"Perspectives 2011" - Sustainability and Annual Report (pdf)

Introduction Company profile and strategyService portfolio Communication and social responsibilityTransparency guidelinesThe FMG Group has a number of organizational hand -books that set out requirements governing processesin Group companies (excluding special purposeentities). There are numerous compliance guidelineson public procurement law, procurement and contractingprocesses, and information security. Theseensure that processes and procedures are transparentand traceable, both internally and externally. Incontracting and tendering procedures, FlughafenMünchen GmbH requires bidders to submit a dec -laration of commitment, stating that they will undertakeeverything necessary to preclude corruption.Compliance failures are liable to sanctions, such asexclusion from the contracting process.Analysis of procurement processesTo improve security in procurement, assessments areconducted on a quarterly cycle to identify possiblecases of noncompliance with Group procurementrules and practices. The standard procurement pro -cesses in different parts of the organization are analyzedto determine whether competition criteria arebeing met in individual instances.Checks are performed to ascertain whether a unitawarding a contract has obtained three competingbids as required under in-house rules or, if it has not,whether it can present adequate justification.In addition, invoices for which there is no matchingorder in the SAP enterprise software systemare scrutinized. The purpose is to reduce so-calledmaverick buying (procurement outside our standardprocurement routes) as this can result in savings.AnticorruptionIn 2010 we published our updated FMG Code of Con -duct. This describes fundamental corporate principlesfor ensuring legally compliant and ethical behavioramong our employees and managers. Available onthe intranet, the Code includes rules prohibiting theacceptance of gifts, entertainment or favors and thegranting of favors to third parties, as well as ruleson sideline work and regulations on contract awardprocedures. It also references other guidelines bywhich employees must abide. The Code’s purposeis to ensure that proper procedures are followed inconnection with procurement and the award andhandling of contracts.We regularly provide training and publish informationto make sure that employees and managersare familiar with the guidelines and any updates oramendments to them. We also require companymanagers and employees to confirm by signaturethat they acknowledge the FMG Code of Conductand that they undertake to support and abide by it.In the event that a unit or individual is confrontedwith an issue or situation that is unclear, they canseek advice from the Compliance department.Through to the end of 2010, our head of internalauditing also served as the Group’s anticorruptionofficer. On January 1, 2011, this role passed to thehead of our newly formed Compliance department.During 2011, as part of ongoing efforts to refine ourcompliance management system, we began cata -loging specific compliance risks. This process encompassesall units at Flughafen München GmbHand all FMG Group subsidiaries.Our anticorruption officer has reported that therewere no alleged cases of corruption at FlughafenMünchen or its subsidiaries in 2011. One case ofsuspect pricing was investigated where it appearedthat price-setting had not been on a competitive basis,but the suspicion proved unfounded.Electronic whistle-blower systemOn July 1, 2011, we rolled out an electronic whistleblowersystem. Known as the Business KeeperMonitoring System (BKMS ® System), it enablesGroup employees, business partners and customers122