Managing Conflict of Interest - Organisation for Economic Co ...

Compliance enforcement in a multinationalbusiness context: The Bayer business modelHans-Josef SchillPresident Director of PT Bayer IndonesiaOverview of Bayer’s Business ModelEnsuring Sustainability and Promoting Compliance to CombatCorporate FraudThe Bayer Group, with its headquarters in Leverkusen, Germany,is a successful multibillion-dollar global company (sales in 2006:29 billion euros) employing more than 106,000 employees worldwide.Its core competencies are in the fields (subgroups) of healthcare, nutrition, and high-tech materials. As a global company with adiverse business portfolio, the Bayer Group is exposed to numerouslegal risks, particularly in the areas of product liability, competitionand antitrust law, patent disputes, tax assessments, and environmentalmatters. In the 1990s, Bayer experienced some violations inthese areas and was forced to pay hefty fines.In response, Bayer launched its first corporate compliance program(CCP) in 1999 and published the second edition of its handbookemphasizing enforcement and information in 2004. Bayer’s comprehensiveprogram ensures global responsibility through its network ofcompliance officers and committees per subgroup, as well as localresponsibility through its network of compliance officers and committeesworking within each individual organization or subsidiary.From the outset, Bayer’s program has been anchored in a zerotoleranceapproach to corrupt practices. The program is implementedfrom the top down, involving high-level managementsupport both globally and locally to implement an array of policiesthat promote a corporate culture of ethical behavior. Specific policiesrelated to corporate fraud include: antitrust, anti-bribery, anticorruption,avoidance of conflicts of interest, and antiharassmentand antidiscrimination policies. Other policies and provisions thatpromote corporate social responsibility include: antidrug policies,occupational hazards/workplace safety guidelines, environmentalconsiderations, and the protection of intellectual property rights.ADB/OECD Anti-Corruption Initiative for Asia and the Pacific