In the Examine stage of the Compliance Program processes to detect hints of possible violations ("Red Flags") are implemented.
In 2018 Corporate Compliance has conducted 49 compliance audits.
In order to detect potential risk exposure at an early stage, Schindler legal counsel conduct reviews and grant clearances for the following business processes:
Corporate Compliance conducts many preventive Compliance Audits per year at Schindler entities worldwide. All audits consist of Risk Exposure (especially competition and corruption) and Compliance Program Ratings and 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|
Investigations: To learn more about investigations go to ENFORCE.
Mock dawn raids are internal antitrust investigations which are conducted in regular intervals and in a similar way as executed by Competition Authorities. An investigation team of internal and external legal counsel, IT specialists and compliance officers "raid" the offices of a Schindler entity at several locations in order to verify full compliance with applicable competition law.
Managers of Key Functions carry out Compliance Monitoring activities, as defined by Corporate Compliance for major business functions.
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.