Clemens von StockertVice President Compliance and Values Management
Frankfurt Airport Services Worldwide
Legal Affairs and Compliance
Compliance and Values Management (RAC-CW)
60547 Frankfurt am Main
Monika WienandVice President Risk Management, Intern Control and Quality Management System
Frankfurt Airport Services Worldwide
Risk Management, Intern Control and Quality Management System (REW-RI)
60547 Frankfurt am Main
When conducting our business activities, compliance with the law and other rules and regulations is our top priority. We, therefore, make high demands on an effective compliance management.
For us, compliance does not end with the adherence to legal provisions: Far from that, we aspire to always act in accordance with ethical principles while minimizing the liability risk for the Company, its management teams and supervisory bodies through organizational and preventive measures. In so doing, the corporate culture geared toward values supports the additional requirements that need to be fulfilled by a comprehensive compliance management system.
Principal elements of the compliance management system:
Introduction of Values Management
Thanks to its preventive character, the Values Management supplements the more complex compliance management system.
Values-based compliance becomes a component of collective agreements
Values-based compliance serves to prevent and pursuit corruption. It is a component of collective agreements for employees and executives. It has been implemented at our majority-owned national and international subsidiaries over the last years.
The electronic reporting system
In order to strengthen the bond of trust between us and our partners and customers, a certified whistleblower system, the Business Keeper Monitoring System (BKMS® System) for the detection and prevention of any conduct that may damage our company was launched.
This system gives employees, business partners and customers an online possibility to leave indications pointing to irregularities. It is available worldwide, 24/7, making it possible to pass on confidential information concerning corruption and economic offences directly and anonymously. Anonymity of the whistleblowers is absolutely guaranteed by the certified BKMS® System.
Each report is intensively examined as to its material content, if necessary sanctions are imposed. This reporting system was also introduced at our Antalya and Lima Airport subsidiaries.
Further development of the compliance management system
For interlocking reasons we started with the implementation of an integrated system for compliance management, risk management and internal control system. The further development of the compliance management system is based on the PS 980 auditing standard issued by the “Institut der Deutschen Wirtschaftsprüfer” (IDW, Institute of Public Auditors in Germany). PS 980 provides instructions for an adequate regulatory framework and the necessary key elements.
In order to provide a closer interlinking of the compliance management, risk management and internal control system subsystems, we are adopting an integrative, risk-oriented approach in accordance with the internationally recognized COSO II regulations. For that purpose, we introduced a supporting IT tool. On the organizational level, interlinking of the various subsystems is ensured by the risk management committee and the compliance board. The latter establishes a cohesive framework and deals with concrete compliance events. It reports to the Executive Board, which is also given an overview of the major risks within the Group at regular intervals. Following this, the Executive Board informs the Supervisory Board.
External ombudswoman supports compliance activities
Fraport appointed an external ombudsperson for confidentiality receiving and examining, indications concerning serious company-related violations of the law. The main task of the ombudswoman (an attorney at law) is the confidential receipt of information pointing to crimes such as fraud, corruption or other improper business practices.
Code of conduct for employees and suppliers
Pyramide Verhaltenskodex englisch
The Executive Board adopted the new Code of Conduct for Employees and Suppliers. With the introduction of these codes of conduct the Values Management that had been implemented for ten years and the values-based compliance were further developed and expanded.
Code of Conduct for employees
The CoC provides an overview on the fundamental orientation that our Company is based on, and on the values Fraport stands for.
According to our fundamental values, i.e. honesty, integrity, trustworthiness, responsibility, transparency, loyalty, and fairness, we endeavor to act in a socially and economically responsible way. In order to do justice to this responsibility, it is indispensable to implement the Company's values also in everyday working life.
Code of Conduct for suppliers
The CoC stipulates rules for all suppliers and service providers that are in a direct business relationship with Fraport. In a similar manner to the code of conduct for employees, it encompasses compliance, conventions on labor as well as human rights, supplemented by environmental and climate protection aspects. Any compliance breach will be considered an infringement of the contract and our suppliers will be notified of it if need be, together with a deadline to remedy the breach. If escalating, this may result in a termination of the contract.
Roll-out of the CMS Group Guideline
In order to implement the Compliance Management System (CMS) on a Group-wide scale Fraport AG developed a CMS Group
guideline for the subsidiaries (majority shareholdings).
Before 2014, elements of the existent compliance program were already applied to the subsidiaries (e.g. code of conduct for employees, supplier code of conduct, local compliance officer) or made available to them, such as the reporting systems (BKMS, internal and external ombudspersons), compliance helpdesk, etc.
Regular Group-wide Compliance Risk Analysis
The Compliance Risk Analysis (CRA) is an essential instrument to identify compliance risks. Since 2015, CRA has been carried out regularly within the Fraport Group. By means of systematically identifying and evaluating risks, CRA thus serves as a basis for appropriate compliance measures.