Schindler Examine

Examine

In the EXAMINE part of the Compliance Program processes are in place to detect hints of possible violations ("Red Flags").

Compliance Clearances

In order to detect potential risk exposures at an early stage, Schindler legal counsel conduct reviews and grant clearances for the following business processes:

  • Membership and Participation in Trade Associations
  • Meetings with Competitors
  • Export Control
  • Intermediary Due Diligence
  • Invitations to Events
  • M&A Due Diligence

Audits

In addition to Investigations (see ENFORCE) Corporate Compliance conducts more than 30 preventive Compliance Audits per year at Schindler entities worldwide. The audits consist of the following elements:

  • Start-up Meeting with management
  • Compliance Briefings: discussions of function-specific rules and issues with key management functions, based on a structured interview ("Compliance Book")
  • Competition and Corruption Risk Review: evaluation of local risk exposure and launch of control measures to eliminate or mitigate the identified risks
  • Accounts review: review of specified accounts in order to check the legitimacy of payments to third parties, e.g. to intermediaries
  • Unannounced visits of branch offices: to detect hints of compliance risks and to check the coordination in case of external investigations
  • Check of Compliance Implementation: evaluation of how the Compliance Program is implemented locally.
     

"Mock dawn raids": in regular intervals Schindler conducts internal antitrust investigations in a similar way as Competition Authorities. An investigation team of internal and external legal counsels, IT specialists and compliance officers "raids" the offices of a Schindler entity at several locations in order to verify full compliance with applicable competition law.

Compliance Counts: Audits

In 2016 Corporate Compliance has conducted 32 compliance audits. The results are categorized as follows:
White rating=  good compliance behavior, no violations detected
 
Yellow rating=  non compliance with mandatory internal rules and processes
 
Red rating
 
=  compliance violations, non conformity with applicable laws
 
Compliance Radar and Hotlines

Compliance Radar and Hotlines

In order to detect and evaluate possible compliance violations at an early stage, all Schindler employees with a Schindler e-mail account participate in a "Compliance Radar" survey every six months. As part of this online process employees answer questions related to major compliance risks, including Antitrust and Anti-bribery.

Schindler encourages good-faith reporting of potential violations ("Whistle blowing") and protects good-faith whistleblowers against discrimination, as specified in Schindler's Whistleblower Protection Policy.
 

Monitoring

Managers of Key Functions conduct Compliance Monitoring activities, as defined by Corporate Compliance for major business functions.