Overview

Integrity, that is, compliance, is one of the four basic values listed in Daimler AG‘s code of conduct (the other three are passion, respect, discipline.)

Daimler established its daughter company Mercedes-Benz Manufacturing Hungary Ltd. (MBMH) in 2008, which stands in its 100% ownership. The Mercedes-Benz plant in Kecskemét was built and now operates in alignment with the basic values and rules. Naturally, there have been some changes over the years but our corporate basic values and conformance to all relevant rules (compliance) are indispensable parts of our culture.

Compliance is an English word, meaning ”adhering to, being in align with something”. In our case by compliance, we mean adhering to rules and regulations, complying with the obligations and principles that we undertook.

More information of the topic Integrity and Compliance here on Daimler AG‘s website.

Compliance organization:

Daimler created its internationally reinforced compliance organization in 2006. The company placed the emphasis on prevention and comprehensive information by means of education and training programs, communication, and creating a system for reports and feedback. At MBMH Ltd. the Legal and Compliance Department is in charge of dealing with compliance issues and sends regular reports to the Group Compliance (GC) in Germany.

Compliance program:

A group-wide compliance program is in operation, including MBMH Ltd. At the focal point of the program – beyond taking the business model into consideration – is identifying, evaluating and handling the potential and existing risks.

The basis for avoiding or minimizing damages is the established communicational and educational system. We operate the employers reporting system (BPO – Business Practice Office) in collaboration with our mother company, whose goal is to enable that severe rule violations are directly reportable and thus their independent examination can be guaranteed.

According to risk classification Hungary belongs to the countries of medium risk. We do have internal control procedures that were determined in align with this classification.

Our compliance regulations concerning our business partners are separately determined in contracts.

The goal that we expect to be achieved by ourselves as well as our partners, is to establish and promote a rule complying conduct, to prevent misconduct, and in particular, corruption.

Compliance objective:

Anti-corruption measures are of the highest priority for the Daimler group. Every new colleague has to take part in an obligatory introduction training where they are educated about corporate values and the prevention of misconduct. Colleagues working in areas of higher risk and employees in employees in leading positions will take part in further training in order to gain the capability to make the appropriate decision in a difficult situation.

The group introduced a web-based training in the year 2013, which has been received by more than 100,000 employees. 

Reporting system - BPO

Our BPO (abbreviation of Business Practices Office) is in charge of handling reports of misconduct.

Mercedes-Benz Manufacturing Kft. is in the ownership of Daimler AG, which means that a reporting system is in operation at us, too. This system belongs to the BPO office in Stuttgart. BPO was established in 2006 by the compliance division of the Supervisory Board of Daimler. BPO is responsible for receiving, documenting and tracking reports on assumed violations of legal regulations or Daimler's internal rules. BPO takes measures for necessary internal examinations and coordinates them. Employees or third parties have the right to send in reports, upon their wish, remaining anonymous as well. The confidential processing of information is guaranteed in every case.

BPO is in charge of examining severe rule violations, with special consideration to:

  • Crimes related to corruption, cartel rights, and money laundering
  • Crimes of theft, careless handling, defalcation and fraud or other crimes of considerable significance or value made against property or in order to gain illegal profit
  • Severe breach of right to bodily or psychological integrity, privacy and data protection
  • Faults in accountancy and bookkeeping auditing resulting in severe consequences
  • Malpractice leading to potentially high damage (over EUR 100.000) for the company
  • Malpractice or misdeeds that are likely to severely damage the reputation of the company
  • Faults by managers from E3 management level and organizational officers (for instance, members of the Board of Management and managing directors of Daimler AG)

Rule violations of lesser significance will be examined and, in case it is justified, will be punished locally at the company.

Contact

Daimler AG
IL/CBP
BPO (Business Practices Office)
HPC: E 703
70546 Stuttgart
Germany
E-Mail: BPO@daimler.com

You can find the report sheet in German at this link on the website of Daimler (reports can be processes in German, English and Hungarian languages.) 

The operation of our BPO complies with the regulations specified in law CLXV of the year 2013 on complaints and reports of public interest and the operative data protection rules. Please be advised that according to these rules you are required to submit your report in good faith and in an honest manner, malevolent reports may result in legal consequences. Anonymous reports may remain ignored and unprocessed.

Information on data protection

The purpose of data processing is the operation of a misuse reporting system, examination and prevention of misuse at the employer in accordance with the law CLXV of 2013 (Civil Code) on complaints and reports of public interest. The legal basis for data processing is the legitimate interest as stated in point f) of paragraph (1) of Article 6 of the data processing European data protection regulation (General Data Protection Regulation No. 2016/679 by the European Parliament and Council, referred to as „GDPR”).

During the data processing the regulations of the Civil Code, the GDPR and the Law I of 2012 of the Labour Code („Mt.”) are in effect.

We inform your that the handler of your personal data by operating the employer‘s misconduct reporting system is Daimler AG (DE-70327 Stuttgart, Mercedesstraße 137) and in relevant cases Mercedes-Benz Manufacturing Hungary Ltd. (6000 Kecskemét, Mercedes út 1.); the data processing party is GCS Compliance Services Europe Limited (Boston House Richmond, Surrey TW9 1QE, UK).

We inform you that your personal information may be stored in the system until the data handling goal is achieved or for a maximum of 6 years after the closure of the examination.

If you have any other questions in connection with processing your personal information, please contact the data protection officer of Daimler, who will be available with their team to provide more information or deal with any other complaints you may have. 

Sebastian Greß
Daimler AG
HPC E600
D-70546 Stuttgart
Germany 

Directive

As a Concerned Party you have the right to

  • request the correction of incorrect personal data about you, and, when necessary, to request the completion of incomplete personal data from the Company (Article 16 of the GDPR)
  • request the deletion of your personal data from the Company, when they are no longer necessary for the application process or for the fulfilling of legal obligations. Special cases are listed in details in Article 17 of the GDPR (“Right to deletion”)
  • forbid the Company to process your personal data, should any of the circumstances stated in Article 18 of the GDPR occur, for example for the duration of an inquiry at the Company, if the subject of the data takes objection to processing their data
  • request and receive the data made available electronically in an electronic, computer-readable format from the Company (Article 20 of the GDPR)
  • object to the processing of data, if your situation creates any special circumstance that prevents the data processing. If it is not in the interest of the Company to protect the data (i.e. execution of or protection against legal claims) then they may not handle your data any further. (Article 21 of the GDPR)

Furthermore, we hereby inform you that we register our data handling according to the GDPR regulations. 

Possibilities of juridical remedy

Upon your request the Company will inform you in writing within a period of maximum 25 days whether we store any personal data regarding you, and if so, what data and under what conditions. Should we, despite our efforts to keep these data correct and up-to-date, store any incorrect information about you, we shall correct them upon your request.

If the Company handles your data for the purpose of fulfilling their legal obligations or enforcing their rightful interest, you have the right to raise an objection with the Company at the contact above. Please contact the Company first with any complaint you may have, we will be pleased to help.

We hereby inform you that if you suffer any encroachment on your rights in connection with our data handling processes, you may lodge a complaint with the National Authority of Data Protection and Freedom of Information at the contact details in Point IX.

We inform you that in the case of an encroachment on your rights or should your objection be rejected you have the right to go to court. The court will handle the case as a special proceeding, judging in the case belongs to the competence of the court. The legal procedure may be started at the Kecskemét Court at the contact in Point IX or at the court of your residence, upon your choice.

If you wish to report a data protection incident, please contact us at: 

Email: cyber.security@daimler.com
Phone: +49 711 17 76758.

A data protection incident is any breach of security that may result in the accidental or illegal eradication, loss, modification, unauthorized publication of or unlawful access to transferred, stored or handled personal data.  

Furthermore, we inform you that on the basis of legal regulations no data protection officer was appointed at our Company.  

Addresses, contact

Nemzeti Adatvédelmi és Információszabadság Hatóság 
(National Authority of Data Protection and Freedom of Information)
address: 1125 Budapest Szilágyi Erzsébet fasor 22/c
E-mail: ugyfelszolgalat@naih.hu
phone: +36 (1) 391 -1400, Fax: +36 (1) 391-1410,

Kecskeméti Törvényszék
(Kecskemét Court)
address: 6000 Kecskemét, Rákóczi út 7., post address: 6001 Kecskemét, Pf.12.,
E-mail:: birosag@kecskemetit.birosag.hu,
central phone number: +36 (76) 519-519

Mercedes-Benz Manufacturing Hungary Kft.
address: 6000 Kecskemét, Mercedes út 1.


Integrity Code

The Integrity Code in effect was prepared in alignment with the principles of UN Global Compact. It places the emphasis on individual responsibility. The basis of our code in everyday business life is fairness, mutual respect, transparency, openness and the compliance with rules. The appropriate conduct is expected not only from the company but towards customers and business partners as well. At our company, the Department of Law and Compliance can provide professional guidance and directions in the area of these topics.

These topics may include:

  • Consideration of human rights
  • Compliance with laws and internal regulations
  • Appropriate conduct towards with authorities, government officials, business partners and customers
  • Dealing with conflicts of interest
  • Prevention of all forms of corruption
  • Protection of corporate assets

Social responsibility also forms part of our integrity code. MBMH Ltd. makes sure in its business operation that it aligns with the current complicated and rather complex political, economic and social life.