20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

Compliance includes adherence to all laws, regulations and guidelines as well as all applicable contractual obligations. The term Compliance denotes that every single individual, from employees and the Executive Board to the Supervisory Board, the Principal, and through to suppliers, exhibitors and visitors, is expected to follow all applicable legal stipulations in the course of business. HMC consequently respects applicable laws and expect its employees and business partners to do the same.

To combat and prevent corruption and other unlawful conduct, the HMC Executive Board introduced a Compliance Management System (CMS) comprising the Corporate Compliance Programme, regular training courses, a Compliance Officer and other measures.

In March 2020, the Hamburg Senate Committee for Public Sector Organisations passed a Compliance Guideline for public-sector companies. The Compliance Guideline is a logical extension of the obligatory Hamburg Code Of Corporate Governance (HCGK) which has been in effect since 2009.

Furthermore, compliance and anticorruption are expressly included in the applicable collective labour agreement (TV-AVH, Section 3(2)):
"Employees are prohibited from accepting any rewards, gifts, commissions or other favours in connection with their work. No exceptions are permissible unless expressly approved by the employer. Any employee who is offered such a favour is under obligation to notify the employer without delay."

Since many different parties interact in the context of an event, there is a certain risk of non-compliance and corruption. HMC counteracts this risk by ensuring transparency, providing sources of information, and consulting with its Legal Department.

All employees receive regular compliance and anticorruption training through the e-learning system sam®. The Compliance Programme and the Operations Manual are freely available to all employees on the intranet, true to the concept that knowledge and accountability are keys to success. Both arise from strict obedience to the law and ethical conduct. It takes regular study of the subject to build the required awareness and sensitivity.

All employees are required to report violations of the Corporate Compliance Programme and other applicable provisions to their supervisors or the Compliance Officer without delay (duty to report). Violations may be reported anonymously.

HMC will ensure that no employee will suffer any reprisals as a consequence of reporting a violation. Supervisors are required to conduct regular checks proactively and engage in conversations with their employees.

Violations may be penalised in a variety of ways, including reprimands, claims for damages, and through to termination.

The ultimate goals of compliance are to minimise risks and damage to the organisation and to increase the efficiency of operations.

In summary, Compliance at HMC is implemented by:
Also refer to: Our Contribution to The United Nations’ 17 Sustainable Development Goals