Our compliance management system (CMS) is a key element of our corporate management
Strict compliance with legal requirements is an indispensable component of our corporate culture. Our compliance management system (CMS) therefore forms a key element of our corporate management. The system helps us to ensure that legal requirements are complied with while also ensuring that our in-house guidelines are implemented and the ethical standards to which we are committed are met.
The CMS covers all of MVV Energie’s material business activities and business processes. A detailed Compliance Handbook describes both the material contents and the necessary organisational structures and processes, as well as the relevant personnel responsibilities and our reporting system. This handbook is binding for all of MVV Energie’s group companies and – as part of our Management Handbook – is permanently available to all employees on our intranet.
We have structured our CMS in such a way as to ensure that relevant processes in sensitive areas are checked in advance already. This way, we can avert any infringements and take corrective measures on a preventative basis. To this end, we do not check our processes in reaction to incidents, but rather structure our sensitive processes so as to ensure that compliance-relevant requirements are already adhered to as part of the respective business process (systemic compliance).
Donations and payments to political organisations are strictly prohibited at the MVV Energie Group. Payments to capital providers are made exclusively in the form of dividends.
Our Compliance Officer (Head of Group Legal, Compliance and Materials Division) liaises with the business units thereby affected to compile compliance-relevant requirements, document and explain these requirements, monitor their implementation and ensure they are adhered to. Furthermore, he trains employees on the key focuses relevant to their individual activities, checks compliance with all CMS processes and reports to the Executive Board. The Compliance Officer advises and supports the Executive Board with regard to preventative measures intended to avoid and, where necessary, investigate any infringements of the law, corruption or deliberate acts harmful to the company.
We pay particular attention to providing employees working in sales, sales-related areas and procurement with detailed information about corruption prevention and extensive explanations of the correct way to deal with offers of gratuities and invitations.
Furthermore, an anonymous Whistleblower Hotline enables employees and third parties to contact the Compliance Officer or an external confidence lawyer directly and to report any misconduct.
We provide regular training to ensure that all managers working at the MVV Energie Group are familiar with general compliance requirements and with the legal requirements relevant to their respective business units. The requirements are specifically laid down for each area of responsibility at the business units.
Compliance Management Declaration
Moreover, our managers are also obliged to submit an extensive Compliance Management Declaration (CMD) at the end of each year under report in which they confirm that the relevant legal requirements have been complied with. This CMD also includes a declaration by individual managers that their employees have received instruction and been trained for the CMS. Furthermore, in the context of the CMD the managers must also respond in detail to questions specifically tailored to circumstances at their respective business units.
To inform new management staff about the basis for assuming management responsibility at the MVV Energie Group, these managers are required to take part in a seminar held over several days, with attendance obligatory for all managers from section manager upwards. At this seminar, we provide all newly appointed managing directors and each new manager with structured instruction on all areas of responsibility.
Compliance at suppliers
We survey the suppliers and service providers to our material company locations in Germany about their compliance. Moreover, for major tenders and contracts our central procurement department obtains supplier self-registration and supplier information. This way, we ascertain
- Which compliance and anticorruption regulations are applicable at the respective supplier and whether these also apply to its upstream suppliers and subcontractors
- Whether working conditions comply with the relevant national laws and regulations and whether internationally recognised labour standards are complied with
- Which nonmonetary company goals, such as voluntary environmental protection measures or educational, cultural or sports sponsoring activities, are pursued.
Further key components of our corporate management include our risk management system and the internal control system in respect of the financial reporting process (IKS).