COMPLIANCE
ORGANISATION AND
MANAGEMENT

METRO GROUP continuously improves the effectiveness of its compliance management system.

Implementation of the comprehensive communication strategy to educate employees by means of Group-wide awareness campaigns in various formats (e.g. Compliance Day), reports in newsletters, the intranet and employee magazines, etc.; to be continued in 2013.

Introduction of Group-wide anti-corruption guidelines and enhancement of the Group-wide competition law compliance programme by the addition of extensive training programmes.

Implementation of an internal control system to manage compliance risks within operational processes, including systematic checks, a dual-control principle and also the separation of functions. All processes of phase 1 have been completed, the processes of phase 2 are to be completed in 2013.

Group-wide online survey of level 1, 2 and 3 managers to measure the progress of compliance at METRO GROUP . The results are reported to the Management Board and included in the Compliance Newsletter. The survey was conducted in 2012.

Compliance check of business partners (based on compliance questionnaire) implemented; questionnaires collected from more than 15,000 suppliers/service providers; assessment to be completed in 2013.

E-training platform for compliance training courses implemented in half of all METRO GROUP countries (first modules: anti-corruption and antitrust).

RISK MANAGEMENT

Establishment of the integration of sustainability criteria into the risk management system by 2012.

Systematic inclusion of sustainability criteria that are critical to METRO GROUP into the risk management system. Since the beginning of 2012, this has been laid down in a risk management guideline. As of 2012, relevant sustainability-related risks are part of the risk inventory.