In addition to preventing compliance violations and detecting misconduct, a quick, effective and systematic response to misconduct constitutes the third pillar of the MAN Compliance Program.
Development of MAN Compliance
If there is a compliance violation, the responsible employee of the GRC Organization analyzes the background and the reasons behind the violation. The findings from this analysis are used to uncover any weaknesses in the Compliance Program and to settle them accordingly. Any compliance violations discovered are used to continuously develop and improve the compliance system. This enables MAN to ensure that its Integrity and Compliance Program is sustainable.
Investigations by authorities
MAN stands for openness and transparency, which is why it cooperates closely with the responsible authorities if they need to carry out investigations or have questions for the Company. The GRC Organization has also issued a set of instructions on how to proceed in the event of searches that tells all employees how to behave when authorities conduct investigations. This set of instructions emphasizes the importance of openness, transparency, and cooperation. Thus, MAN has clearly communicated to all employees that they have to inform the GRC Organization in the event of investigations and that they have to cooperate with the authorities.
MAN does not tolerate any compliance violations. If compliance violations are identified, the Corporate Audit department suggests suitable and appropriate sanction measures. An internal MAN committee, in which the GRC Organization is represented, then decides whether these sanctions will be implemented. Sanction measures range from action under labor law to civil law, depending on the severity of the violation. Implementation of sanction measures is monitored within the Group.