The self-image, mission and vision of the Fraunhofer-Gesellschaft is anchored in our Statute and in our Guiding Principles. At the same time, responsible corporate governance naturally means to us adherence to legal requirements and rules for national funding.
To systematically ensure compliance, we operate a Compliance Management System, which was successfully evaluated for suitability in 2015. The goal of compliance is to provide transparency and responsible adherence to legal regulations in order to protect our organization and employees.
For the Fraunhofer-Gesellschaft compliance is part of our daily business. Hence, the structure of our Compliance Management System builds on established responsibilities. The Executive Board is responsible for the system as a whole. The Executive Vice President Finances and Digitization, Andreas Meuer, is appointed as Chief Compliance Officer (CCO). The responsible business units and appointed officers at the headquarters assist in the implementation. At each of the individual Fraunhofer Institutes the respective management is responsible for compliance implementation. All employees are urged to follow the given rules and they have the possibility to actively participate in the improvement of regulations.
To complement this, since 2011 the Compliance Office comprehensively supports and systematically reviews and optimizes the Compliance System. Furthermore, Institute and executive management representatives, as well as other managers, regularly attend Compliance Committee meetings. During such meetings, participants are informed by the Compliance Office of the latest developments in the Compliance Management System while providing information on the system and suggesting important measures or issues.
All roles and responsibilities are described in a Compliance Management System manual and are communicated throughout Fraunhofer.
In operating our Compliance Management System it is important to us to preventatively sensitize all employees to risk-relevant topics. Our internal Fraunhofer Code of Conduct transparently summarizes the main organization-wide compliance-relevant topics. It provides applicable framework conditions and specific recommendations for action to provide employees with orientation for their daily work. Based on this Code our most important compliance topics, such as good scientific practice and integrity, Information security, privacy and confidentiality or terms of employment in the »Principles of the Fraunhofer-Gesellschaft regarding cooperation« are described for our business partners.
Internally the general rules can be easily accessed and training sessions and workshops regarding compliance topics are made available to employees. In addition, web-based and on-site trainings on issues such as corruption prevention or data protection are held to raise awareness. The Compliance Office co-hosts and supports such measures in cross-departmental, system-related workshops and in trainings at the executive level. The Compliance Office is also the contact for rule-related questions.
As a publicly funded organization, the Fraunhofer-Gesellschaft is subject to both special rules and regular external audits. For example we are audited by the Federal Audit Office, the local tax office, and external auditors.
Compliance adherence and implementation within the organization is also subject to regular internal supervision and documentation. Responsible business units and appointed officers, as well as the Internal Audit Office perform issue-specific audits. Management at the institutes monitors the site-specific adherence to the standards and are in turn regularly audited by the internal Audit Office.
The Executive Board is informed – regularly or as needed – about the audit findings in special reports. Intentional violations are not tolerated and are penalized accordingly. At the same time, the Compliance System is continuously reviewed and improved by identifying weak points and making appropriate adjustments.
For us, maintaining a positive and open organizational culture involves compliance with legal and internal requirements as well as responsible handling of indications of violations or misconduct. Relevant reports of potential wrongdoings help us counteract violations at an early stage and thus prevent damage to our organization, our employees and our business partners. We therefore offer the possibility of establishing contact via various reporting channels in order to notify any breach of external and internal regulations.
To bring forward details In case of suspected misbehavior our employees can contact different channels and contact persons depending on the topic, which are clearly sorted by subject matter on the intranet and internet.
Often, misconduct is not addressed through the usual reporting channels for fear of personal disadvantages. To protect all parties involved, we have therefore introduced an anonymous, electronic mailbox for reporting potential misconduct or major rule violations. The purpose of this whistleblower system is to offer employees of Fraunhofer-Gesellschaft and external partners the possibility to report detected infringements to the responsible Fraunhofer bodies and to be able to communicate with them in a manner that protects the whistleblower, while maintaining their anonymity and without being prone to any personal disadvantages.
By this means, significant violations of applicable legal and organizational rules or codes of conduct can be reported. Typical examples are criminal offenses (such as corruption, theft, embezzlement, etc.), scientific misconduct, privacy violations or environmental crime. We carefully and confidentially examine every report submitted and consistently and appropriately prosecute all genuine violations accordingly.
Prof. Dr. rer. publ. ass. iur. Alexander Kurz, Executive Vice President for Innovation, Transfer and IP Management
Headquarters of the Fraunhofer-Gesellschaft
80686 München, Germany