Organisation

Based on our compliance strategy, we have implemented a decentralized approach with local compliance responsibility. The involvement of managers and employees in line with their tasks and responsibilities is our primary goal in this regard.

The Compliance Committee, established in 2012, acts as a central unit that coordinates the implementation of a standard corporate compliance approach for the SHS Group across all subsidiaries.

The committee consists of representatives from departments Human Resources, Corporate Audit, Risk Management and the Legal. They are supported by the compliance analyst of SHS and, if necessary, by specialists from other departments.

The tasks of the Compliance Committees include in particular:

• Implementation of the compliance strategy defined by the Management Board
• Mediation of the contents of the guidelines for managers/executives
• Sensitization through information (also towards external third parties)
• Creation/adoption of guidelines
• Clarification of compliance violations

Worldwide we have established a network of risk coordinators to implement the operational risk management process. These risk coordinators are also the first local contacts for compliance.

The risk coordinators collect additional information for early identification of compliance risks (preventive risk analysis). Through this they contribute to the integrated governance risk and compliance approach of the SHS. The derivation of measures is part of the compliance program. The implementation of the compliance strategy is subject to internal audits.