Preventing acts of corruption is a high priority for Mitteldeutscher Flughafen AG and its associated companies. Corruption is not a trivial matter; it does massive harm to the group, every one of our employees and society at large.
To prevent such occurrences and to protect our shareholders and employees from contraventions of regulatory and criminal law provisions during the course of their official duties, appropriate precautions have been taken within the group. These include binding rules on the giving and receiving of gratuities, and conduct in the marketplace. In addition, an ombudsman has been appointed as an external contact for internal and external persons providing information.
This procedure is intended to encourage responsible, legitimate and ethically correct conduct and lays a solid foundation for the long-term success of our company.
Ombudsman Dr. Axel Bauer
Giving and receiving gratuities
The giving and receiving of invitations, gifts and other gratuities in relation to the performance of official duties is prohibited. An exception is made where it is customary or courteous to give or receive such gratuities, provided these are within socially acceptable and generally approved limits. Every gratuity received or given is subject to the corresponding tax rules concerning benefits in kind.
Conduct in the marketplace
All group employees are required to observe all relevant statutory provisions. This applies in particular with regard to the laws on public procurement, unfair competition and restriction of competition.
As required by our compliance guidelines, Mitteldeutscher Flughafen AG has set up a ‘whistleblowing’ system and has appointed the well-known external lawyer Dr. Axel Bauer as an ombudsman. Many companies and airports use whistleblowing systems as effective preventative tools, and they are recommended as a best practice solution by Transparency International Deutschland e.V.
Within our anti-corruption management strategy, the ombudsman’s role is to receive information on acts of corruption, irregularities, conflicts of interest and contraventions of laws, and to forward them to the appropriate departments or people at Mitteldeutscher Flughafen AG. He will only forward such information if he has permission from the person providing it to do so. The ombudsman does not accept general complaints or suggestions for improvements. Because the ombudsman has the legal right to refuse to give evidence, anyone providing information will be assured that the information will be treated in confidence and impartially.
People reporting this kind of information are not informers. Rather, in doing so they are helping to avoid harm and to ensure that the law is upheld. The ombudsman Dr. Axel Bauer can be contacted as follows:
Dr. Axel Bauer, Lawyer
LEXPERT Dr. Bauer & Partner Rechtsanwälte
Tel.: +49 351 8888-10
Fax: +49 351 8888-191
Internet: http://ombudsmann.lexpert.de [German only]
By setting up an ombudsman system we are creating an additional channel for drawing attention to breaches of compliance. Naturally, employees can continue to contact their line manager, the general managers, the legal department and the audit department as internal points of contact for such matters.