Compliance Policy
Introduction
This manual defines the measures and activities for implementing compliance within the Meyer Logistics Group and provides all essential descriptions of the organisational structure and operational procedures of the compliance organisation.
Fundamental Principles
Compliance means ensuring that the conduct of all employees and the management complies with statutory requirements and internal company rules, as established in the Code of Conduct and other corporate policies. Our group of companies has decided to formally document its long-standing commitment to legal compliance and communicate it to employees with relevant responsibilities, thereby emphasising the importance that senior management attaches to these principles. Binding guidelines are to be established for all employees and management and communicated to everyone concerned. The objective of the compliance management system is to ensure adherence to all applicable internal and external laws, regulations and policies. Compliance must be maintained without exception across all departments and areas of the company. This also serves to minimise existing liability risks for the company and its responsible managing directors by establishing clear guidelines and defined responsibilities.
Compliance Culture
The compliance culture is primarily shaped by the integrity of the company’s legal representatives and the management’s unequivocal commitment to responsible corporate governance in accordance with applicable rules and legal requirements. To this end, the management has established principles of conduct set out in the Code of Conduct, which is binding on all employees, managers and members of the management. The management team recognises its responsibility to lead by example and is committed to managing the company in a legally and ethically impeccable manner while upholding the fundamental values laid down in the Code of Conduct (“Tone from the Top“).
Collective Responsibility / Zero Tolerance
Compliance can only be effective if all employees align their actions with these fundamental values. Every employee is therefore responsible for observing and applying these rules in their daily work. Our group of companies follows a zero-tolerance approach to compliance. This means that any conduct detrimental to the company will be investigated, clarified and sanctioned according to the severity of the violation, irrespective of the individuals involved.
Compliance Organisation
Overall Responsibility of Management
The compliance organisation is an independent component of the company’s corporate governance framework. Management bears overall responsibility for compliance with applicable regulations and, consequently, for compliance matters. The risk management structure is integrated into all key business processes.
Risk management responsibilities and procedures are organised as follows:
- The Compliance Officer, who reports directly to senior management, oversees implementation.
- The Human Rights Officer is responsible for the overall coordination of risk management.
- An independent team or external consultant conducts detailed investigations and handles complaints.
- Regular training and communication measures promote a culture of compliance throughout the company.
This structure ensures that compliance and risk management are integral components of our business processes. Regular training and communication activities foster a culture of compliance and support adherence to legal requirements and internal company policies. Internal audits and external advisory services help ensure that the Human Rights Officer acts objectively.
Objectives of the Compliance Organisation
The objective of the compliance organisation is to ensure that the principles and measures of compliance are understood and observed by all relevant individuals (employees, managers, etc.) in accordance with their respective responsibilities and are applied in their daily work (“Tone from the Middle“).
A further objective is to identify risks of regulatory or policy violations at an early stage, prevent such violations and report any violations that have already occurred to the Compliance Officer. This enables (a) the immediate cessation of the violation, (b) the imposition of disciplinary measures where appropriate and (c) improvements to the compliance organisation or its processes where necessary.
Responsibilities of the Compliance Organisation
The Compliance Officer has the following responsibilities:
- Developing and implementing the compliance programme and carrying out the necessary activities in cooperation with managers (head office & regional offices), who are responsible for their respective organisational units.
- Continuously monitoring and taking account of economic and legal developments within the company and its business environment to prevent potential compliance violations.
- Developing and implementing appropriate communication measures to convey the principles established in the compliance programme.
- Acting as the point of contact for management, executives and employees regarding compliance-related questions and concerns.
- Independently conducting reviews within the various departments to assess the implementation of compliance measures and identify potential violations.
- Providing regular quarterly reports to management on the implementation status of the compliance programme and all relevant incidents.
Compliance Programme
The compliance programme comprises measures, activities and processes designed to ensure that business operations are conducted in accordance with applicable laws, regulations and internal principles and rules. These include, but are not limited to:
- compliance with road traffic and vehicle registration regulations in the operation of vehicles,
- compliance with social regulations governing road transport,
- compliance with tax regulations,
- compliance with regulations concerning state aid and subsidies,
- compliance with administrative and criminal law provisions,
- compliance with applicable hygiene standards.
In this context, specific responsibilities will be formally delegated to the logistics and regional managers operating at the various branches. Regardless of this delegation, all employees remain obliged to comply with the aforementioned regulations.
The programme is divided into three areas of action:
Prevent, Detect and Respond.
The ML Compliance Programme
 |
 |
 |
|
|
|
Prevention
Clear and consistently implemented policies make a significant contribution to preventing improper conduct before it occurs. The Code of Conduct, which is binding on all employees, forms the core of the compliance programme.
Policies / Processes
Code of Conduct (CoC)
The CoC sets out the essential principles of conduct that all employees are obliged to observe, some of which are also derived from other corporate policies. These principles relate not only to compliance with statutory requirements but also to the company’s broader values and ethical standards. The Code of Conduct is distributed to all employees or incorporated into the onboarding process for new employees. Employees must confirm receipt and acknowledgement of the CoC by signing the relevant document.
Compliance Policy and Compliance Programme
This policy summarises the fundamental principles, responsibilities and objectives of the compliance organisation, the appointment of the Compliance Officer and the compliance programme for which the Compliance Officer is responsible. The policy is reviewed annually and updated to reflect any changes in circumstances or requirements.
Employees must be guided in their actions by generally applicable legal provisions and the ML policies issued by the various departments and published on the intranet (IT, company cars, working from home, GDPR, driver instructions, etc.). Irrespective of departmental responsibilities, the compliance organisation is responsible for conducting an annual review of the ML policies to ensure consistency, accuracy, completeness and appropriateness (policy management). The compliance organisation forwards suggestions for improvements or additions to the relevant departments.
The publication of new policies and any additions or amendments to existing policies must be coordinated with the Compliance Officer. All policies must identify the issuing department or responsible author, specify the purpose and intended audience, and include the date of initial publication, the version number and the revision history. The compliance organisation provides a policy template incorporating these requirements.
Publication of Policies
Following approval by the compliance organisation and subsequent authorisation by management, policies are published centrally in a designated location on the intranet (LM-Connect) and incorporated into the onboarding process. Additional training and communication measures help ensure that managers and employees understand and accept the rules and policies.
Training
- An online training application, accessible via a link, is provided to communicate the essential elements of the CoC and the compliance programme. All administrative and commercial employees are required to complete the compliance training, including the integrated final assessment, once a year.
In-Person Training for Managers
In-person training sessions on the CoC and compliance are provided for managers and, upon request, for other employees. Documented participation in an in-person training session replaces the requirement to complete the online training application.
Communication
Communication Strategy (“Tone from the Top”) All communication measures designed to convey compliance-related information are based on a communication strategy that selects the most appropriate communication channel according to the content, target audience and desired level of understanding. This strategy incorporates the “Tone from the Top” (the clear commitment of senior management).
Personal Communication (“Talk about it”) Training and personal communication are central elements of compliance communication. Regular dialogue with employees, managers and senior management ensures that employees are informed about the current status of the compliance organisation and know whom to contact with compliance-related questions. Personal communication measures include structured one-to-one discussions with managers, small-group discussions (Compliance Talks), and the exchange of experience and information within the compliance organisation.
Electronic Communication LM-Connect contains a dedicated “Compliance” folder with all relevant documents issued by the compliance organisation for information and knowledge sharing (“Find it“). In addition to the CoC and the Compliance Policy, this includes training materials, guidelines, process documentation, organisational charts and areas of responsibility. Checklists and self-assessment tools are also available for matters such as accepting and granting gifts or other benefits (“Check it“). Suggestions for improvement can be submitted via email to compliance@meyer-logistik.com (“Improve it“).
Detection
Investigating conduct that violates applicable rules is essential for effective compliance. Reliable reporting channels through the internal helpdesk and protection against retaliation for internal whistleblowers ensure that potential misconduct can be reported, investigated and clarified.
Helpdesk
Compliance Hotline
A compliance hotline is available by telephone (06175 4007 917) or email (compliance@meyer-logistik.com) for reporting suspected violations of applicable rules (“Tell us“). All reports are treated in strict confidence and may also be submitted anonymously upon request. Meyer Logistik does not tolerate any form of retaliation against whistleblowers.
The hotline can also be used to ask questions about the application and interpretation of the CoC or the Compliance Policy (“Ask us“) or to obtain approval for accepting a gift or other benefit (“Approve it“).
Reviews and Investigations
Investigations All reports of potential misconduct received through the helpdesk are investigated by the Compliance Officer.
Reviews The Compliance Officer regularly conducts reviews within individual departments to assess the implementation of the compliance programme, determine whether the relevant rules are consistently observed and identify any compliance violations. When conducting reviews, the Compliance Officer may also draw on findings from audits carried out by the Quality Management Representative, who provides the Compliance Officer with the relevant findings from audit reports.
Internal Departmental Reviews Independently of the reviews conducted by the Compliance Officer, managers are responsible for ensuring through regular, ongoing process controls within their departments that applicable legal requirements and compliance rules are known and observed.
Response
Prevention and Immediate Remediation of Violations
As soon as an imminent compliance violation is identified, all appropriate measures must be taken to prevent it. If a violation has already occurred, it must be remedied without delay.
Disciplinary Measures for Violations
Compliance violations are subject to disciplinary measures permitted under employment law, depending on the severity of the violation. Decisions regarding such measures are the responsibility of management, subject to all applicable statutory participation rights, responsibilities and procedural requirements.
Case Tracking / Reporting
Reports and indications of misconduct or potential compliance violations are centrally documented and categorised by the Compliance Officer in a consistent manner. All cases form part of the Compliance Officer’s reporting to management. The Compliance Officer reports regularly, generally on a quarterly basis, to management on the implementation status of the compliance programme, all compliance violations identified during the reporting period and the status of measures taken in response.
Remediation of Deficiencies
Findings from investigations into incidents are used to implement safeguards designed to prevent recurrence. This includes adapting and improving existing processes and implementing new measures to prevent future violations.
Measures to Ensure Confidentiality
Confidentiality Agreements
All employees involved in the complaints procedure sign confidentiality agreements to safeguard the confidentiality of information. These agreements oblige employees to treat all information obtained in the course of their duties as strictly confidential and prohibit disclosure to unauthorised third parties.
Training and Awareness
Regular training sessions are conducted on the importance of confidentiality and the relevant legal requirements. These sessions raise employee awareness and promote compliance with company policies. Employees receive training on protecting confidential information and ensuring data protection.
IT Security Measures
Access to information relating to the complaints procedure is restricted to authorised individuals and protected by technical measures such as encrypted data transmission and secure access controls. These IT security measures ensure that sensitive data can only be accessed and processed by authorised persons, thereby preserving the integrity and confidentiality of the information.
Confidentiality of Identity
Anonymous Reporting Channels
Anonymous reporting channels are provided to protect the identity of whistleblowers. These channels allow employees to report incidents without disclosing their identity, thereby fostering a culture of trust and openness within the company.
Access Restrictions
Only specifically authorised individuals have access to confidential information. These access restrictions are necessary to prevent confidential data from falling into unauthorised hands and to ensure the protection of whistleblowers.
Confidentiality Declarations
All individuals involved in the process undertake to maintain confidentiality. This is ensured through the signing of confidentiality declarations that establish an obligation to protect information obtained during the complaints procedure from unauthorised disclosure.
Protection Against Disadvantage
Anti-Discrimination Policies
Clear policies prohibit any form of disadvantage resulting from the submission of complaints. These anti-discrimination policies ensure that all employees are treated fairly and equally, regardless of whether they raise complaints.
Protective Mechanisms
Mechanisms are in place to protect whistleblowers against retaliation, including the option to submit complaints anonymously. These protective measures ensure that employees do not have to fear adverse consequences when reporting violations. They also include support from management and an explicit commitment by senior leadership to protecting whistleblowers.
Environment
Environmental Protection
We are committed to minimising our environmental footprint by using sustainable resources and technologies to reduce energy and raw material consumption, minimise waste and control emissions. Our objective is to continuously improve our environmental performance and make a positive contribution to environmental protection.
Greenhouse Gas Emissions
We are committed to reducing greenhouse gas emissions, preventing environmental pollution and using resources efficiently. We continuously monitor our emissions and actively work to reduce them. This includes introducing energy-efficient processes, using renewable energy sources and promoting sustainable transport solutions.
Social Responsibility
Employee Rights and Working Conditions
We comply with all applicable laws and regulations relating to employee rights and working conditions. We respect the rights of our employees and strive to provide safe and healthy working conditions. We promote diversity, equality and equal opportunities in the workplace and create an inclusive working environment in which all employees feel valued and can realise their full potential.
Social Engagement
We are committed to social initiatives, support charitable organisations and promote social responsibility and sustainability. We invest in education and science and support local communities. Our activities aim to generate positive social impact and contribute to improving the quality of life in the communities in which we operate.
Governance
Ethics and Integrity
We adhere to high ethical standards and uphold the principles of integrity, transparency and compliance in all our business practices and decisions. We reject all forms of corruption and bribery and are committed to fair and ethical business practices. Our actions are guided by the values of honesty, reliability and responsibility.
Transparent Decision-Making
Our decision-making processes are open and transparent in order to strengthen the trust of our stakeholders. Oversight and control mechanisms ensure that our business practices are aligned with our corporate objectives and values. Transparent reporting and clear communication channels are essential to maintaining the trust of employees, customers and business partners.
Final Provisions
This Compliance Policy enters into force upon signature by all members of the management and applies without exception to all employees in Germany, Austria, Sweden, Romania and the Czech Republic. It is reviewed regularly and updated as necessary to ensure that it continues to meet current legal requirements and business needs.