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Compliance

Compliance Management System

 

Cologne Bonn Airport has implemented a comprehensive Compliance Management System which is subject to ongoing development. The prevention of corruption offenses, or property crime resp., is one of the central concerns.

In order to prevent such incidents, extensive measures have been implemented. These include binding regulations for the employees on the acceptance and granting of benefits and the formation of a compliance committee which coordinates the measures taken and pursues incoming information. Furthermore, an internal reporting office („Internal Audit / Compliance “) has been established, serving as the point of contact for internal and external whistleblowers (see implementation of the Whistleblower Protection Act at Cologne Bonn Airport).

For any questions concerning our Compliance Management System, please contact the Internal Audit/Compliance department:

Alexander Hilgert

Director Internal Audit/Compliance

Heinrich-Steinmann-Str. 12
51147 Köln

For Cologne Bonn Airport, the topic of compliance is of great importance. The legal obligations of the Whistleblower Protection Act („Hinweisgeberschutzgesetz“) are consistently implemented.

The Whistleblower Protection Act („Hinweisgeberschutzgesetz“) is the German implementation of the EU Whistleblowing Directive of 2019. The law shall protect whistleblowers against so-called reprisals and create a secure environment for whistleblowing.

One important rule of the law is the obligation for companies to establish internal whistleblowing systems. According to the law, employees must now have the opportunity to report potential grievances in the company both verbally and in writing.  It must be possible to contact personally a responsible person in the company. In addition to the internal reporting, it will also be possible to contact the external reporting office, which has been established at the Federal Office of Justice:

https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes_node.html

At Cologne Bonn Airport, employees can give hints to the internal reporting office. There are  two ways to do this: First, by contacting the ombudsman, Prof. Dr. Björn Gercke (law firm „Gercke Wollschläger“, Cologne), second, by contacting trustfully the Internal Audit/Compliance department (SR).

In particular, the ombudsman is responsible to  receive compliance related hints and to pass it on to Cologne Bonn Airport. He only passes on information to which he has been authorized by the whistleblower. Furthermore, he is also available to employees as a confidential point of contact.

As a lawyer, the ombudsman has the right to refuse the testimony. Therefore, any report will remain absolutely anonymous if the whistleblower so wishes.

The ombudsman will collect reports of corruption, irregularities, conflicts of interest and violations of the law. General complaints are not collected. Other departments within the company have already been appointed as responsible for reports in accordance with the General Equal Treatment Act (AGG) or for suggestions for improvement.

There are no costs for the whistleblower providing the information.  You can contact our ombudsman in person or by other means of communication:

Foto: Prof. Dr. Björn Gercke

Prof. Dr. Björn Gercke

Lawyer

Gercke|Wollschläger, Clever Str. 16, 50668 Köln

Since January 1, 2024, Cologne Bonn Airport has also fallen within the scope of the "Act on Corporate Due Diligence Obligations for the Prevention of Human Rights Violations in Supply Chains", or Act on Due Diligence in Supply Chains (Lieferkettensorgfaltspflichtengesetz - LkSG) for short. For the first time, the LkSG regulates corporate responsibility for the observance of human rights in supply chains.

The due diligence obligations include the following in particular:

  • Establishment of appropriate and effective risk management
  • Submission of a declaration of principle on respect for human rights 
  • Implementation of preventive measures in the event of identified risks
  • Taking appropriate remedial action in case of identified violation of due diligence
  • Establishment of a complaints procedure
  • Documentation and reporting obligations as part of the fulfilment of due diligance obligations

Cologne Bonn Airport consistently pursues the implementation of the due diligence obligations of this law. Important information and documents can be found below.

Cologne Bonn Airport rejects all forms of human right violations. An appropriate and effective complaints management is therefore an important part of our due diligence processes in order to effectively prevent and remedy any potential negative human rights impacts caused by our company and our business activities. We have established an organization-wide complaints management which is accessible both inside and outside our company and take part in industry-wide procedures.

Within Cologne Bonn Airport, the department „Interne Revision / Compliance“ (Internal Audit / Compliance) is responsible for receiving hints on potential legal violations. Furthermore, a legal ombudsman has been appointed as an external contact person. His contact details can be found on our home page or on the company intranet. Hints of whistleblowers are processed in accordance with legal requirements. The appropriate processing of the information is of great importance to Cologne Bonn Airport.

Foto: Prof. Dr. Björn Gercke

Prof. Dr. Björn Gercke

Lawyer

Gercke|Wollschläger, Clever Str. 16, 50668 Köln

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