Compliance, which consists of all measures aimed at ensuring that statutory provisions and internal company policies are abided by, is a component of good corporate governance and for the Uniper SE board constitutes a central management responsibility.
Compliance Management System (CMS)
With this in mind, we established a corporate-wide Compliance Management System (CMS) at the time the company was founded, which is based on generally accepted auditing standards that are reviewed and updated regularly based on a company-specific risk analysis.
All Uniper compliance measures focus on preventing corruption, money laundering and terrorist financing, as well as violations of antitrust and securities law (insider trading) and all risks associated with these activities.
Reports on violations (Whistleblowing)
Moreover, at Uniper, the failure to comply with statutory provisions and internal company policies is considered to constitute an economic risk. Therefore, the board asks that all employees report any potential infractions against the code of conduct and other violations of law or internal company policies, in particular those involving corruption, money laundering, as well as antitrust and securities law (insider trading).
Reports on potential rule violations within the company may be directed to any member of the Uniper Compliance Team and to supervisors serving as internal ombudsmen. This opportunity is equally available to all third parties (like customers and suppliers) who have a business relationship with Uniper.
In addition, all employees have the opportunity to securely submit tips on any violation – also anonymously, if desired – via our "Whistleblower Hotline". The Whistleblower Hotline is operated by the law firm Simmons & Simmons and available at email@example.com. Employees can also find local "whistleblowing" contact persons on the Uniper intranet.
Each report received will be treated with the utmost confidentiality. Also, each employee, who reports potential rule violations, benefits from special protection according to the principles of our Code of Conduct. In other words, a whistleblower has not to fear any retaliation resulting from his report.
Investigations, evaluations and remediations relating to Compliance incidents are coordinated by the Chief Compliance Officer.
The board's commitment to compliance
Through its commitment to compliance, the board makes clear its rejection of infringements of any kind.
Dr. Patrick Wolff (Chief Compliance Officer), who reports directly to Uniper's Chairman of the Management Board, is responsible for the suitability and effectiveness of CMS in the area of "Law & Compliance" and is assisted in his role at the corporate level by Dr. Malte Abel (Senior Vice President for Compliance) and his team as well as by decentralized compliance officers and line managers (in the various divisions or legal entities). The board serving as a collegial body bears overall responsibility for compliance.
Code of Conduct
Compliance is essential to integrity and constitutes an important part of Uniper's corporate culture. This is why it is important that all compliance measures not only be developed so as to comport with the company's specific culture, but that all employees and line managers (who serve as role models) make them part of their professional routine. A crucial element of this compliance culture is the Uniper Code of Conduct, which outlines the central principles – based on our values and integrity – governing our professional conduct.