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ARTICLE · 15 JULY 2026

Part II Compliance Management Systems Set-Up Reporting And Decision-Making

Mayer Brown
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This comprehensive guide examines how German companies can design and operate a credible compliance management system that meets both domestic legal requirements and international standards. It explores the interplay between board-level organizational duties, specialized statutory regimes like the Whistleblower Protection Act and Supply Chain Due Diligence Act, and globally recognized frameworks such as ISO 37301, while providing practical guidance on governance structures, reporting lines, and implementati

GermanyCorporate/Commercial Law
Pauline Stadler
Pauline Stadler
Dr. Hagen Köckeritz
Dr. Hagen Köckeritz
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Part II of our Series sets out how to design and operate an effective compliance management system (CMS) that is both credible across jurisdictions and tailored to German corporate practice. The core message is clear: compliance should be organized on a risk-based, independent, and well-documented footing, aligned with recognized frameworks, and supported by structured reporting lines and clearly defined decision-making rights vis-à-vis management and the supervisory board.

In Germany, the baseline is formed by board-level duties to properly organize and monitor the enterprise, including the obligation to ensure early risk detection. These expectations are heightened for listed companies and complemented by the German Corporate Governance Code (Deutscher Corporate Governance Kodex – DCGK), which requires a transparent description of the internal control and risk management system, including the CMS, and an assessment of its adequacy and effectiveness.

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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