Materiality, Impact, and Risks
For United Internet, compliance means both observing all statutory requirements and internal organizational guidelines, and acting in accordance with our corporate values. Its aim is therefore to ensure that all employees act in a legally and ethically acceptable manner. For United Internet, compliance is a precondition for doing business successfully in the long term and hence an integral part of all Group activities.
United Internet AG’s Management Board has established a compliance management system (CMS) to ensure ethical behavior and adherence to the law throughout the Group. The Group General Counsel, who reports directly to United Internet AG’s CFO, is responsible for the CMS. Compliance is part of our end-to-end risk management approach, which comprises the Governance, Risk Management & Compliance (GRC), Corporate Audit, and Legal Department functions. Pooling these functions allows a common management approach to be adopted, utilizing and linking interfaces at content and process level. Dedicated compliance managers exist at segment level, while function-specific and local compliance managers have been appointed at the level of the operating divisions and foreign companies. These perform their compliance role as an additional part of their duties.
The overarching objective of our compliance activities is to prevent compliance violations. We achieve this by taking appropriate measures that are based on the Company’s risk position, in keeping with our three-tier activity hierarchy – “Prevent, Detect, and Respond.” Our compliance activities focus primarily on prevention: Transparent rules, well-informed employees, and early identification of potential infringements are the keys to success here.
Our Code of Conduct for employees is the foundation for legally and ethically acceptable behavior in this area. It summarizes the main rules, explains them using examples, and gives concrete recommendations for dealing with colleagues, customers, business partners, competitors, shareholders, public authorities, and the media. At the same time, the Code refers to our key internal guidelines, offering employees a rapid overview.
Among other things, our Code of Conduct for employees contains rules on how to ensure fair competition and anti-corruption. In line with our corporate value of fairness, it clearly states that we aim to outperform our competitors fairly and honestly, and that we will not employ any unfair practices to prevent, restrict, or distort competition. In addition, our Code of Conduct clearly sets out the measures that we take to prevent corruption, and uses concrete examples to explain what we mean by anti-corruption. We do not tolerate corruption, regardless of where it happens, whom it targets, or what the reason for it is. In line with this, directly or indirectly offering or granting any form of undue benefits (bribery), and requesting or accepting such benefits (corruption), are prohibited.
These basic rules are set out in more detail in our internal guidelines on preventing corruption and dealing with incentives and conflicts of interest. The guidelines are supplemented by approvals processes and confidential reporting channels plus IntegrityLine, the new electronic whistleblower system introduced in 2021. Once again there were no incidents of corruption or indications of potential cases of corruption in the reporting period, as in the year before.
An e-learning course on the Code of Conduct is used to familiarize employees with its content in an interactive, easily understandable way. It is an integral part of the onboarding process for new staff. In addition, new employees are made aware of the importance of compliance during their “welcome day.“
We use specific measures to benchmark whether we have achieved our compliance goals. Measures-based performance indicators include training and e-learning course participation rates or the number of approvals issued in the course of anti-corruption and other compliance processes.
A total of 6,679 employees (2020: 6,586; 2019: 5,845) had passed the test at the end of the mandatory e-learning course on the Code of Conduct as of December 31, 2021. This corresponds to an overall success rate of 91.22% (2020: 92.29%; 2019: 92.50%).
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