Compliance Management at Springer

© strixcode/fotolia [m] In 2009 Springer started to build up an effective and transparent Compliance Management System.

That system consists of five pillars:

1. Compliance Office & whistle-blowing
    system

2. Springer’s Guideline System

3. Internal communication and trainings

4. Reporting and Compliance Reviews

5. Supplier Code of Conduct and diligence on 3rd party business partners

All of these pillars serve to protect Springer more efficiently from material and immaterial damages.

As a guide for day to day business, ethical principles which comply with local laws and regulations have been defined and implemented. Due to an extension of the organizational and monitoring duties, liability risks should be minimized. The only risks that remain are those which are unforeseeable, which may occur as a result of human errors or misjudgments, or a deliberate violation of these principles.

1. Compliance Office & whistle-blowing system

Thomas Thiekoetter is Springer’s Global Compliance Officer. He is available to all employees, suppliers and customers, for consultation and support in all questions concerning compliance, harassment, discrimination or fraud protection.
Thomas Thiekötter has direct access to Springer’s Audit Committee. This ensures that breaches or suspicions of breaches of law or internal regulations are dealt with appropriately.

Additionally all employees, suppliers and customers can contact Elke Schaefer, attorney at law. As a neutral and external ombudswoman, Elke Schaefer is obligated to maintain confidentiality as well.

The professional whistle-blowing system BKMS has been implemented in order to strengthen the early disclosure of risks or misconduct, and to protect Springer from material and non-material damage. BKMS is available to all employees and business partners via the Internet and can be used to address non-compliances, complaints or recommendations.

2. Springer’s Guideline System

Springer´s System of Guidelines comprises the Code of Conduct, global guidelines which apply to all Springer entities or corporate processes and local guidelines. The Code of Conduct sets out Springer’s legal and ethical principles; it is the guide for the day-to-day business to all employees, managers and directors at Springer.

The global and local guidelines provide detailed rules for specific business transactions or for particular countries or entities.

3. Internal communication and training

Springer informs its employees about the Compliance Management System by using different channels and media.

All information and documents about the system are available on Springer´s intranet. Videos explain in an “easy to digest” way the basic principles of Springer’s Code of Conduct and some of Springer’s major global guidelines.

Additionally eLearning programs have been developed to raise awareness for anti-corruption measurements and potential threats regarding competition and anti-trust compliance.

Finally Springer’s Compliance Officer supported by Internal Audit offers sessions at all Springer’s locations worldwide to inform local staff about the major components of Springer’s Compliance System.

4. Reporting and Compliance Reviews

Springer prepares and distributes twice a year a Compliance Report for the Springer Group summarizing single compliance reports received through the whistle-blowing system and presenting the status of the various ongoing initiatives related to Compliance.

Based on that report the Springer management regularly reviews the effectiveness and  efficiency of the Compliance System. The report is distributed to Springer´s owners, BC Partners, to Springer´s Management Board and to external auditors.

Springer has constantly challenged its Compliance System over the last years. Step by step resources, tools and processes have been optimized or amended to meet the changing requirements set by external parties or by Springer itself. Thus Springer is raising compliance awareness and ensures that environmental, safety and health consciousness among its employees and business partners remains at a high level. Springer will continue to develop and adapt its Compliance Management System in the future.

5. Supplier Code of Conduct and diligence on 3rd party business partners

Springer expects from its suppliers to familiarize themselves with and adhere to the business, ethical and environmental, health and safety standards as laid out in Springer´s Supplier Code of Conduct.

Specific suppliers will receive this code of conduct per email. Additionally to ensure compliance with these standards Springer regularly performs supplier audits either as standardized self-declaration request or alternatively as on-site audits performed by experienced Springer auditors.