BMW 2008 Annual Report Download - page 140

141 Corporate Governance
own initiative, check compliance with the law and commu-
nicate regularly with staff on this issue. Any indications
of non-compliance with the law must be rigorously investi-
gated.
As part of the first implementation phase, more than ,
managers received training in essential compliance matters
in . This training is obligatory for all managers working
for the BMW Group and is available in the form of web-
based training sessions in either German or English. Suc-
cessful participation in the relevant training sessions is
documented in a certificate. This basic training is also sup-
plemented by training sessions for specific target groups
covering specific compliance issues.
In order to avoid legal risks, all members of staff are
ex-
pected to discuss matters with their managers and with
the relevant departments within the BMW Group, in par-
ticular the Legal Department, the Group Internal Audit
Department and the Group Security Department. As a
fur-
ther point of contact (telephone or e-mail), the BMW Group
Compliance Contact was set up in  for employees
and non-employees with questions regarding compliance.
This also applies if weaknesses or circumstances have
been identified which could result in non-compliance with
the law. Information can also be provided anonymously if
so desired.
Compliance-related queries and all matters to which atten-
tion has been drawn are documented and followed up by
the Compliance Committee Office, where necessary with
the assistance of Group Internal Audit, Group Security
and legal advisory departments. A reporting system is cur-
rently being established for the Compliance Organisation
which will enable compliance-relevant issues to be reported
to the Compliance Committee on a regular basis, and –
where necessary – on an ad hoc basis. This includes re-
porting on the status and the progress made in setting up
the Compliance Organisation, identified legal risks and
incidences of non-compliance as well as corrective / p r e -
ventative measures implemented.
Compliance with, and the implementation of, the LCC is
reviewed regularly by the Group Internal Audit and Group
Security departments. For this purpose, the Group Internal
Audit Department also performs on-site audits and inter-
views employees.
It is essential that employees are aware of, and comply with
applicable legal regulations. The BMW Group does not tol-
erate violations of law by its employees. Culpable violations
of law may result in employment-contract sanctions and
personal liability consequences for the employee involved.
In order to avoid this situation, the BMW Group’s employ-
ees are – via various internal channels – kept fully informed
of the tools and measures used by the Compliance Organi-
sation. The central channel of communication is the Com-
pliance website within the BMW Group Intranet where
employees can find compliance-related information and
also have access to training materials, in both German and
English. Employees can use the website to access fre-
quently asked questions (and related answers) on compli-
ance-related issues.
In the interest of investor protection and in order to ensure
that the BMW Group complies with regulations relating to
potential insider information, the Board of Management
appointed – as early as  – an Ad-hoc Committee which
is made up from representatives of various specialist de-
partments and whose members examine the relevance of
issues for ad-hoc disclosure purposes. All persons work-
ing on behalf of the enterprise and with access to insider
information in accordance with existing rules have been,
and continue to be, included in an appropriate list – which
is regularly updated – and informed of the duties arising
from insider rules.
Compensation Report
The BMW Group supports the endeavours of the German
Corporate Governance Code (GCGC) to increase trans-
parency in the disclosure of the components of compen-
sation. The following section therefore describes the
principles relating to the compensation of the Board of
Management and the stipulations set out in the statutes
relating to the compensation of the Supervisory Board. As
well as discussing the structure of remuneration, the com-
ponents of compensation are also disclosed in absolute
figures. In accordance with the recommendations of the
GCGC, the compensation of each member of the Board of
Management and the Supervisory Board is disclosed by
name and analysed into components.
. Compensation of the Board of Management,
Responsibilities
In order to increase the efficiency of the Supervisory Board’s
work in personnel-related matters, the task of determining
the remuneration of the Board of Management has been
delegated to the Personnel Committee. The Supervisory
Board is informed regularly and in detail of the work of the
Personnel Committee.
Overall objectives
The compensation model used for the Board of Manage-
ment should be attractive in the context of the competitive
environment for highly qualified executives. The objective
of the variable component of compensation is to create