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41HERAEUS | FINANCIAL REPORT 2014 | GROUP MANAGEMENT REPORT The Heraeus Compliance Officer reports to the CEO. In this capacity, the Heraeus Compliance Officer compiles the reports from the compliance officers of the individual business groups, who in turn receive reports from the compliance officers of the subsidiaries, highlights signifi- cant individual events, and reports about ongoing progress with the compliance management system. Furthermore, the Heraeus Compliance Officer shares information on compli- ance matters with the compliance officers of the different business groups on a regular basis. Group Internal Audit does not just obtain information related to compliance risks from the Compliance Board. It also includes explicitly compliance-relevant issues in its auditing catalog and reports on its findings to Group management and to the Heraeus Compliance Officer. Using systematic risk analysis, the head of Group Internal Audit and the Heraeus Compliance Officer together select the companies where compliance audits are to be con- ducted. If it is necessary to conduct an internal investiga- tion because a significant compliance violation is sus- pected, the procedure for internal investigations sets out the relevant responsibilities. Since 2009 the Group companies have completed an annual compliance questionnaire on the introduction and implementation of compliance guidelines. The completed compliance questionnaires are available to Group Internal Audit as the starting point for compliance audits. Based on all these findings, Group management informs the Supervisory Board’s Audit Committee about devel- opments and progress in the compliance management system, as well as important individual events.

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