The Otto Group and its Group companies depend on their good reputation. This makes it all the more important for us to have a clear commitment to compliance. What this means for us on a daily basis is described below.
Compliance, meaning to act within the framework of applicable laws, standards, and voluntary commitments, is a key requirement for all market players since it is the only way to ensure that fair competition works properly. These requirements apply in particular for the Otto Group, however: the Otto Group and its Group companies also set themselves apart from the competition through an unconditional commitment to a comprehensive understanding of responsibility, or as our CEO Alexander Birken puts it: “Responsible conduct has always been deeply rooted in how we view ourselves as a family business—and it serves as the foundation for fairness and integrity in our business transactions.”
Compliance is thus not only a requirement made necessary by law, but is a requirement that should be practiced by all employees based on a profound conviction. At stake here is nothing less than the credibility of everything for which the Otto Group stands. But how can you make this concept a permanent part of daily work routines? And how can paragraphs and guidelines be filled with life?
For one thing, the Otto Group can rely on its employees. Whoever joins the team at the Otto Group or one of its Group companies is consciously aware of this commitment. The Otto Group makes no attempt to conceal its values: sustainability, accountability, and fairness. This purpose, i.e., the fact that one’s job is seen as meaningful and valuable beyond just being a means of earning a living, plays a key role in recruiting and managing human resources in the Otto Group. There is thus good reason to believe that employees at the Otto Group are more motivated on average when it comes to viewing fair play as the top priority of their work and will thus also be happy to abide by the rules.
Resting the sole responsibility for compliance on employees, however, would be a mistake and is simply not possible due to the fact that there are many complex codes and standards to be dealt with. Everybody knows that any form of bribery, no matter how harmless it may seem, is taboo. However, one’s moral standards and personal sense of what is legally right and wrong quickly reach their natural limits in other major fields of compliance such as data privacy, information security, and antitrust law. That’s why the Otto Group has created clear structures with its compliance management system, established binding guidelines, and defined general rules of conduct which are taught in on-site training sessions and online courses.
Continually improving processes within the Otto Group and its Group companies under the premise “prevent, detect, respond” and purposefully designing them to prevent the opportunity to violate compliance rules from arising in the first place is also just as important and thus an inherent part of compliance management. The instruments used here are well known: transparency, prevention, and education, as well as different ways of (anonymously) pointing out rule violations. No back-room deals are made at the Otto Group. All important decisions are taken in teams, with different authorities signing off at various levels. Potential risk factors are systematically identified in all major Group companies and recorded and shared in one central system. This is the Otto Group’s proactive, transparent, and collaborative approach to managing risk. Compliance mechanisms are constantly being adjusted in this process. The Compliance Office and the Compliance Committee, among others, who report to the Compliance Officer on the Executive Board, ensure that this is done. Compliance is monitored on all levels within the Otto Group.
A security system is only effective to the extent that it is resilient, however. So what is to be done if employees, business partners, suppliers, or customers observe behavior that seems questionable to them in terms of compliance? In such cases, it is crucial to have an atmosphere of trust and maintain the desired level of anonymity. Anyone who wants to report something that they believe violates the compliance rules must be sure that the information or suspicions will be treated confidentially. There are two ways in which this can be ensured. Firstly, it is possible to ask questions or submit a report online and if desired – completely anonymously – via the internal whistleblower portal SpeakUp. To do this, the whistleblower sets up a mailbox, which is then used for correspondence to guarantee the highest level of protection for whistleblowers. Secondly, anyone can turn to the Otto Group’s external compliance ombudsman, Dr. Rainer Buchert. As a lawyer, he is bound by professional secrecy and is not allowed to pass on any information to third parties – but he can, with the consent of the person submitting the report, initiate the appropriate steps within the Group.
All of this underscores the fact that compliance is not only taken seriously in the Otto Group but is in fact the inalienable basis of our business or, as Petra Scharner-Wolff, Group Chair of Finance, Controlling, and Human Resources, puts it: “Our business success is directly linked to compliance. For we can only gain and maintain trust if we act with integrity and in compliance with the rules.”