MAN Compliance Program

Engagement at MAN

Tone from the Top

The Executive Board of the MAN Group is aware of its responsibility for compliance and is fully committed to it. The Compliance Officers regularly brief the Executive Board of MAN SE and the Executive Boards of the subgroups as well as the heads of other functions (such as Legal, Accounting, Controlling, and Corporate Audit) on the progress of compliance activities, any compliance incidents, and the action taken in this respect. MAN’s Executive Board and its managers consider compliance to be an integral part of the Company. They encourage a culture of transparency and integrity. Compliance violations are not tolerated.

MAN SE's Chief Executive Officer Joachim Drees states: "Compliance is an integral part of MAN's corporate strategy. All employees must be aware of their individual responsibility and make their contribution to fulfilling our corporate responsibility jointly. Compliance with laws, ethical values, and internal policies is a matter of course for everything we do - everywhere and at all times. When it comes to the infringement of law we live zero tolerance."

Communication

Compliance topics are featured regularly in MAN’s company media, such as newsletter, employee magazines and the intranet. Furthermore new compliance policies are not only communicated to employees via the intranet and e-mail, but also in compliance training sessions. The GRC Organization’s contact details are published on the MAN Group’s intranet; employees can contact the GRC Organization in case of doubts or questions at any time. Furthermore, employees worldwide use the Compliance Helpdesk to ask questions and find out more about compliance topics.

Further communication measures, for example the organization of internal information events and the development of an internal poster campaign ensure that employees are comprehensively informed and sensitized on compliance issues. Compliance is on the agenda of Executive Board meetings and manager events on a regular basis.

Reporting and checking

In order to ensure that the Compliance Program is sustainable, MAN continuously reviews its efficiency and its effectiveness. In 2015, an external auditing company audited the Compliance Management System implemented at MAN Group on the basis of IDW auditing standard 980 and confirmed its appropriateness and effectiveness. In addition to that, the compliance checks and an analysis of any compliance violations ensure that any weaknesses in the GRC Organization are identified and that the compliance system is adapted accordingly.

Furthermore, the GRC Organization continuously tracks implementation of the compliance measures and ongoing projects. Examples of this include regular recording and analyses of the number of business partners recorded in the Business Partner Approval Tool and the number of inquiries processed by the Compliance Helpdesk. This means that the efficiency of the GRC Organization is continuously monitored.