GRI Standards Content index

103-1 Explanation of the material topic and its Boundary

#KPMG
2018 materiality analysis

AR: Compliance and risk management

103-2 The management approach and its components

AR: Compliance and risk management

103-3 Evaluation of the management approach

AR: Compliance and risk management

205-1 Operations assessed for risks related to corruption

AR: Risk and opportunity report

All operating companies and service companies of METRO (except companies with minority shareholdings) are reviewed for compliance risks such as corruption.

Every year, METRO holds workshops on compliance risk assessment. Within the framework of the workshops, various compliance risks such as corruption are checked for their damage potential and their probability of occurrence in the respective company. Various risk scenarios were developed for the audit, for example on active or passive corruption towards various stakeholders such as suppliers or civil servants. The results of the risk assessment in the companies are reviewed and consolidated at Group level as part of corporate risk management.

METRO's business activities are subject to a large number of legal norms and voluntary commitments. The legal requirements have become more comprehensive and complex, as have the expectations customers and the public have of the company's compliance. In order to meet these requirements, METRO has introduced and continuously expanded a Group-wide compliance management system. The aim of this system is to systematically and permanently prevent violations of the law within the company. METRO regularly identifies behavioural risks.

The focus of our compliance management is on the prevention of corruption and cartels. Corruption risks can arise when dealing with authorities and civil servants, for example as part of international expansion or approval procedures. They can also occur in business relationships with suppliers and other business partners. The Group-wide compliance management system also covers data protection and other regulatory, criminal and labor law risks such as discrimination.

On the basis of the compliance risks identified and examined, the necessary organizational structures are set up as part of the compliance management system. Within the existing structures, the responsible departments are responsible for the seamless management and control of risks.

In order to manage the compliance risks identified, METRO AG has issued Group-wide guidelines, such as a cartel guideline with working aids for negotiations with suppliers. This guideline also contains sample formulations for the communication with suppliers in compliance with antitrust law. METRO AG has also introduced Group-wide corruption prevention guidelines which lay down rules of conduct for dealing with authorities and civil servants on the one hand and business partners on the other. The corruption prevention guidelines also provide for a compliance audit of business partners in risk areas before entering into a business relationship.

205-2 Communication and training about anti-corruption policies and procedures

#KPMG
United Nations Global Compact – Anti-corruption measures

AR: Compliance and risk management

METRO has established procedures for training and regulations management that apply to all operating companies and service companies (except for companies with minority shareholdings) and promote compliance and the prevention of corruption. The training and regulation management processes apply throughout the Group and affect employees as well as members of the management bodies.

The target groups of the anti-corruption guidelines and procedures are defined according to their significance in terms of content and organization. They are distributed either via the intended IT tool or by cascading information about the management levels. The target groups for training measures are defined according to a risk-based approach, which is based, among other things, on the risk profile of the function or position in the company. Executives are as much a part of this approach as employees. A risk-oriented selection is made for temporary staff. Training management can be used to adequately monitor participation in training. The adoption of policies and procedures is checked using the tool.

In fiscal 2017/18, new employees were informed about anti-corruption guidelines and procedures. In addition, anti-corruption guidelines are regularly communicated via internal communication channels such as the intranet or the social network. As the existing anti-corruption guidelines were not revised, no separate notification was made about the planned IT tool.

In fiscal 2015/16, based on the results of the most recent annual compliance report, anti-corruption training courses were held in 84 percent of all participating operating and service companies for over 90 percent of employees and managers, including members of management bodies.

In the same period, anti-corruption training courses in 16 percent of companies reached less than 90 percent of employees and managers. Measures to optimize the training rate in these companies have already been initiated.

All relevant business partners must complete a Compliance Questionnaire for Business Partners (BPQ) before concluding a contract with METRO for the first time. A new survey is carried out at regular intervals. The BPQ covers compliance-relevant topics and is intended to give indications of non-compliance with the specifications on the part of the suppliers.

A breakdown by regions and employee categories is generally not published.