Compliance
Compliance — even beyond corporate boundaries
Compliance refers to the observance of legal requirements and company guidelines. At Bosch, this is an integral part of our corporate values. To this end, we have unequivocally defined our position on legal requirements and ethical issues in our globally applicable Code of Business Conduct. Together with the Bosch values, it provides a foundation that we believe is key to Bosch’s success in business. And because responsible and lawful conduct is important beyond company boundaries, we have formulated our expectations of our business partners in a corresponding code of conduct.
Company-wide compliance management system
Bosch’s compliance management system provides a binding framework worldwide for promoting compliant conduct and serves to reduce compliance risks. It provides the basis for effective implementation of external and internal requirements and defines minimum requirements for processes of relevance for compliance. These include various prevention and control measures as well as the internal Bosch whistleblower system. Associates, business partners, and third parties can use this system at any time to report non-compliance, anonymously if they wish.
Frequently asked questions
Compliance means observing laws and company regulations. In other words, all business activities of the Bosch Group and its associates must comply with all legal requirements, the Code of Business Conduct, and any applicable guidelines and central directives that relate to this topic in any way (“compliance principle”).
The topic of compliance is one that concerns all associates, as everyone is affected — directly or indirectly — by violations: on the one hand, violations of the law may lead to criminal prosecution, depending on the seriousness of the case. On the other hand, violations of the compliance principle can cause the company pecuniary harm, as well as damaging its reputation. The result is a deterioration in the company’s business efficiency, and thus in its success. Compliance also concerns business relations between Bosch and third parties: Bosch does not want to be involved in other parties’ violations of the compliance principle.
It is up to all associates to report possible violations of the compliance principle, and in this way to help limit the consequences of such violations and prevent similar misconduct happening in the future. This also applies to business partners and third parties.
• Any associate, including interns and Ph.D. students
• Externally employed persons such as subcontracted workers or associates working for external service providers
• Any business partner, such as suppliers, customers, or joint venture partners
• Any third party
It is important that matters be reported that indicate a criminal offense has been committed — such as theft, fraud, or bribery — or that there has been a systematic violation of legal or company-internal regulations, such as the deliberate and sustained non-compliance with quality or safety standards or with the Code of Business Conduct.
Yes. Compliance officers are responsible for conducting investigations, gathering evidence that will stand up in court, and instituting any proceedings that may be necessary. They receive support from experts in the specialist departments who have the required training and relevant authority.
People who report possible compliance issues to the best of their knowledge and in good faith do not have to fear being disadvantaged by the company as a result of their actions.
Yes, reports can be submitted anonymously via the Bosch compliance hotline. It is possible to set up a secure mailbox within the hotline to interact anonymously with the responsible compliance officer.
The compliance officer is responsible for launching an investigation into the reported violations and ensuring the matter is properly resolved (if necessary with the support of Bosch specialist departments or external specialists).
Every report of possible violations as well as the measures subsequently taken must be documented by the compliance officer. Taking into account the legitimate interests of the parties involved, the person reporting the matter may inquire about the status of the investigation. If the investigation of a matter is dropped because no relevant misconduct has been found, the individual concerned will be informed accordingly, provided they were asked to comment in the course of the investigation or requested such information.
Any report of possible compliance violations will normally involve the disclosure of personal data. The receipt and processing of such reports therefore requires that the people making reports confirm they have been informed of their rights under data privacy laws, and consent to their personal data being used in the course of the investigation of the compliance matter. In the case of a report submitted anonymously, this does not apply.
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