Compliance

The overarching commitment and obligation to comply with all legal requirements and internal guidelines is expressed by the BGE in its Code of Conduct, which defines the ethical basis and the framework for the BGE’s actions. The code is derived from the material legal risks identified and evaluated at the BGE, as well as from the BGE’s guidelines.

For the BGE, however, compliance also entails a supportive culture with a view to ensuring conduct in accordance with the rules. The Code of Conduct is intended to help raise awareness of legal risks and avoid infringements of the law. It does so by specifying and explaining binding guidelines in an easily understandable form as general guidance in relation to all decisions and actions. The code applies to all employees of the BGE. However, the BGE also expects its contractors, suppliers and all third-party business partners to adhere to the applicable provisions of the code if they are working with the BGE.

Code of Conduct (PDF, 1,64 MB)

The BGE has set up a compliance management system, which it develops on an ongoing basis. The system is based on a compliance programme whose focus lies on proactive prevention. This includes key measures such as the creation of internal rule transparency, continual further development of the anti-corruption programme, and comprehensive training activities in all compliance-related risk areas. The programme, which is closely intertwined with risk management and the internal control system, is based on the legal risks identified, evaluated and documented at the BGE. The avoidance of future rule violations requires appropriate and effective measures to ensure that rule violations are detected and sanctioned. To this end, violations can be reported by both internal and external parties (via a “whistleblower system”). In addition to its own compliance audits, the BGE’s Internal Audit department assists the Compliance & Anti-Corruption staff unit in identifying the need for action and improvement as part of its risk-oriented audits.

The BGE is unequivocally committed to respect for human rights and environmental due diligence. In terms of respect for human rights, the BGE is guided by the international human rights reference instruments and frameworks. The BGE’s comprehensive approach includes not only the BGE itself but also all suppliers and business partners within the existing supply chains. The BGE’s own commitment is set out in its Statement of Principles along with a description of the principal human rights, processes and measures addressed. This Statement of Principles also sets out the BGE’s expectations of its suppliers and business partners with regard to the protection of humans and the environment.

Statement of Principles (PDF, 71 KB) (PDF, 0,07MB)

The Compliance/Anti-Corruption Officer of the BGE is on hand to act as an internal reporting office. With regard to the acceptance and processing of reports, the officer is independent, not subject to instructions, and bound to secrecy. The reporting office established for this purpose meets the requirements for internal reporting offices in accordance with the German Whistleblower Protection Act (HinSchG).

With this reporting office, the BGE safeguards the interests of whistleblowers and ensures that any reports received are handled confidentially and that whistleblowers are protected by every possible means – to the best of the company’s knowledge and belief – against any disadvantages resulting from a report. As far as legally permissible, anonymous reports are also accepted. However, it is helpful if the whistleblower gives their contact details when making a report in order to allow better investigation of serious misconduct and to increase the capacity for dialogue as part of the system.

The BGE’s whistleblower system also serves as a complaints office in accordance with the Supply Chain Act (LkSG). Accordingly, it also allows the reporting of human-rights and environmental risks as well as violations of duties relating to human rights or the environment that arise due to the BGE’s economic activities in its own area or due to the actions of a direct or indirect supplier/service provider of the BGE.

Procedural rules (PDF, 124 KB) (PDF, 0,07MB)