GRI G4 Content Index

All operating companies and service companies at METRO GROUP (excluding minority shareholding companies) are assessed for risks related to compliance, including corruption.

METRO GROUP conducts compliance risk assessment workshops on an annual basis. During the workshops, various compliance risks – including corruption – are assessed in terms of loss potential and probability of occurrence within every entity. For the assessment, different risk scenarios have been provided. These include, for example, active or passive corruption involving different stakeholders, such as suppliers or public officials. The results of the risk assessment in the local entities are validated and consolidated at the corporate level as part of the corporate risk management process.

The business activities of METRO GROUP are subject to a wide range of statutory and self-imposed standards. Various legal requirements, as well as increased expectations among customers and the public that companies ensure compliance within their organisations, are resulting in more demanding requirements and greater complexity. In order to satisfy these requirements, METRO GROUP has established and continually developed a group-wide compliance management system. The aim is to systematically and permanently prevent regulatory violations within the organisation. METRO GROUP regularly identifies behavioural risks.

The main focus of our compliance management is on preventing corruption and antitrust risks. Corruption risks may exist in interactions with public institutions and officials, for example in the context of international expansion or approval procedures. They can also arise from business relations with suppliers and other business partners. In addition, the group-wide compliance management system also covers other relevant criminal and regulatory risks, data protection and risk areas concerning labour law, such as discrimination.

Taking into account the identified and assessed compliance risks, the necessary organisational structures are established within the framework of the compliance management system. The risks are steered and controlled consistently by the responsible departments within the existing structures.

In order to manage the identified compliance risks, METRO AG has introduced guidelines with a group-wide validity, including an antitrust manual, which provides, for example, work aids for supplier negotiations. It also includes sample formulations that are used for the purposes of antitrust-compliant communication with suppliers. In addition, METRO AG has introduced anti-corruption guidelines throughout the group, which include behavioural requirements for dealing with public institutions and officials on the one hand, and business partners on the other. The anti-corruption guidelines also require a compliance check for business partners in risk-related areas before entering into business relations.

METRO GROUP has set up a training management and guidelines management process that is applicable for all operating companies and service companies (excluding minority shareholding companies) to facilitate compliance and the prevention of corruptive practices. Training management processes and guidelines management processes cover employees as well as governance body members and are applicable group-wide.

Target groups for anti-corruption policies and procedures are defined according to content and organisational relevance. Distribution is carried out either via the designated IT tool or via the cascading of information through management. For training activities, target groups are defined using a risk-based approach based, for example, on the risk profile of the function or the job position. Both managers and employees are part of this approach. For supervised workers and non-permanent employees (temporary staff and workers on fixed-term contracts), a risk-oriented selection is made. The training management ensures that participation in training programmes is adequately tracked. For policies and procedures, acknowledgement is tracked by the tool.

New employees have received communications regarding anti-corruption policies and procedures within financial year 2015/16. Moreover, ongoing communication regarding anti-corruption policies takes place through internal communication channels such as the intranet and the social network. As no update of the existing anti-corruption policies has taken place, no separate communications were initiated via the designated IT tool.

Based on the results of the current compliance annual reporting, in 84 per cent of the operating companies and service companies taking part, training on anti-corruption had been conducted with more than 90 per cent of employees and executives (including governance body members) within financial year 2015/16.

In 16 per cent of the targeted entities, training on anti-corruption was conducted with less than 90 per cent of employees and executives within financial year 2015/16. Measures to optimise the training rates in these entities have been already set up.

Based on risk, all business partners have to complete a compliance business partner questionnaire (BPQ) before concluding a contract with METRO GROUP for the first time. Renewal of the BPQ is requested at regular intervals. The BPQ is focused on compliance-related topics and aims at identifying any indication of non-compliance on the supplier side.

We do not externally report on regions or issue breakdowns by employee category.

Information on legal disputes, investigations and any other legal matters, and also on the potential risks or impacts for METRO GROUP, is contained in section 47. Other legal matters in the notes to the consolidated financial statements of METRO AG as of 30 September 2016.

Only those legal matters that are of significance to the asset, financial and earnings position of the group or METRO AG are included in the reporting. The materiality principle for reporting is based on Section 315 of the German Commercial Code (HGB) in conjunction with German Accounting Standard no. 20 (GAS 20) with regards to the consolidated financial statements of METRO AG and on Section 289 HGB in conjunction with GAS 20 with regards to the separate financial statements of METRO AG.

We consider non-compliance with social standards, particularly poor labour conditions, to be among the main actual and potential significant negative impacts on society. We help combat such circumstances with our efforts in the field of social standards within our non-food own-brand production (Level 1 factories). As a result, we make reference here to our response to G4-LA14.

We consider non-compliance with social standards, particularly poor labour conditions, to be among the main actual and potential significant negative impacts on society. We help combat such circumstances with our efforts in the field of social standards within our non-food own-brand production (Level 1 factories). As a result, we make reference here to our response to G4-LA15.