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Frequently asked questions

Compliance

Compliance Contact


Robert Bosch Ltda.
Compliance Officer
Rodovia Anhangüera, Km. 98
Campinas/SP
Brazil

What do we mean by compliance?

Compliance means observing laws and company regulations. In other words, all business activities of the Bosch Group and of its associates must comply with all legal requirements, the Code of Business Conduct (see attachment), and any applicable guidelines and central directives that relate to this topic in any way (“compliance requirement”).

The compliance topic is one that concerns all associates, as everyone is affected – directly or indirectly – by violations: on the one hand, violations of the law may lead to criminal prosecution, depending on the seriousness of the case. On the other hand, violations of the compliance principle harm the company both in material terms and in terms of the Bosch Group’s public image. The result is a deterioration in the company’s business efficiency, and thus in its profit. Compliance also relates to business relations between Bosch and third parties: Bosch does not want to be involved in other parties’ violations of the compliance requirement.

Compliance – something new for Bosch?

For Bosch, observing laws and company regulations is nothing new. Right from the company’s beginnings as a “Workshop for Precision Mechanics and Electrical Engineering” in 1886, its proper and legal management was a matter of the utmost importance for Robert Bosch.

What should be done if the compliance requirement is violated?

Apart from supervisors, it is up to every Bosch associate and every Bosch business partner to report any possible violations of the compliance requirement, and in this way to help limit the consequences of such violations and prevent similar misconduct happening in the future. Reports can be made in the following ways:

1. Report to the supervisor or the contact person at Bosch

If at all possible, violations of legal or company-internal regulations should as a matter of principle be reported to the supervisor or contact person at Bosch and dealt with via the normal channels.

2. Direct report to the compliance officer

However, if the person reporting has to assume that the matter cannot be dealt with via the normal channels, he or she can turn to the compliance officer as neutral, independent contact person.

3. Bosch Compliance Hotline

If the person reporting has to assume that they may incur a personal disadvantage as a result of the report, they may preserve their anonymity by reporting a possible violation of the compliance requirement via the Bosch Compliance Hotline. The service provider operating the compliance hotline for Bosch will forward without delay any reports it receives via the Bosch Compliance Hotline to the compliance officer responsible or to the Compliance Committee for their attention.

Who can report violations of the compliance principle?

  • Any associate, including interns and Ph.D. students
  • Externally employed persons such as subcontracted employees or associates working for external service providers
  • Any business partner, such as suppliers, customers, or joint venture partners
  • Any third party

What violations should be reported?

It is especially important that matters should be reported that appear to indicate a criminal offense – such as theft, fraud, or bribery – or a systematic violation of legal or company-internal regulations, such as the deliberate and sustained non-compliance with quality/safety standards or with the “Principles of Social Responsibility.”

A suspicion, but no proof – enough for a report?

Whoever makes a report must carefully consider the following two criteria before doing so:

Are there serious signs of wrongful behavior?

Do these signs justify investigating an associate or Bosch business partner who may in fact be acting legally?

Conducting investigations, gathering evidence that will stand up in court, and instituting any proceedings that may be necessary is the responsibility of the compliance officers. They receive support from experts in the specialist departments who have the necessary training and powers.

Do people who report violations have to fear disadvantages?

Persons who report possible compliance issues to the best of their knowledge and in good faith do not have to fear any harassment by the company as a result of the report.

If it is clear that the Bosch Compliance Hotline has been misused, i.e. if matters are reported that are so obviously without foundation that they do not require serious investigation, Bosch reserves the right to take legal or disciplinary action against the person making the report.

Are anonymous reports compatible with the Bosch values?

Anonymous reports alone will not result in disadvantages for an associate. Additional, incriminating evidence is always needed. If evidence is found as a result of anonymous reports, the associate concerned must answer for the proven misconduct. But if there are no facts to back up the anonymous report, the matter will be treated as though it had never happened. There is no risk of any consequences for the accused associate. In particular, the issue will not be documented in his or her personnel file.

Moreover, anonymous reports are nothing new. The company has received anonymous reports in the past, and has had to follow them up. All that is new about this situation is that associates and third parties now have a defined reporting channel and, in the person of the compliance officer, a clearly defined contact person. From his position of neutrality, it is his responsibility to ensure that the situation is clarified rapidly and fairly.

What exactly happens to a report?

The compliance officer is responsible for having the matters reported to him investigated and properly settled (if necessary with the support of Bosch specialist departments or external specialists). If necessary, he initiates any steps that may be needed. If the case is one of special significance, e.g. if members of senior management are involved, or if there is a risk of considerable damage to the Bosch Group, either financially or image-wise, the Compliance Committee will also be alerted immediately. The Compliance Committee – comprising the persons in charge of Corporate Internal Auditing and Corporate Legal Services – coordinates global observation of the compliance requirement in the Bosch Group.

Documentation and transparency

Every report, and the measures taken, must be documented by the compliance officer. Once due consideration has been given to the justified interests of the parties involved, the person reporting the matter may inquire about the status of the investigations. If the investigation of a matter is dropped due to lack of sufficient evidence, the person accused will be informed accordingly, provided he was asked to comment in the course of the investigation or requested such information.

Protection of personal data

Any report of violations of the compliance requirement will normally involve the disclosure of personal data. The receipt and processing of such reports therefore presupposes that the persons making reports confirm they have been informed of data protection laws and give their consent to their personal data being used in the course of the investigation of the compliance case.