Other management systems
Corporate Responsibility in the RWE Group covers a broad spectrum of issues. The responsibility for concepts and their implementation on specific areas for action is with the relevant specialist departments of RWE AG or the Group companies. They have developed tailor-made management systems where appropriate.
Protection of the environment is a statutory requirement for obtaining an operating licence for the maintenance and continuation of the operating licences to run our plants and facilities. Compliance with stringent regulations covering environmental protection is also a requirement of our stakeholders and exerts a direct influence on the reputation of our company. A guideline applicable across the Group therefore commits the companies within the RWE Group to set up appropriate environmental management systems. Operational implementation of environmental protection is therefore under the remit of the individual companies, in accordance with their specific activities and the statutory regulations. The Group Centre has been carrying out audits for more than ten years checking the structure and effectiveness of the management systems at Group companies. On this basis, RWE has set up a stable environmental management system covering 99.6% of the Group. In 2012, RWE AG established its own environmental management system. This means that it is subject to the same requirements which apply to its subsidiary companies. Around 480 employees work at the Group Head Office in Essen. When projects are being developed, one of the central environmental functions within RWE AG is taking account of environmental aspects. The companies in the RWE Group are free to choose whether to have their environmental management systems certified entirely or in parts in conformity with ISO 14001. Virtually all the power stations in the RWE Group are certified in conformity with ISO 14001. The certification level as a function of the number of full-time employees is similar to the percentage of 43.1% in the previous year.
Occupational health and safety
RWE wants to ensure that our workforce and the employees of subcontractors return home just as healthy at the end of the day as they were when they arrived for work. Group-wide coordination of occupational health and safety is handled by the Occupational Safety and Occupational Medicine/Healthcare Management competence centres set up in 2009. They report directly to the Chief Human Resources Officer at RWE AG.
The strategy and measures taken to improve occupational safety are agreed in an international occupational safety forum. Companies operating in the sectors of oil and gas production, lignite mining, electricity generation and grid operation are particularly demanding with respect to occupational safety, and these have had their occupational safety management inspected and certified in conformity with OHSAS 18001 or comparable standards by independent third parties. The level of certification is 33.9% throughout the Group.
Occupational Healthcare Management has been centrally coordinated for all German companies since 2009. The other companies are responsible for the issues of occupational health and occupational medicine. Since 2012, RWE East has therefore started to establish systematic company healthcare promotion.
RWE does not tolerate any corruption or other breaches of compliance. Incidents involving corruption have the potential to cause the company substantial material damage as well as entailing associated serious reputational risks. We therefore attribute great importance to compliance in all business decisions and we do not enter into business relations if potential suppliers and partners fail to live up to our compliance requirements.
RWE has been building up a group-wide system of Compliance Management since 2009. The main focus is on raising the level of awareness and on prevention. The aim is to prevent corrupt behaviour by employees and executive officers of the company right from the start.
A group-wide reference standard sets out a guidance framework for our employees. The principles for compliant behaviour are described in our Code of Conduct. Details are included in the Group guidelines on prevention of corruption. They primarily include guidelines relating to dealings with holders of public office, business partners and politicians, expenditure on donations and sponsorship measures, and handling contracts with consultants. Compliance with the guidelines is supported by organisational regulations, e.g. the double-checking principle, separation of functions, authorisation concept and rules for approval.
Compliance organisation and training sessions
Compliance Management is handled by the Group Centre through the Compliance Department. The Chief Compliance Officer reports directly to the Chief Executive Officer. All the operating companies are integrated in Compliance Management. The companies have appointed their own Compliance Officers who are responsible for ensuring uniform implementation of group-wide compliance principles. We have also appointed an independent external ombudsman. Employees can contact the ombudsman if they have identified breaches of compliance with the Code of Conduct and they do not wish to address these breaches with their supervisor or Compliance Officer. Any inquiries will be treated in strict confidence and will be handled anonymously if requested by the employee. Since the beginning of 2012, the external ombudsman has accepted inquiries from employees of subcontractors, suppliers and other business partners as well as from members of the workforce of the RWE Group. An international law firm is available to all employees of the Group as a contact – supported in some cases by partner law offices – to accept inquiries in the relevant national languages in Germany, the United Kingdom, the Netherlands, Poland, Slovakia, the Czech Republic and Hungary.
Regular communication of information and instructions play a role in raising the awareness of behaviour that conforms to compliance guidelines, as well as the risks to the company and individual employees if compliance is breached. A regular newsletter, articles in our staff newspaper, information events and the group-wide Intranet provide conduits for informing our employees. Our workforce also receives training through a web-based training programme and at presentation events. Participation is obligatory and calibrated according to the risk of corruption associated with the relevant activity. In 2012, we continued to implement a process of ongoing training for corruption prevention. More than 4,850 employees participated in training sessions during the course of 2012.
Compliance supervision and monitoring
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.
Development and application of new technologies, procedures and processes are absolutely essential for the long-term success of our company. Research and development are therefore managed by a dedicated department in the RWE Group which reports to the Chief Commercial Officer. The department draws up concepts outlining the development of future energy supply and defines R&D activities that are necessary to achieve these aims. The department also manages and coordinates the research and development activities in the operating companies as part of the group-wide R&D Strategy. Key criteria for assessing new technologies constitute their contribution to mastering the central challenges of the RWE Group, such as climate protection and security of supply. The development of innovative business models facilitated by new technologies is gaining increased importance, such as the use of CO2 as a raw material, or electromobility.
RWE regards protection against criminal actions as a key factor for success, in order to ensure long-term earnings power, stability and the business success of the Group. The security concept of RWE covers the protection of tangible and intangible assets, and protection of employees against criminal actions as a constituent element of business processes. We have established consistent, group-wide structures, reference standards and processes to achieve this end. Individual national statutory regulations vary to some degree but they are the defining factors. Inclusion of employees and the co-determination committees is an important factor for success in security management. We have carried out group-wide and company-specific activities with the objective of raising awareness for security as an issue.
RWE will follow up all criminal actions and will bring prosecutions before the courts in all cases. A group-wide whistle-blower system is available to all employees for this purpose. The departments of Compliance, Auditing and Security (Group Security) will work closely together in any investigation and review of breaches that may be necessary.
RWE also plays a proactive role in a variety of security partnerships with government authorities and within the industry with the aim of achieving a permanent improvement in its preventive measures. For example, in July 2012 RWE joined the security partnership in Germany for combatting metal thefts.
Energy supply and in particular the supply of electricity constitute a vital infrastructure, and supply bottlenecks occur if there are any outages or impairment of the infrastructure. Such problems may have major economic consequences and public security may be significantly compromised. RWE is the biggest operator of the electricity distribution grid in Germany. We are well aware of our social responsibility and we have regular communication with politicians and the responsible government agencies. Representatives of RWE play an active role in the relevant committees and public bodies.
RWE has a duty of care towards its employees, most importantly also including periods when they are on business trips. RWE works together with specialist partners to carry out security assessments of the countries and regions where we send our employees and to draw up security classifications. Security information and explanations are provided for each country. Business travel to high-risk countries requires security clearance by Group Security and involves security measures. The internal Travel Booking System enables RWE to track the destinations of its employees. Appropriate security training can be provided as required to employees and members of their family for long-term secondments.
We have made comprehensive organisational preparations to overcome crisis and emergency situations. Crisis teams have been appointed at different levels and they are accessible. The information cascade ensures that senior crisis teams are informed at an early stage and appropriate preparations can be made. Manuals, alarm lists or tools, and the necessary technical equipment are available for crisis management. We carry out regular emergency training courses and exercises.
Emergency plans are drawn up at the operational level for different scenarios. The robustness of the approach adopted by RWE was put to the test at the beginning of 2011 when employees and their families were evacuated from Egypt and Libya as part of managing the crisis there.
Restarting business processes after major interruptions is controlled by ‘Business Continuity Management’.