2008 I 2009 Sustainability Report - Econsense

Comprehensive "Corporate
Compliance" rules
The issue of compliance with legal regulations
and internal company guidelines has
gained considerably in importance in recent
years. The reason that this is so is the everincreasing
complexity of the legal and regulatory
framework as well as the growing interest
among the public at large. The EnBW
Management Board responded to this by
taking various measures at the beginning of
2009: firstly, the new "Corporate Compliance"
unit was set up, pooling all the existing
activities in this area in a central function
at the Holding company: these
activities include all measures to avoid
corruption, antitrust violations and breaches
of trust as well as measures to coordinate
these activities with the "Unbundling Compliance"
unit. In addition, there are now interfaces
to the risk management and crisis
management functions. The compliance
system also addresses the protection of employees,
our customers and the public at
large as well as the protection and conservation
of nature and the environment. A further
compliance issue is how we conduct
our dealings with foreign business partners.
Among other things, this area also supplements
our supplier assessment system,
which has been in place since 2007 with the
aim of performing "supplier prequalification"
at national level – in particular with
regard to environmentally relevant issues.
2008 Annual Report, p. 81 et seq.
The compliance organisation at EnBW
basically comprises the following elements:
› The Management Board of EnBW bears
overall responsibility for compliance and
is the top-level body for questions and
decisions.
› The "Corporate Compliance" unit is responsible
for the implementation and
ongoing development of the tools and
methods that make up the compliance
management system. This unit reports
directly to the member of Holding Man
agement Board in charge of personnel, legal
affairs and IT.
› The "Compliance Committee" is an internal
advisory body; its members are the heads of
the 15 most important compliance functions
within the Group – such as legal
affairs, auditing, environmental protection,
work safety or data protection.
› In the Group companies, there are compliance
officers who act as decentral contacts
and who contribute their expert knowledge
in the specialist areas of the companies.
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