| UN Global Compact principle: X |
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Corruption and bribery impede economic development, deter investors, and contribute to the persistence of poverty in many countries. For this reason, many states have tightened their anti-corruption laws in recent years. In the event of violation, executives and employees as well as the company itself may face considerable consequences under criminal and civil law, e.g., imprisonment, pecuniary fines, confiscation of profits, exclusion from tender procedures, and the revocation of permits. Business customers are also increasingly demanding evidence of effective anti-corruption compliance measures as a prerequisite for cooperation. Effective corruption prevention within the organization is therefore one of the key priorities for the Bertelsmann Executive Board. The objective is to reduce the risk of corruption to the greatest possible extent.
To avoid violations of laws and regulations as well as directives and company guidelines, the Bertelsmann Executive Board created a compliance organization. It appointed a Corporate Compliance Committee (CCC) and established an Integrity & Compliance program. The Integrity & Compliance department is subordinated to the CCC and advises and supports it. The department also handles the global further development of corruption prevention within the Group. The Head of the Integrity & Compliance department reports to the Head of the Corporate Legal department, who also serves as Chair of the CCC. The latter, in turn, reports to the Chairman and Chief Executive Officer of Bertelsmann, who is responsible for matters of compliance within the Executive Board. This organization reflects the relevant standards for compliance management systems that contribute toward mitigating risks in various ways. Its basic elements include the Bertelsmann Code of Conduct, the Bertelsmann Supplier Code of Conduct (see GRI 102-16
), the compliance guidelines, risk analysis, consultation, communication and training measures, whistleblowing systems, and case management.
Bertelsmann complies with all applicable national and international anti-corruption regulations. Bribery and corruption as well as conduct that may harm the company’s assets or those of business partners or third parties are strictly prohibited. Both the Bertelsmann Code of Conduct and the Executive Board Guideline on Anti-corruption & Integrity explicitly prohibit all forms of corruption and bribery. The latter guideline specifies detailed principles and rules of conduct for complying with applicable regulations. Along with instructions for dealing with officials and guidelines for the granting or accepting of gifts in the context of business relations, it prescribes appropriate due diligence processes in dealing with third parties. It also describes the speak-up channels for reporting suspected violations and seeking advice as well as other prevention and control measures. The Executive Board Guideline for Dealing with Reports of Compliance Violations anchors an obligation to report suspected violations of the prohibition against corruption to the Bertelsmann Corporate Center. Another Executive Board Guideline regulates the compliance organization and the role of the compliance officers.
The Bertelsmann Supplier Code of Conduct requires Bertelsmann business partners that work for, with, or on behalf of the company to comply with the same strict anti-corruption rules.
The most important measures in 2021 included the publication of a new Code of Conduct. The findings of the Bertelsmann Compliance Risk Analysis 2021 show that the measures taken minimize the risk of corruption to the greatest extent possible.
