Compliance Management at Schaeffler
Integrity and compliance are significant cornerstones of the Schaeffler Group’s manner of conducting business. Business activities must always be in line with the values of Sustainable, Innovative, Excellent, and Passionate.
Integrity as integral part of our corporate culture
Code of Conduct & Business Partner Code of Conduct
Under the Schaeffler Code of Conduct, the board of managing directors and all employees undertake to comply with the values and principles of conduct established as well as local, national and international laws and regulations. The Schaeffler Group expects the same from its business partners in accordance with the Business Partner Code of Conduct.
To ensure compliance throughout the entire supplier network, the supplier’s acceptance of the Schaeffler Group’s Business Partner Code of Conduct is mandatory for all Schaeffler’s existing and future business relationships.
Elements of our compliance management systems
The elements of the compliance management systems of our compliance organization are largely based on our understanding of the seven core elements of the IDW AsS 980.
Culture
- Basis for the adequacy and effectiveness of the CMS.
- Attitude and behaviours of management, e.g., tone from the top.
Objectives
- Definition of key objectives to be achieved with the CMS.
- Definition of essential sub-areas and the rules to be observed in the sub-areas (scope).
Program
- Based on identified risks, risk mitigation principles and measures are introduced.
Organization
- Defined roles and responsibilities.
- Structure and process organization.
- Resource planning.
Risks
- Identification of material compliance risks.
- Systematic risk identification with risk assessments.
- E.g., annual risk analysis, compliance country risk report.
Communication
- Employees and, if applicable, third parties are informed about the compliance program and the defined responsibilities.
- Definition of a reporting system for identified risks, detected rule violations, as well as incoming information.
Monitoring & Improvement
- Monitoring the adequacy and effectiveness of the CMS.
- E.g., Global Compliance Key Controls, audits.
Overview of different compliance management systems at Schaeffler
Responsibility for uniform compliance management systems that are aligned with industry and assurance standards rests with the Group Chief Compliance Officer who reports directly to the CEO and to the Chairman of the Supervisory Board and maintains a continual dialogue with the Chairman of the Audit Committee.
The Schaeffler Group operates a training program tailored to its various target audiences that promotes its employees’ and managers’ understanding of compliance and raises awareness of compliance risks in day-to-day business. Web-based and classroom training sessions provide knowledge of the Schaeffler Code of Conduct and the relevant group guidelines.
The Forensics & Investigations department, assigned to the Group Chief Compliance Officer, is responsible for independently investigating suspected violations of the Schaeffler Code of Conduct and operates a global whistleblowing system. The department analyzes the causes of misconduct, develops remedial measures, and monitors their implementation.
The Group’s Business Integrity Compliance Management system controls and monitors activities designed to prevent, and detect early on, violations of the law in the areas of corruption, money laundering, competition and antitrust law, and economic crime.
To strengthen information & cybersecurity, the Schaeffler Group implements preventive, detective , and corrective measures to safeguard intellectual property and sensitive data, aligned with ISO/IEC 27001 and other relevant standards.
The Group’s Export Control Compliance Management System ensures that external or internal business activities do not violate economic embargoes, sanction regulations or import and export control requirements.
The Group’s Tax Compliance Management System (Tax CMS), which is based on loss prevention and risk control, ensures compliance with tax requirements throughout the company and conforms with the Schaeffler Group’s governance model.
The Group’s Human Rights Compliance Management System focuses in particular on ensuing to respect Human Rights according to the Schaeffler Self Commitment and complying with the legal requirements (e.g. German Supply Chain Due Diligence Act).
The Group’s Technical Compliance Management System aimed at complying with product-related technical obligations follows the fundamental elements of compliance management systems in the technical context.
Incident reporting system
As a key component of an effective compliance management system, Schaeffler offers various ways to report potential compliance violations, including an electronic 24/7 incident reporting system. All Schaeffler employees and third parties can report potential violations without fear of reprisals.
The 24/7 incident reporting system is available in different languages and allows anonymous, confidential, specially encrypted, and secure communication with Schaeffler’s independent Forensics & Investigations department.
If you observed a violation of the Schaeffler Code of Conduct, specifically illegal business practices or potential human rights violations , you could contact the compliance department directly or use of one of the following incident reporting channels:
Post
Schaeffler AG
Forensics and Investigations
Industriestrasse 1 – 3
91074 Herzogenaurach
24/7 telephone hotline
+49 30 99257146 (German, English, French)
+1 213 2791015 (Spanish)
+55 61 35507564 (Portuguese)
10800-320-0116 (only to be reached from China net)
If you are asked to enter a Company Access Pin, please enter: 3758
Further information
You can find additional information on compliance at Schaeffler in the following publications of the Schaeffler Group:
- Sustainability Report 2023
- Annual Report 2023
- Guideline whistleblowing system
- Human trafficking policy
- Statement on respect for human rights
- Schaeffler AG | Bericht zum LkSG (Lieferkettensorgfaltspflichtengesetz) 2023
- Schaeffler Technologies AG & Co. KG | Bericht zum LkSG (Lieferkettensorgfaltspflichtengesetz) 2023
- Schaeffler Automotive Bühl GmbH & Co. KG | Bericht zum LkSG (Lieferkettensorgfaltspflichtengesetz) 2023
- Vitesco Technologies Group AG | Bericht zum LkSG (Lieferkettensorgfaltspflichtengesetz) 2023
- Vitesco Technologies GmbH | Bericht zum LkSG (Lieferkettensorgfaltspflichtengesetz) 2023
- Vitesco Technologies Germany GmbH | Bericht zum LkSG (Lieferkettensorgfaltspflichtengesetz) 2023
- Modern Slavery Statement Schaeffler (UK) Ltd
- Responsible tax strategy