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.
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.
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 may be directed to any member of the compliance staff and to supervisors serving as internal ombudsmen as well as to an external ombudsman – reports to the latter may be submitted anonymously, if desired. A "whistle-blowing hotline" has been set up in the intranet specifically for this purpose and is available to all employees.
Compliance violations and the investigations, evaluations and remediations relating to them are coordinated by the Chief Compliance Officer.
Dr. Patrick Wolff (Chief Compliance Officer), who reports directly to Klaus Schäfer in his capacity as chairman with overall responsibility in this area, 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. Gabriele Haas (Senior Vice President for Compliance) and her 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.
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.