MAN Truck & Bus

Compliance & Risk

Hands lying on top of each other

We create values with values

As a globally-active business with a multitude of divisions and a long heritage, MAN bears a social responsibility towards customers, employees, investors and the public. This social responsibility includes ensuring that MAN complies with applicable laws at all times and in all places, respects fundamental ethical values and acts sustainably.

Portrait of Alexander Vlaskamp

Compliance and integrity are essential for successful cooperation within MAN and with our business partners.

Alexander Vlaskamp – CEO MAN Truck & Bus SE

Compliance and Integrity

A compass lying on a rock

Compliance and integrity are fundamental components of MAN’s strategy and must be practised at all levels of the Group and by all employees, i.e. the Executive Board, managers and each individual employee.

On the one hand, this involves compliance with legal regulations as well as internal company guidelines, rules and standards. On the other hand, integrity as one of the five corporate values is the basis of an open corporate culture. Here, the focus is on awareness and understanding how to act sustainably and with integrity in every situation in working life. The basis is provided by the Code of Conduct as a set of rules for all MAN employees. The MAN Governance, Risk & Compliance (GRC) organisation supports employees with various measures to ensure that compliance and integrity are lived and implemented throughout the Group. Each employee is responsible for complying with internal and external rules and laws. And this responsibility does not end at the workplace. Just as the company is aware of its responsibility to society, MAN also sets expectations for compliance with social responsibility for business partners. This includes, for example, the Statement on the UK Modern Slavery Act  – MAN explicitly refers to measures to ensure compliance with human rights within and outside the company.

MAN Compliance Programme

Compliance and integrity are relevant in all areas of the company. For this reason, the MAN Compliance Programme was defined. It underlies the entire ethical and moral set of values of the company:

Graphic explaining the MAN Compliance Programme

Prevention

The MAN Compliance Programme promotes a culture of integrity and transparency. Numerous communication and training measures raise staff awareness of compliance and integrity issues and thus prevent compliance violations.

Reveal

Despite preventive measures, compliance violations can occur. Various reporting channels and our own monitoring systems are used to identify violations, which are then investigated carefully and confidentially.

Reaction

MAN does not tolerate compliance violations. Any violations discovered are remedied immediately and efficiently. In addition, any necessary measures are initiated immediately.

Memberships in external organisations

two men discussing in an office behind a pane of glass

MAN is also committed to compliance outside its own group boundaries. The GRC organisation regularly exchanges views with experts from business and academia on current compliance topics.

Together with TRATON, MAN supports and promotes the fight against corruption and represents this position together with other business enterprises in the following organisations:

Transparency International

United Nations Global Compact

German Institute for Compliance (DICO)

Code of Conduct

people giving each other a high five

For employees

The MAN Code of Conduct applies equally to all MAN employees, i.e. the Executive Board, managers and each individual employee. Together with the corporate values of respect, team spirit, responsibility, customer first and eliminating waste, it forms the core of MAN’s corporate culture. The Code of Conduct is aimed specifically at MAN employees and sets out concrete and binding principles for situations in which employees must pay particular attention to responsible conduct. Using examples, it describes how to deal with conflict situations in everyday business.

people discussing in an office

For suppliers and business partners

MAN expects suppliers and business partners as well as their employees to act responsibly, to comply with applicable laws and to respect fundamental ethical values at all times and in all places.

MAN has therefore issued its own Code of Conduct for Suppliers and Business Partners, which contains minimum ethical standards that MAN’s suppliers and business partners undertake to comply with.

Risk management

Graphic explaining the MAN risk management system

MAN is exposed to a large number of risks – because entrepreneurial activity is not possible without risks. These result from the entrepreneurial actions themselves or external influences. MAN has therefore implemented an effective combination of risk management systems geared to the concerns of its business activities.

The following management systems rolled out worldwide form the basis for MAN’s risk management:

  • Business Continuity Management (BCM)
  • Enterprise Risk Management (ERM)
  • Internal Control System (ICS)
  • Continuous Controls Monitoring (CCM)

The information obtained is aggregated, placed in the overall context of the company, managed by risk officers and regularly reported to the Executive Board and relevant decision-making bodies.


Our whistleblowing system

Dimly discernible people

Integrity and compliance with laws and regulations as well as the principles laid down in the Code of Conduct and the Code of Conduct for Suppliers and Business Partners are top priorities and cornerstones of our corporate culture. To meet these values and to avoid or minimize potential risks due to regulatory violations, it is crucial that potential regulatory violations by employees or external partners are identified at an early stage, clarified, and stopped, and that disciplinary measures are applied where necessary. To encourage a speak-up culture and to detect potential wrongdoings, the TRATON GROUP operates a global independent, impartial, and confidential whistleblowing system managed in collaboration between the Brands and the TRATON Investigation Office.

The TRATON Investigation Office is the central contact point for whistleblowers.The Group-wide whistleblowing system and procedures for conducting internal investigations are governed by an internal Brand Policy.

Our whistleblowing system is based on fundamental principles such as the protection of whistleblowers and persons concerned of or supporting the investigation. We respect whistleblowers’ right to confidentiality, and we uphold the presumption of innocence and fairness of investigations towards any persons concerned. Information received via the whistleblowing system will be reviewed fairly, promptly, and in a sensitive manner and will be treated with the highest level of confidentiality. No actions are taken to identify anonymous whistleblowers. However, any report in bad faith will be treated as serious regulatory violation.

Dedicated functions of MAN Truck & Bus within Governance, Risk & Compliance, Security, Audit, Legal and HR/People and Culture support the investigations. An investigation is only initiated after a careful examination of the facts and reasonable suspicion of a regulatory violation. The MAN Truck & Bus departments involved in whistleblowing and internal investigations work closely with colleagues at the TRATON Investigation Office, especially regarding potential serious regulatory violations.

It is the responsibility of every employee to protect our company from legal violations and their negative consequences.

Dr. Bernhard Lippsmeier – Lead Governance, Risk & Compliance, Chief Compliance Officer MAN Truck & Bus

How can tips be reported?

If you have specific information about any legal violations or breaches of rules in connection with the MAN Group, you can contact our whistleblower system using the following contact options.

Whistleblowers worldwide can use the TRATON Speak up! tool, which is available around the clock in several languages to report hints on potential violations regarding white-collar crime such as corruption or antitrust law, data protection issues as well as risks and violations regarding human rights and environmental obligations, or other internal and statutory regulations. Whistleblowers can register on Speak up! with their name or stay anonymous. All hints are treated as confidential. Even if their preferred language is not offered in the reporting channel, whistleblowers can use any language to submit their report. Our whistleblowing portal is operated by a third-party, who is hosting the portal on external, certified servers (located in Germany) allowing whistleblowers to address hints to us on an anonymous, non-traceable basis.

Speak Up! is accessible from every internet-enabled computer on https://www.bkms-system.net/TRATON

At all times and in all languages, internal and external whistleblowers can report potential regulatory violations or risks related human rights or environmental obligations directly and confidentially to colleagues at the TRATON Investigation Office:

Postal Address

TRATON SE
TRATON Investigation Office
Hanauer Strasse 26
80992 Munich, Germany

investigation-office@traton.com

The relevant teams are available to talk to you in person, on the phone, or via email.

Whistleblowers always have the possibility to adress their concerns to the following internal functions:

  • Direct manager
  • Human Resources/People and Culture function (local or central)
  • Group Internal Audit
  • Group SecurityGroup Compliance/Local Compliance Officers
  • Locally or regionally designated contact person for most of our legal entities based in the EU

The receiving function will then forward the information to the dedicated whistleblowing functions, as set out in our internal procedures.

Regulatory violations can also be reported via the 24/7 Whistleblower Hotline provided by Volkswagen AG. The hotline is available around the clock and accepts hints concerning all Brands of the Volkswagen Group — if desired also anonymously. All hints concerning Companies within the MAN Truck & Bus that are received via the hotline are forwarded to the TRATON Investigation Office directly.

This is how you can reach the whistleblower hotline:

+800 444 46300 * (international toll-free number)

+49 5361 946300 (chargeable number, if your local telephone provider does not support the toll-free service)

* Depending on the country you are calling from it is possible that the international toll-free hotline is not available since some telephone network providers do not support the service. If so, please use the offered chargeable number or your country-specific number.

Coutry Toll-free number Local phone number
Brasil
0800 5912743 021 23911381
Mexico 001 800 4610242 0155 71000355
Slovak Republic 0800 002576 02 33325602
USA 833 6571574 908 2198092
South Africa 0800 994983 021 1003533
Malaysia 1 800 819523 0154 6000099
Argentina 0800 6662992 011 52528632
Germany 0800 444 46300 05361 946300

Volkswagen AG has authorized two external lawyers (Ombudspersons) who can assist or ensure that hints are forwarded to the TRATON Investigation Office – per request also anonymously.

Please find information about the Ombudspersons of Volkswagen AG here .

We encourage reporting of misconduct via the internal reporting channels as described above. However, in view of the EU Whistleblowing Directive, EU member states have defined (or will soon define) designated authorities that also accepts reports on misconduct as external reporting channels. Check on the following countries you are reporting from the following overview of external channels.

How do we process your report?

At our Company, hints regarding potential regulatory violations can be reported by employees, business partners/counter parties, customers, and other third parties through various channels, at any time, and in any language. Hints are then received by the TRATON Investigation Office, which ensure that thorough and appropriate investigations are carried out in a confidential and timely manner.

The qualified and experienced colleagues at the TRATON Investigation Office examine every report on potential misconduct thoroughly and follow the process according to the applicable Brand Policy systematically. First, whistleblowers will get a confirmation of receipt from the TRATON Investigation Office, which will then assess your report for potential legal risks. This includes clarifying questions about the reported matter and gathering available facts particularly from the whistleblowers. If this initial evaluation shows grounds for suspicion of a serious violation, an investigation by a dedicated investigating unit within the MAN Truck & Bus will be started. Afterwards, the results of the investigation will be legally assessed by the TRATON Investigation Office and appropriate measures will be recommended. If the hint points to a less serious regulatory violation, the case may be handed over to a suitable body within the MAN Truck & Bus to investigate and assess on their own, but with the chance to receive guidance from the TRATON Investigation Office. Whistleblowers or involved employees can always contact the TRATON Investigation Office about the status and the outcome of the procedure. The outcome will also be shared as far as legally possible considering the need-to-know-principle. However, the processing time varies depending on the subject of the procedure.

Potential violations of the Code of Conduct for Suppliers and Business Partners by business partners /counter parties, suppliers, and other third parties, including risks and violations regarding human rights and environmental obligations, can also be reported to the TRATON Investigation Office. The TRATON Investigation Office will inform the responsible departments, who will process the reported matter accordingly. This particularly includes taking the necessary measures to minimize or end violations and/or risks.

Find more information on the Rules of Procedure for the TRATON GROUP Complaints Procedure here . In addition to this, MAN Truck & Bus has published a Policy Statement on Human Rights , describing the expectations on the organization and suppliers to protect and respect human rights.

Data Protection for Whistleblowers: The TRATON Investigation Office collects and processes the personal data you provide for the purpose of assessing and processing your reported hint. Further information on data protection and the rights to which you are entitled can be found here.

Do you have any concern or feedback regarding our products or services?

If you have any questions or inquiries regarding our products or your vehicle, feedback or complaints about services provided by us or our business partners (such as car dealerships or workshops), please contact our customer care centers.

Do you have further questions?

Please contact the TRATON Investigation Office in case of any questions or suggestions for improvement concerning the whistleblowing system at any time.

You can contact us at investigation-office@traton.com

Contact

MAN Truck & Bus SE
Governance, Risk & Compliance (GO)

Dachauer Str. 667

80995 München

Deutschland


compliance@man.eu