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

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.

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.