TUI Group’s Compliance Management System focuses on the legal sub-areas anti-corruption, competition and anti-trust law, data protection, export controls and anti-money laundering. It defines the related pilot and standard operation of the Compliance Management System and the documentation of the roles, responsibilities and processes in these areas.
The Compliance Management System applies to TUI AG and all German and foreign companies in which TUI AG directly or indirectly holds an interest of more than 50 % as well as other stakes directly or indirectly controlled by TUI AG (so-called ’managed Group companies’). Implementation of the Compliance Management System is recommended for investments not controlled by TUI AG (so-called ’non-managed Group companies’).
In financial year 2016, TUI Group’s Compliance Management System was subjected to a design audit by a leading auditing firm in accordance with auditing standard PS 980 published by the German Institute of Auditors. The audit confirmed that TUI Group’s Compliance Management System has been designed to meet the requirements of that certification standard. In the run-up to the audit, the Group-wide Compliance Management System had been readjusted and compliance processes had been harmonised across the Group.
TUI Group’s Compliance structure supports those responsible in the task of communicating the values and rules and anchoring them in the Group. It ensures that Compliance requirements are implemented throughout the Group in different countries and cultures. TUI Group’s decentralised Compliance structure includes Head Compliance Officers whose role is to implement and support the requirements of Group Legal Compliance. Under the aegis of the Chief Legal Compliance Officer, Group Legal Compliance work with the decentralised Compliance Officers to perform the following tasks at different management levels:
- Raising awareness of Compliance and the technical issues allocated to Legal Compliance
- Achieving the goals of the Code of Conduct and the Compliance Rules
- Providing training
- Advising managers and employees
- Securing the necessary exchange of information
- Monitoring national and international legislative initiatives
- Providing regular quarterly reports to the Board and annual reports to the Audit Committee of the Supervisory Board
In addition, the Group has a Compliance Committee headed by the CFO and consisting of the HR Director, the Heads of Group External Affairs and Communications, Chief Legal Compliance Officer, Group Audit and representatives of the Group Works Council and the TUI Europe Forum. The committee meets on a regular basis as well as ad hoc in order to monitor implementation of the Compliance Management System and obtain reports about key indicators in this area.
The Compliance culture forms the basis for an appropriate, effective Compliance Management System. It reflects management’s fundamental attitude and conduct and the role of the supervisory body. It is expressed in our corporate value ’Trusted’, appealing to our employees’ personal responsibility and their honesty and sincerity in handling customers, stakeholders and employees.
Code of Conduct / Suppliers’ Code of Conduct
The Code of Conduct, drawn up for the entire TUI Group, is a further embodiment of our Compliance culture and enshrines guiding principles for everyone to follow, from the Board members, executives and senior management to every Group employee. It defines minimum standards aimed at assisting our employees in their everyday work and providing orientation in conflict situations. TUI’s Code of Conduct covers anti-corruption, avoiding conflicts of interest and handling invitations and gifts appropriately.
The Suppliers’ Code of Conduct forms the counterpart to TUI’s Code of Conduct. It details our ethical, social and legal expectations of our business partners.
Moreover, business partners are required by contract to observe all national and international anti-corruption laws applicable to the supplier relationship. This places our business relationship with our partners on a solid legal and social basis.
In addition, the principles set out in the Code of Conduct are detailed in various policies and rules reflecting the legal requirements. This is supported by our Group-wide policy management, developing the standards for Group-wide policies and coordinating incorporation of the relevant internal stakeholder groups, e. g. other departments or the works council. This approach is designed to provide TUI Group with a set of policies which are as complete and comprehensible as possible without seeking overregulation. TUI Group’s Compliance Rules offer guidance on appropriate conduct regarding gifts and invitations, data protection and compliance with trade sanctions. All groups of employees have thus been acquainted with policies of relevance to their everyday work.