Date Name Function Type and place of transaction Number of shares1 Price Total volume
(rounded)
Aug 16, 2006 Susan J. Unger Senior Officer Acquisition of shares by exercise 25,000 €34.40 €860,000
of options, off-market
Aug 16, 2006 Susan J. Unger Senior Officer Sale of new shares, Frankfurt 25,000 €40.78 €1,019,500
Oct 26, 2006 Günter Egle Senior Officer Acquisition of shares by exercise 15,000 €34.40 €516,000
of options, off-market
Oct 26, 2006 Günter Egle Senior Officer Sale of new shares, Frankfurt 15,000 €43.42 €651,300
Nov 2, 2006 Christine K. Cortez Senior Officer Acquisition of shares by exercise 22,500 €43.57 €980,325
of options, off-market
Nov 2, 2006 Christine K. Cortez Senior Officer Sale of new shares, Frankfurt 22,500 €45.65 €1,027,125
Nov 2, 2006 Trevor M. Creed Senior Officer Acquisition of shares by exercise 50,000 €34.40 €1,720,000
of options, off-market
Nov 2, 2006 Trevor M. Creed Senior Officer Sale of new shares, Frankfurt 50,000 €45.24 €2,262,000
Nov 3, 2006 Hubertus Troska Senior Officer Acquisition of shares by exercise 5,000 €43.57 €217,850
of options, off-market
Nov 3, 2006 Hubertus Troska Senior Officer Sale of new shares, Frankfurt 5,000 €45.50 €227,500
Nov 10, 2006 Hubertus Troska Senior Officer Acquisition of shares by exercise 1,000 €43.57 €43,570
of options, off-market
Nov 14, 2006 Prof. Peter Pfeiffer Senior Officer Acquisition of shares by exercise 25,000 €34.40 €860,000
of options, off-market
Nov 14, 2006 Prof. Peter Pfeiffer Senior Officer Sale of new shares, Frankfurt 25,000 €46.38 €1,159,500
Nov 16, 2006 Susan J. Unger Senior Officer Acquisition of shares by exercise 25,000 €43.57 €1,089,250
of options, off-market
Nov 16, 2006 Susan J. Unger Senior Officer Sale of new shares, Frankfurt 25,000 €48.27 €1,206,750
Nov 17, 2006 Günter Egle Senior Officer Acquisition of shares by exercise 15,000 €43.57 €653,550
of options, off-market
Nov 17, 2006 Günter Egle Senior Officer Sale of new shares, Frankfurt 15,000 €48.25 €723,750
Nov 30, 2006 Robert G. Liberatore Senior Officer Acquisition of shares by exercise 50,000 €34.40 €1,720,000
of options, off-market
Nov 30, 2006 Robert G. Liberatore Senior Officer Sale of new shares, Frankfurt 50,000 €44.97 €2,248,500
Dec 5, 2006 W. Frank Fountain Jr. Senior Officer Acquisition of shares by exercise 22,500 €43.57 €980,325
of options, off-market
Dec 5, 2006 W. Frank Fountain Jr. Senior Officer Sale of new shares, Frankfurt 22,500 €44.37 €998,325
Dec 6, 2006 W. Frank Fountain Jr. Senior Officer Acquisition of shares by exercise 35,000 €34.40 €1,204,000
of options, off-market
Dec 6, 2006 W. Frank Fountain Jr. Senior Officer Sale of new shares, Frankfurt 35,000 €44.37 €1,552,950
1 The information pertains to no-par-value registered shares of DaimlerChrysler AG with a pro-rata amount of €2.60 of the capital stock.
Compliance at DaimlerChrysler
Compliance is firmly anchored at DaimlerChrysler. By the term
compliance, we understand the conformity of DaimlerChrysler’s activities with applicable laws and regulations, as well as with the ethical and moral principles that the DaimlerChrysler Group is guided by or to which we have voluntarily committed ourselves. We already formulated the DaimlerChrysler Integrity Code in 1999. This comprehensive Integrity Code was expanded in 2003 with the Principles of Social Responsibility, and was supplemented with the Code of Ethics. The Code of Ethics is oriented towards the Board of Management as well as persons with special responsibility for the contents of financial disclosure, and can be seen at www.daimlerchrysler.com/corpgov_e.
Our goal is to institutionalize all activities that aim to safeguard this compliance. In addition, the issue of compliance is to be firmly anchored at DaimlerChrysler as an important pillar of our entrepreneurial actions.
Integrity Code put into more concrete form. In the year 2006,
the Integrity Code was supplemented by specific Corporate Policies & Guidelines, which transfer the principles of the Integrity Code with ethical or compliance relevance into concrete guidelines for behavior. The new Corporate Policies & Guidelines are intended to prevent corruption, to protect Group property, to more clearly regulate our approach to donations, to ensure the selection of responsible business partners, and to avoid conflicts of interest.
An “Anti-Bribery Handbook” has been prepared to support the implementation of the new Corporate Policies & Guidelines. It supplements the Policies and Guidelines and puts them into a concrete form with background information, examples and illustrative questions and answers. These documents and additional information on the issue of compliance and its organization are available on the Group’s intranet.
Starting out from our corporate values – Passion, Respect, Integrity and Discipline – the Integrity Code gives details of the key compliance elements that apply to all of our employees. This hierarchical approach is intended to ensure the consistency of all behavioral standards. An overview of the system of regulations is shown in the chart on page 119.
The organization of compliance at DaimlerChrysler. In order to
ensure compliance with all applicable laws as well as with the relevant principles that we have voluntarily accepted, we already started to set up a worldwide compliance organization at the end of 2005. We established the Compliance Committee as a direct representative of the Board of Management on all compliance issues. It is composed of high-ranking and experienced executives from the departments Legal, Corporate Audit, Finance & Controlling, Sales, Procurement and Supply, and Human Resources, and generally meets every six weeks.
The Compliance Committee approves and controls the imple- mentation and execution of our Ethics & Compliance Program. It monitors and secures the integration of compliance aspects in the Group’s business and personnel processes. In addition, the Compliance Committee approves all of the Group’s guidelines. Also at the beginning of 2006, we created the new department Corporate Compliance Operations (CCO). This department has the tasks of developing the Group-wide compliance organization, coordinating the implementation of the measures decided upon by the Compliance Committee, and ensuring that the relevant guidelines are adhered to. In this function, the head of CCO, who
Another element of our compliance structure is an external advisor who, since September 2006, supports our Supervisory Board, Audit Committee and Board of Management in connection with all compliance issues. The advisor’s focus is on the sustained implementation of our Compliance Program.
In addition, in various sales companies and in other operating units of the DaimlerChrysler AG, we installed specific internal con- trols in order to prevent corruption. These units were provided with intensive support to implement these controls. The mecha- nisms installed serve to fulfill the provisions of German law, the US Foreign Corrupt Practices Act (FCPA) and all relevant local regulations.
The selection of the units was based on an internal risk analysis as well as Transparency International’s annual ranking of countries that are particularly susceptible to corruption. We also appointed local compliance managers in the afore- mentioned sales companies and business units. Their main task is to support management in the respective locations with the fulfillment and achievement of all the Group’s compliance standards. In addition, they are to submit regular status and progress reports to Corporate Compliance Operations. Their independence of the local management is secured due to their close organizational links to the CCO department. In 2007, the experience gained is to be used to
support additional subsidiaries with the implementation of DaimlerChrysler’s compliance approach.
Expansion of compliance advice. A Sales Practices Hotline
was already established in November 2005, in order to support correct business-transaction processes at the Group. All of the Group’s employees can turn to the Hotline with questions on the application of external and internal regulations, and can obtain advice and guidance on concrete issues. The Sales Practices Hotline processed approximately 4,000 inquiries in 2006. In addition, the Business Practices Offices are available in Stuttgart and Auburn Hills to receive, document and process complaints and information on suspected infringements. This facility allows our employees to report any questionable accounting and auditing issues, likewise anonymously.
Execution of detailed training program. In the year 2006,
more than 5,600 employees worldwide were trained in a one-day course on compliance-relevant topics. In addition, compliance conferences were held in Singapore, Tokyo, Stuttgart, Mexico and Beijing, attended by more than 600 executives.
We will continue these conferences in 2007. The one-day compliance courses will be supplemented by e-learning modules, enabling us to expand the scope of the training courses. Furthermore, the compliance contents will become an integral part of the management training and specialist training carried out at the DaimlerChrysler Group.
Corporate Guidelines Corporate Policies Integrity Code Code of Ethics Local Guidance Corporate Values Anti-Bribery Handbook DaimlerChrysler standards of business conduct