Business Security Worldwide: The New Compliance Risk Atlas of Deutsche Bahn

By Deutsche Bahn, Nicole Knapp (Deutsche Bahn)
12:06 PM, July 22, 2014

Deutsche Bahn (DB) is an international group active in more than 130 countries that offers mobility and logistics services worldwide. This gives rise to complex challenges in its conduct toward business partners and employees. The DB Compliance Risk Atlas is designed to create a clear framework for compliant action in this regard.

DB is active at some 2,200 sites in more than 130 countries. DB Schenker Logistics, with its 15 subsidiaries alone, is present in 100 locations and is now the secondlargest transport and logistics service provider in the world. DB Arriva, which runs all of DB’s regional transport services outside of Germany, offers bus and rail transport in 12 European countries. DB International has successfully carried out several thousand projects for transport and infrastructure companies, governments, and financial institutions in 107 countries since 1966. Other business units have also long been operating beyond German borders. They include DB Sales, with offices in India and Australia, and DB Systemtechnik, whose employees are sought after as experts for rolling stock technology in China and Ukraine.

The world is green, yellow, orange, and red – with a few gray spaces in between. Or at least this is how it looks on the maps of Deutsche Bahn’s new Compliance Risk Atlas. The colors do not indicate political orientations or the average temperatures in countries around the world. Instead, they provide information on corruption, the role of economic crime in each country, and the status of human rights there. Red indicates an extremely high risk exposure; green a low one.

“The maps, which are accompanied by an individual report on each country, are based on statistical data collected by nine well-respected independent institutions,” says Werner Grebe, Chief Compliance Officer of DB. These institutions include Transparency International, the World Bank, Amnesty International, the United Nations, and the International Labour Organization. Deutsche Bahn collected the data, analyzed it, and compiled it in the DB Compliance Risk Atlas thereby reflecting its own risk-based approach to compliance work.

The Atlas covers corruption, economic crime, legal certainty, fair competition, regulatory environments, reliability of financial reporting and auditing, and human rights. The list of risks is accompanied by a depiction of countermeasures, which include adequate compliance regulations, training courses, and whistle-blowing management.

“From a compliance point of view, the DB Compliance Risk Atlas offers the Group a well-structured decision-making aid when it is considering whether to do business in a country,” Grebe says. “For instance, if a business unit receives a request for cooperation from a rail operator in a country in which the business unit is not yet present, it can use the Atlas to more quickly and precisely assess opportunities and risks.”

In concrete terms, that means that if there is a high level of corruption in the country or a considerable risk that contractual claims cannot be enforced, the corresponding color in the DB Compliance Risk Atlas will be red and the risks of engaging in business operations in this country must be thoroughly evaluated. In addition, the heads of the business units and service centers receive detailed analyses for their areas that are designed to assist them in their day-to-day business decisions. These detailed reports enable the managers in helping to make their employees aware of these risks and to ultimately protect them from potential dangers. “Our employees’ own prior experiences in the countries are incorporated here as well,” says Grebe. “In other words, if all the warning signs in regard to corruption in Country X are in ‘red,’ the
business unit awarding contracts there will meticulously examine all the bids submitted to make sure that everything is correct. And if Country Y does not offer a high degree of legal certainty, DB will be all the more careful to incorporate appropriate protective mechanisms in contracts there.”

The Compliance Risk Atlas provides DB Group management with a wellfounded decision-making basis for carrying out international business transactions in a legally certain manner. As a “dynamic product,” the Atlas is revised as needed and updated annually.

InitiatorDeutsche Bahn
Project start
Contact person
Nicole Knapp
Anti-Corruption X
Business & Peace -
Development -
Environment -
Financial Markets -
Implementing UNGC Principles in your Corporate CSR Management -
Human Rights -
Labour Standards -
Local Networks -
Advocacy of global issues X
Business opportunities in low income communities/countries -
Project funding -
Provision of goods -
Provision of services/personal -
Standards and guidelines development X

The goal of DB Compliance is to prevent the violation of rules both in Germany and abroad and to ensure that DB continues to be a fair and trustworthy business partner. The focus of the DB Group’s compliance work is to further develop business-oriented compliance risk analyses, customer-oriented information, targeted prevention, as well as Group-wide, risk-based compliance management with a preventative approach. The Chief Compliance Officer, who bears company-wide responsibility, is supported in this process by the corporate compliance team and locally established compliance coordinators and compliance managers worldwide, who rely on organizational tools such as compliance regulations and training courses. 

The DB Group offers employees, business partners, and customers various international channels for calling attention to the infringement of regulations. For example, the online “BKMS” tool (Business Keeper Monitoring System) offers anonymous web-based access for reporting infringements and is available in seven languages (German, English, French, Spanish, Italian, Polish, and Russian).

About the Authors
Deutsche Bahn

Deutsche Bahn AG was founded in 1994. Today, it is one of the world’s leading passenger and logistics companies and operates in 130 countries.
Every day about 290,000 employees are committed to providing mobility and logistics services for customers around the world, as well as controlling and operating the related transport networks in the rail, land, ocean, and air freight transport sectors. In the 2010 financial year, DB AG posted revenues of about 34.4 billion euros, as well as operating profits (EBIT) of 1.9 billion euros before special items.

The company’s railway activities in Germany – with about seven million passengers and 1,138,000 tons of freight transported every day – is its core business. Moreover, every day DB transports more than two million customers by bus. And every day DB AG operates over 26,000 train trips on its modern 33,000 kilometer long track network, which is also open to the competition. The main focal points of DB strategy, in addition to increasing its international activities, are linking together all modes of transport and building overlapping and comprehensive intermodal travel and logistics chains. This is how the company is meeting the changing challenges posed by the market, which is demanding increasingly efficient and environmentally friendly services from a single source. Deutsche Bahn AG is already providing answers to the determining trends of globalization, climate change, scarcity of resources, as well as deregulation.

Knapp, Nicole
The views expressed in this article are the author's own and do not necessarily reflect CSR Manager's editorial policy.
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