CWT Responsible Business Report 2012 - Carlson Wagonlit Travel

ContentsChapter 3 - Ethics, Compliance, Data Protection2012 Responsible Business Report -chapter 3Compliance governancestructureBCC membershipPresident & CEO(Chairman of the BCC)EVP Traveler & TransactionServicesOur commitmentto ethical businesspracticesThe CWT global compliance governance structure identifiesresponsibility for designing the compliance program,implementing program elements consistent with business needsand ensuring overall accountability for program results.EVP & CFOEVP & General CounselGlobal Compliance LeaderInternal AuditorEVP, Global HREVP & CIOEVP, Global Marketing &Enterprise StrategyRegional Business LeadersGlobal Responsible BusinessLeaderCode of BusinessEthics and ConductPrevention of corruptionand anti-competitivepracticesGlobal data protectionand privacy programBusiness Conduct Council(BCC)The Business Conduct Council is the key compliance governancebody within the company. It was created in 2012 to establish andassure implementation of high ethical standards and businessconduct practices at CWT as well as ensure compliance withapplicable global regulations company-wide.The BCC is responsible for convening thought leaders in the companyto strategically address compliance and ethics issues throughout theorganization. It ensures management alignment and ultimate accountabilityfor the development, implementation, and management of compliancebest practices. In this way, the BCC supports management’s commitmentto sustain the highest level of trust with our customers and promote legalcompliance and high ethical standards throughout the company. The BCCmeets every other month in advance of Board meetings.Key Business Conduct Council responsibilitiesAwareness, supportin implementation,dissemination and promotionof the company’s overallcompliance programs,policies and procedures;Collaboration in respondingto material reports orinquiries from governmentor regulatory agencies;Review of complaintsreceived from internal andexternal sources, includingthe Ethics Helpline;Approval of new policies,procedures, and versions ofthe Code of Business Ethicsand Conduct;Annual assessment ofthe state of complianceand ethics within theorganization; and,Members shall also carry outsuch other duties as may berequired from time to time.Copyright © 2013 CWT23