Principal Elements of the Compliance Management System

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 Fraport's core values supports the additional requirements that need to be fulfilled by a comprehensive compliance management system.

Values-based compliance is a component of collective agreements for employees and executives. The Compliance Management System has been implemented at our majority-owned national and international subsidiaries over the last years.

In order to detect and prevent any conduct that may damage our company,  a certified whistleblower system, the Business Keeper Monitoring System (BKMS® System) 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.

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.

The main task of the external ombudswoman is the confidential receipt, legal examination and forwarding of information pointing to matters open to criminal charges. These include for example corruption, competition violations, fraud and embezzlement but also serious company-related violations of duty. With her many years of experience and expertise, the ombudswoman autonomously and independently checks the incoming information for their relevance to the company. If she comes to the conclusion that the suspicion has to be investigated, she will forward the case to the responsible party at Fraport AG under the condition that the whistleblower has declared his or her consent.

You may contact the external ombudswoman free of charge as follows:

Via phone: +49 800 1230125
Via fax: +49 800 1230126Via
Via mail: Attorney at Law Annette Parsch, Ombudswoman,
Q 2, 5, 68161 Mannheim


Who can turn to the ombudswoman?

The ombudswoman is a confidential contact person for of all employees of Fraport AG and its subsidiaries, as well as for externals such as suppliers or participants in contract award procedures.

What kind of information does the external ombudswoman receive?

The most important objective is the detection and prevention of economic crimes (e.g. corruption, competition violations, fraud and embezzlement) but also of other serious violations of duty in connection with Fraport AG.

Can I contact the ombudswoman anonymously?

The ombudswoman also receives information from anonymous whistleblowers.

Even if the ombudswoman knows the name of the whistleblower, his or her identity is forwarded to Fraport AG only with his or her explicit content. Fraport AG has explicitly and irrevocably waved all claims to information in regard to the ombudswoman. If the whistleblower does not explicitly allow the forwarding of the information given to the ombudswoman, these information are protected by the lawyer’s code of secrecy.

For anonymous information you may also use the  electronic reporting system of Fraport AG  as an additional reporting channel. All information thus given are processed by Fraport AG. The external ombudswoman cannot be contacted via the electronic reporting system.

Is any attorney-client relationship established between whistleblower and ombudswoman?

No, as the ombudswoman is a representative of Fraport AG. Still, the ombudswoman and the company have concluded an agreement which enables the ombudswoman to informally consult the whistleblower on practical individual issues. It is not possible for the ombudswoman to represent the whistleblowers’ legal interests.

With the introduction of the codes of conduct for employees and suppliers the values-based compliance was further expanded. With these codes, Fraport recognizes its responsibility as a global company.

Code of Conduct for Employees

The CoC for employees provides an overview on the fundamental orientation that our company is based on, and on the values Fraport stands for.

According to our Company values - trust, reliability, openness, courage, commitment and competence - 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.

Suppliers  Code of Conduct

The CoC for suppliers 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.

Code of Conduct for Employees of Fraport AG

Fraport AG Supplier Code of Conduct

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).   

Already before its implementation elements of the existing compliance program had been applied to the subsidiaries, e.g. the codes of conduct and the reporting systems.

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.



Martin Glock

Senior Vice President Legal Affairs and Compliance Fraport AG Frankfurt Airport Services Worldwide Rechtsangelegenheiten und Compliance (RAC) 60547 Frankfurt am Main
Elke Breuer

Vice President Compliance and Values Management Fraport AG Frankfurt Airport Services Worldwide Legal Affairs and Compliance Compliance and Values Management (RAC-CW) 60547 Frankfurt am Main