Compliance management

The law and our Code of Conduct as well as other internal policies require DHL Group's management and employees to comply with the applicable regulations.  As one of the leading global companies in its industry, DHL Group is also faced with increasing demands from its investors, customers, business partners and employees. In order to address potential compliance challenges and risks, we have established the DHL Group CMS.

To foster compliance, DHL Group implemented its Group-wide Anti-Corruption and Business Ethics Policy as early as in 2009 which prohibits improper, unethical or illegal action and promotes the performance of due diligence on major sub-contractors, joint venture partners and careful evaluation of our representatives, agents and consultants providing important elements of our services.

The Competition Compliance Policy (also introduced in 2009) contains rules on how to compete fairly and openly in the marketplace.

Our managers serve as role models. We expect them to lead by example in both behavior and values, foster both the corporate culture and the principles of DHL Group in everything they do, and communicate these values to our business partners. Through targeted communication and regular training, we help our employees and business partners to both understand and adhere to our compliance policy and rules. We also encourage our employees to be alert to compliance violations and to report them through various internal channels, including our dedicated Incident Reporting System. Compliance is thus an integral part of our corporate culture and is lived out at all levels of the Group; its cornerstone is the Group's Code of Conduct.

Compliance is a management responsibility and is thus overseen by all management bodies within the Group. Responsibility for designing the compliance management system lies with the Chief Compliance Officer, who reports directly to the Chief Financial Officer. The Chief Compliance Officer is assisted by the Global Compliance Office, which establishes Group-wide standards for compliance management and supports the corresponding activities of the divisions.

Each of the five operating divisions has a Compliance Officer who can draw on additional local resources and regularly presents a report to the divisional Board of Management. The activities and the content of the reports drawn up by both the divisional Compliance Officers and the Global Compliance Office are incorporated into the quarterly update reports to the Board of Management as well as the annual report to the Finance and Audit Committee of the Supervisory Board.

The continuous assessment and evaluation of our company-specific risk profile in an integral part of our compliance management system; the system focuses on antitrust and competition law, bribery and corruption, as well as fraud and embezzlement for purposes of self-enrichment.

Based upon the assessment of DHL Group's compliance risks, principles and measures were introduced to curb compliance risks (e.g., business partner screening) and thus to avoid compliance violations. The Group is highly selective in its choice of qualified and ethical business partners.  The DHL Group Anti-Corruption and Business Ethics Policy contains criteria when to perform due diligence on sub-contractors, joint venture partners, representatives, agents and consultants providing important elements of our services. A Supplier Code of Conduct has been established in co-operation with Corporate Procurement to ensure that our suppliers and vendors understand DHL Group's expectations for those who are acting on the Group's behalf. The Compliance Program also includes measures to identify and deal with compliance violations (incident reporting system).

Each employee affected and relevant third parties are informed of DHL Group's Compliance Program so that they can understand and meet their functions in the CMS sufficiently. A specific online training program was developed to educate relevant target groups regarding the Group's general integrity standards as well as more specific topics such as corruption and competition law aspects.

The structure of the compliance organization, the Compliance Program tailored to DHL Group's needs, and additional measures to avoid compliance risks are derived from the results of the compliance risk analysis and compliance audits.

Any compliance violations discovered are also used to continuously develop and improve the compliance system.  This enables DHL Group to ensure that its integrity and Compliance Program is sustainable.