violations by our sales partners. We also reserve the right to terminate cooperation with, or terminate the selection process for, any partner who fails to comply with our standards. In addition, we work with our procurement units to continuously enhance our processes for selecting and cooperating with suppliers.

The Daimler Supplier Sustainability Standards also apply to our suppliers. On the basis of these standards and our Integrity Code, we provide them with a Compliance Awareness Module that is developed specifically for each partner. These modules are intended to sensitize them to current integrity and compliance requirements such as those related to corruption prevention and technical Compliance. Through these measures we also offer our sales partners assistance for dealing with possible compliance risks.

Communication and training: How we train our employees with regard to compliance

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GRI 205-2

We offer an extensive range of compliance training courses that are based on our Integrity Code — for example, courses for employees in administrative areas and in the compliance and legal affairs departments as well as for members of the Supervisory Board and the executive management. The contents and topics of the training courses are tailored to the roles and functions of the respective target group. We regularly analyze the need for our range of training program, expand or adapt it, and conduct evaluations.

For all employees in administrative areas a web-based and target group-oriented training program is available consisting of various mandatory modules. The training program encompasses a basic module as well as a module specifically for managers and expert modules on various compliance-related subjects. During the reporting year, we supplemented the basic module with additional content of the revised Integrity Code, e.g. concerning human rights.

These modules are automatically assigned when an employee is hired, promoted or transferred to a function that involves an increased risk. Employees generally have to complete the training program approximately every three years. Factory employees can complete the training voluntarily. The web-based training program is supplemented by face-to-face trainings, some of which we conducted in adapted digital form during the reporting year due to the covid-19 pandemic.

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 the technical Compliance Management System. In 2020, new members of the supervisory boards of Group companies were also provided with information on various topics relating to compliance, data protection, and integrity. As part of the onboarding program, these new supervisory board members are also provided with "Know Your Responsibilties" courses adressing compliance-related topics for example corruption prevention and 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. This module provides information about their tasks and responsibilities, contact partners, and points of contact that deal with central topics addressed by the Integrity and Legal Affairs division and adjacent units. The module thus supports such executives in their new role.

Monitoring and improvement: How we assess the effectiveness of our management approach

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We monitor the processes and measures of our CMS annually and conduct analyses to find out whether our measures are appropriate and effective. For these activities, we rely on information about the Group companies as well as additional locally gathered information. We also monitor our processes regularly on the basis of key performance indicators such as the duration and quality of individual processes. To determine these indicators, we check, among other things, whether formal requirements are met and the content is complete. We also take into account the knowledge gained through both internal and independent external assessments.

If changed risks or new legal requirements call for adjustments, we adapt our CMS accordingly. The Group companies implement the respective improvement measures on their own authority. They also regularly monitor these measures to determine their effectiveness and continually inform the responsible management committees about the results of their monitoring process.

28 | Training program integrity and compliance 2020 - web-based trainings
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Basic modules

These modules are automatically assigned to all of the active administrative employees at Daimler AG and Group companies controlled by Daimler.

 

Basic Module — lntegrity@Work (Key content integrity and compliance as a competitive advantage, corruption prevention, protection of free competition, protection of personal data, human rights, tip-offs of rule violations)

Number of participants

150,055

thereof

 

administrative employees worldwide:

133,162

managers worldwide:

16,893

Basic Module — Sustainability

Number of participants

148,657

thereof

 

administrative employees worldwide:

131,832

managers worldwide:

16,825

Management module

This module is automatically assigned to all of the managers at Daimler AG and Group companies controlled by Daimler.

 

Management Module — Integrity@Work

Number of participants

16,814

thereof

 

managers worldwide:

16,814

Expert modules

These modules are automatically assigned to the relevant administrative employees at Daimler AG and Group companies controlled by Daimler.

 

Expert module — Anti-Money Laundering (Rollout started in December 2020)

Number of participants

2,678

thereof

 

administrative employees worldwide:

2,410

managers worldwide:

268

Expert Module — Antitrust Overview

Number of participants

22,226

thereof

 

administrative employees worldwide:

16,575

managers worldwide:

5,651

Expert Module — EU General Data Protection Regulation

Number of participants

6,347

thereof

 

administrative employees worldwide:

5,763

managers worldwide:

584

Expert Module — Integrity & Compliance@DMO

Number of participants

89

thereof

 

administrative employees worldwide:

52

managers worldwide:

37

Expert Module — Integrity & Compliance@MS

Number of participants

2,519

thereof

 

administrative employees worldwide:

2,413

managers worldwide:

106

Expert Module — Integrity & Compliance@ Procurement

Number of participants

968

thereof

 

administrative employees worldwide:

851

managers worldwide:

117

Expert Module — Integrity & Compliance@ Truck, Bus and Van

Number of participants

1,583

thereof

 

administrative employees worldwide:

1,457

managers worldwide:

126

Expert Module — Intellectual Property

Number of participants

21,774

thereof

 

administrative employees worldwide:

19,524

managers worldwide:

2,250

Expert Module — Social Compliance

Number of participants

128

thereof

 

administrative employees worldwide:

80

managers worldwide:

48

Expert Module — Technical Compliance & lntegrity@Buses

Number of participants

158

thereof

 

administrative employees worldwide:

150

managers worldwide:

8

Expert Module — Technical Compliance & lntegrity@Cars and Vans

Number of participants

2,165

thereof

 

administrative employees worldwide:

2,039

managers worldwide:

126

Expert Module — Technical Compliance & lntegrity@Trucks

Number of participants

774

thereof

 

administrative employees worldwide:

691

managers worldwide:

83

29 | Training program integrity and compliance 2020 - face-to-face trainings*,**
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Number of events

Number of participants

Corruption prevention (incl. general compliance topics)

394

7,868

Anti-money laundering

140

3,026

Antitrust law

85

2,518

Sanctions compliance

52

1,058

Data compliance

231

7,536

Technical compliance

49

2,917

*

Some of the face-to-face trainings courses were conducted in adapted digital form during the reporting year.

**

Target group: relevant managers and adminstrative employees worldwide

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: Bernd Pischetsrieder

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

UN Global Compact

The United Nations (UN) Global Compact is a pact concluded between companies and the UN in order to make globalization more socially and environmentally friendly. The companies regularly report to the UN on the progress they make.

All glossary terms