The compliance organization is headed by Chief Compliance Officer Hans-Jörg Grundmann and Chief Counsel Compliance Klaus Moosmayer.

The Chief Compliance Officer is responsible for all operational and sales-related issues, while the Chief Counsel Compliance is responsible for all legal aspects of compliance.  Responsibilities within the organization are clearly assigned:

The Chief Counsel Compliance (CCC) manages the three departments

The CCC’s organization takes on the entire process of dealing with indications of potential compliance violations, from the time these are brought to the notice of the company, through the legal proceedings and investigation to the employment law-related sanctions which may follow and finally any legal response and investigation of such violations (“Remediation”). The Chief Counsel Compliance is also responsible for the legal aspects of the corporate Compliance guidelines and controls.

The Chief Compliance Officer and the Chief Counsel Compliance are jointly responsible for the group’s compliance risk analysis activities and together report to the company’s Managing Board and Supervisory Board.

The compliance organization is not intended to be a static body, but aims at allowing a certain degree of permeability to and from other Company staff and operating units. Compliance success depends critically on the work undertaken in the compliance organization being regarded as a step up the career ladder. For this purpose, a separate expertise development program (Competency Management) has been designed together with Human Resources to help systematically support employees of the compliance organization.