Report on the Compliance System

MVV Energie introduced a comprehensive and stringent compliance system in the 2008/09 financial year. The organisational structures, processes and responsibilities thereby required were determined and the head of the group legal department appointed as Group Compliance Officer.

In the past 2008/09 financial year we provided those employees with contact to customers in the sales, energy-related services and environmental energy businesses with detailed training as to how corruption is to be combated and as to the correct forms of behaviour when offered non-monetary gifts and invitations. All management staff have been briefed on MVV’s compliance system. Furthermore, we have compiled an extensive Compliance Handbook, which has been made available to all employees as part of the MVV Management Handbook on the intranet. Here, all company employees can find the relevant regulations and explanations, together with contact partners to approach in cases of doubt.

We have laid down specific business processes for the compliance system. Gratuities and invitations are recorded and all business fields, divisions, group departments and subsidiaries are systematically inspected on a sample basis during the year and within a comprehensive audit once a year. Employees wishing to provide any tip-offs can use the “whistleblower hotline” we have set up. At the end of the financial year, each manager responsible must confirm that legal requirements have been complied with and that the employees have been briefed and trained. Confirmation is provided using a prescribed questionnaire tailored to specific circumstances at the business unit.

MVV’s compliance system was audited by the group internal auditors in the 2008/09 financial year and assessed as being appropriate to its function.

Over and above the training already in place for newly appointed managers, we plan to provide systematic training to upcoming management staff in all areas of responsibility as well. To this end, the personnel development, group organisation, technical and group legal departments have jointly prepared a suitable seminar to inform participants on basic features of management responsibility at the MVV Energie Group. From April 2010, the seminar will be obligatory for all levels from section managers upwards.