Compliance
At the start of 2006 MAN implemented a »Code ofConduct« for all employees; a Compliance Board was also established at the same time. The Code of Conduct – a behavioral code based on the MAN Group’s mission statement (available online at www.man.eu) – lays down fundamental rules for employees, serves as an orientation guide and contains minimum standards that are mandatory for all MAN Group employees worldwide.The aim of this behavioral guideline is to support employees in their encounters with legal and ethical challenges in their everyday work routine, to provide orientation and encourage appropriate conduct. A Compliance Board was also set up in 2006 comprising managers from the Controlling, Communications, HR, Legal and Auditing departments. The Compliance Board deals with issues relating to and further development of the Code of Conduct and with fundamental issues relating to compliance within the MAN Group. It also organizes training courses and studies. The Compliance Board has set up a hotline for reporting possible compliance infringements and to answer questions. An external ombudsman was also appointed to receive and assess reports of possible misconduct from employees; he can then forward such reports to the Compliance Board for further investigation, maintaining the anonymity of the informant where requested.
In 2008 executives and employees received intensive training on issues and procedures, in compliance with the law. All executives underwent mandatory web-based training that is now being extended to other groups of employees. Numerous training courses were also held locally in relevant departments. Compliance with the »Code of Conduct« is monitored by the Group’s central Auditing department.
In May 2009 the Public Prosecutor’s Office Munich I searched offices of MAN SE and MAN Nutzfahrzeuge AG in Munich along with branches of MAN Truck & Bus Deutschland. There was a suspicion that between 2002 and 2005, inadmissible consultancy/commission payments were made in connection with the sale of commercial vehicles in particular. Working closely with the investigating authorities, MAN immediately took measures to ensure the allegations made were quickly clarified in full.
MAN immediately began internal investigations by external lawyers and fiscal experts and started implementing five urgent measures to clarify the allegations of bribery and improve safeguarding against corruption at MAN:
- Informing the public prosecution authorities in any future compliance cases
- Reviewing and strengthening the compliance organization
- Increasing staff in the Audit function
- Reviewing the organization and processes of commercial vehicle sales
- Dialogue with anti-corruption experts from non-governmental organizations (NGOs).