We set up a group-wide database in 2010 to deliver comprehensive documentation of all compliance-sensitive procedures. This stores all information and documents relating to expenditure on donations and sponsorship, compliance-relevant contracts with consultants, and promotional gifts to holders of public office from a specified amount. The database safeguards the maximum possible transparency within the company for all transactions relevant to compliance. They also offer our employees comprehensive advice and support in processing the defined transactions through help options and links to the relevant Group guidelines. The obligation to use the Compliance IT Tool ensures that statutory regulations and internal guidelines within the Group are complied with. It also provides employees with greater protection against any infringements of the law.
We systematically identify and evaluate the compliance risks that occur for the RWE Group in the area of corruption. The process adopts a two-stage approach. In the first phase, we determined the risk profiles of the Group companies which report directly to RWE AG during the course of 2012 with reference to an internal list of criteria. In a second stage, we will carry out a close analysis of the measures taken by the companies to prevent corruption during the course of 2013.
The Group Audit Department carries out regular preventive Compliance Audits in the Group companies in order to review the effectiveness of our Compliance Management across the Group. The focus of the review includes implementation of compliance-relevant Group guidelines. The Group Audit Department also consistently follows up any information on potential breaches of compliance. If necessary, measures to remedy the situation are subsequently initiated. If personal misconduct is involved, the entire spectrum of measures under employment law may be brought to bear, through to termination of the employment relationship. Notifications of compliance breaches are dealt with by the Compliance Department of RWE AG and the relevant Compliance Officers of the Group companies. The audits carried out by the Group Audit Department for the year 2012 revealed no serious or systematic breaches of our compliance guidelines. However, there were deviations in processes and documentation which have been remedied without delay.
The Executive Board of RWE AG commissioned an audit of the Compliance Management System (CMS) to combat corruption in accordance with the Audit Standard 980 drawn up by the German Institute of Auditors (Institut der Wirtschaftsprüfer) for 2012/2013 in order to ensure independent monitoring of the compliance system. In August 2012, auditors KPMG started to audit the conceptual approach and the appropriateness of the CMS. The audit of the effectiveness will follow in 2013.
In November 2012, RWE established the German Institute for Compliance (DICO) together with other major companies. The aim of the institute is to work together with academics on more advanced practical compliance management systems that take international developments into account.
German Institute for Compliance (DICO – only German)