Compliance System

Our Code of Conduct is a key element of our compliance system. Bilfinger Berger is aware that only responsible actions and the observance of ethical principles can effectively protect the interests of the Group and its partners. We have clearly defined these principles in our Code of Conduct. The principles of conduct that apply to all of the Group’s employees include fundamental rules to combat corruption, bribery, prohibited agreements and illegal employment, as well as dealing with confidential information, donations and social behavior at work. As different legal and social conditions exist in Germany and abroad, the Code also includes country-specific behavioral guidelines.

The propagation and application of our Code of Conduct is ensured by a network consisting of the Group’s Chief Compliance Officer, compliance officers in the main operating companies who report to him, and compliance executives in the Group’s larger operating units. In addition to the function of internal ombudsmen, we have also appointed an external ombudsman, attorney at law Dr. Erich G. Bähr, through whom misconduct can be reported not only by employees but also by persons outside the Group. Any information given to the ombudsman via the hotline remains anonymous because calls made to this special telephone number cannot be identified. Internal whistleblowers are protected against any reprisals; the voluntary disclosure of one’s own misconduct is to the advantage of the employee concerned.

The control systems we have implemented to ensure adherence to the Code of Conduct include routine and special audits by Corporate Internal Auditing, special controls on adherence to competition regulations and employee deployment, and the regulation and monitoring of third parties’ involvement in the obtaining of orders. Our Code of Conduct and the compliance system are at the focus of employee events,employee discussions and numerous training courses. With the elearning program we launched in 2009, we are able to train a large number of employees in compliance in a short time via the intranet without them having to leave their workplaces.

The Executive Board, the Audit Committee of the Supervisory Board and the entire Supervisory Board are comprehensively informed about developments in this area through the immediate reporting of serious cases and through the Chief Compliance Officer’s quarterly and annual reports.

The Chief Compliance Officer is supported in the general design and further development of the compliance system by a Compliance Committee, which convenes at least once a quarter and is composed of the heads of the corporate functions of Legal, Internal Auditing and Human Resources.

If information is received about possible compliance infringements, we take active steps with our own investigations, inform the responsible authorities, and cooperate with them wholeheartedly on the clarification of the matter. Any misconduct revealed results in organizational measures being taken as well as personnel consequences. The internal findings from reporting, comparisons with other systems and assessments by external experts facilitate the continual further development and improvement of our compliance systems.

External ombudsman for the group

Dr. Erich G. Bähr
Lawyer
Phone: +49 (0) 69 74 5050
Fax: +49 (0) 69 74 6861
E-Mail: [email protected] 


Compliance Hotline

Phone: +49 (0) 180 1240 843
3.9 cent/min from a Deutsche Telekom landline, maximum price from mobile networks 42 cent/min, prices for international networks may differ