Das Konstanz Institut für Corporate Governance

    Anti-corruption compliance and integrity management in high-risk countries

    Challenges, solutions and management instruments for medium-sized companies in the D-A-CH region

    Aim of the research work

    The research project aims to support in particular large medium-sized companies and SMEs from Germany, Austria and Switzerland in their internationalisation projects in growth countries by analysing the challenges of compliance with rules and ethical behaviour in high-risk regions and developing directly application-oriented solution strategies and management instruments (development of an integrity toolkit).

    One focus of the research work is on the topic of "Corruption Prevention".

    Project Manager

    Prof. Dr. Stephan Grüninger

    Project Collaborators

    Anna Zubrod

    Quirin Kissmehl

    Project duration

    1. Mai 2019 – 30. April 2021

    Project Sponsor

    KBA-NotaSys Integrity Fund

    Forum Compliance Mittelstand (FCM)

    In the period 2016-2019, the CBCI, which is based at KICG, coordinated the Forum Compliance Mittelstand (FCM)

    Self-conception of the FCM

    The Forum Compliance Mittelstand (FCM) is designed as a voluntary association of medium-sized companies and associations and serves to promote and disseminate value-based management in medium-sized companies. For this purpose, the FCM deals thematically with methods of compliance management for medium-sized companies. The objective of the FCM is to facilitate a mutual transfer of knowledge between research and practice within a network. Furthermore, the FCM serves a continuous exchange of experience between the partners involved and enables mutual consultation on current questions and challenges concerning compliance.

    The forum was founded from the merger of companies that participated in the so-called "Praxisdialog - Compliance im Mittelstand" in 2016. The Forum Compliance Mittelstand is currently still open to interested companies.

    Thematic orientation

    Topics of the implementation of an effective compliance management and monitoring in small and medium-sized businesses are dealt with. The starting point is the high importance, but still low prevalence of compliance in small and medium-sized companies.

    The FCM takes the specifics of the SME sector as a starting point and opportunity to develop practical solutions, concepts and methods for SMEs and to contribute to their dissemination. The work of the FCM takes place at the interface between business and ethics, as well as in the exchange between research and practice.

    The FCM plans to organize two events a year for members, at which current topics and challenges will be discussed in lectures and discussion groups. Furthermore, this is intended to contribute to networking and exchange among members.

    The FCM also aims to carry out research projects in the field of compliance management for medium-sized companies and thus to actively contribute to the exchange between science and practice.


    Membership in the Forum Compliance Mittelstand is possible in the form of a corporate membership. In the long term, a number of approximately twenty corporate members is planned. The aim is to establish the FCM as a manageable group of experts, in which confidential discussions are guaranteed for participants. The number of members should therefore remain limited.Scientific Director of the FCM

    Prof. Dr. Stephan Grüninger

    Coordination of the FCM

    Quirin Kissmehl

    Anna Zubrod

    Further information on the current activities of the Forum Compliance Mittelstand (FCM) can be found on the homepage of the Zentrum für Wirtschaftsethik e.V. (ZfW).

    Research Compliance & Integrity (FCI)

    Until 31 December 2019, the KICG coordinated the research work in the Compliance & Integrity Forum (FCI).

    Self-conception and activities of the FCI

    The Compliance & Integrity Forum serves to discuss and exchange experiences on current issues of modern and sustainable effective integrity and compliance management. The competence of the forum lies in the close connection and dialogue between science and practice. The members meet twice a year for a joint one-day meeting and additionally in three professionally oriented working groups.

    Issues discussed include the implementation of adequate compliance systems, monitoring and the interplay between compliance management and integrity management. With regard to good corporate governance, a comprehensive, value-based understanding of compliance is assumed. Also against the background of global challenges as well as international and global standards, questions of the development and effectiveness of compliance management systems are intensively discussed.

    About the history of the FCI

    In 1999 Prof. Josef Wieland, Director of the Centre for Business Ethics, founded the User Council for Value ManagementZfW. The council was dedicated to the development, introduction and implementation of the value management system according to the certified standard of the ZfW. The practical competence of the User Council ensured that the ValuesManagementSystemZfW was application-oriented right from the start, and the promotion, further development and quality assurance of the ValuesManagementSystemZfW were among the central tasks of the User Council.

    Increasingly, compliance and integrity became focal points of its content orientation.
    In 2009, the ComplianceProgramMonitorZfW guideline and the statement "Recognition of third-party codes of conduct" were developed and published.

    In 2011, the User Council therefore created a more catchy title for the working group and decided to change its name to Forum Compliance & Integrity - Anwenderrat für WertemanagementZfW (FCI).

    In 2014, under the direction of Prof. Dr. Stephan Grüninger and with the participation of many companies represented in the FCI, a research project was completed that concretizes generally accepted elements of compliance management systems (CMS) and applies them to different sizes of companies (companies of different levels of compliance complexity). Among other things, guidelines for four types of companies have been developed, a guidance document that deals with the necessity and permissibility of the different implementation of CMS measures, and a document on the possible specific requirements and risk drivers for the design of CMS in certain companies (capital market orientation, degree of internationalisation, industry affiliation, etc.). The documents can be obtained here.

    In May 2016, the auditing firm EY and the Forum Compliance & Integrity published the "Existing Practice in Compliance 2016 Survey". This provides a comprehensive comparative study regarding the status and trends in integrity and compliance management systems. The basis for this was a standardized survey of a selected group of participants with already sound experience in the implementation of a compliance management system (CMS). The study can be downloaded here.

    One result of the joint work in the FCI working groups is the practice-oriented FCI handbook "Corporate Integrity & Compliance - What really matters", which was published in October 2016.Scientific Director of the FCI

    Prof. Dr. Stephan Grüninger

    Coordination of the FCI

    Anna Zubrod

    Quirin Kissmehl

    Further information on the current activities of the Compliance Integrity Forum can be found on the homepage of the Zentrum für Wirtschaftsethik e.V. (ZfW).

    Project "Transparent Corporate Culture" (Deutsche Telekom)

    Breaches of laws and regulations in companies endanger reputation and business success - this has been demonstrated by various cases at Dax companies in recent years. Deutsche Telekom has therefore set itself the goal of strengthening integrity and the culture of contradiction within the company.

    A triad of scientific studies, experts and employee opinions was to be used to objectively analyze the corporate culture and to identify and raise awareness of possible causes of unethical pro-organizational behavior. The project aimed to address these causes and strengthen the basis of a value-oriented and compliance-conscious corporate culture.

    To this end, the European School of Management and Technology (ESMT) and the Hertie School of Governance were commissioned to carry out an international scientific study of corporate culture. The study was accompanied by an independent group of experts, of which Prof. Stephan Grüninger was co-chair. Further participants of the group were:

    • Manuela Mackert, Chief Compliance Officer, Deutsche Telekom (Co-Chairwoman)
    • Monika Brandl, Chairwoman of the Central Works Council Deutsche Telekom AG
    • Muel Kaptein, Professor of Business Ethics and Integrity Management, Erasmus University Rotterdam
    • Birgit Klesper, Head of Group Transformational Change & Corporate Responsibility, Deutsche Telekom
    • Klaus M. Leisinger, Chairman of the Global Values Alliance Foundation, Basel
    • Noor Naqschbandi, prevention of corruption, UN Global Compact, German Network
    • Sylvia Schenk, Transparency International Germany
    • Rita Süssmuth, former President of the Bundestag and Federal Minister
    • Matteo Tonello, Managing Director, The Conference Board, New York

    "Deutsche Telekom gets naked" - on the interview with Prof. Dr. Stephan Grüninger. 


    Guidelines for the Management of Organizational and Supervisory Duties

    KICG works out recommended actions for the design and assessment of management systems.

    The KICG worked on the research project “Guidelines for the Management by Organizational and Supervisory Duties”, sponsored by the Federal Ministry for Education and Research from November 1, 2011 to December 31, 2013.

    Project Goal
    The goal of the interdisciplinary research project was to identify the requirements for fulfilling the essential organizational duties (organizational and supervisory duties) in the management and supervision of companies to identify the principles of the management measures required for this purpose and to compile the derived "Guidelines for Assessing Organizational and Supervisory Duties" for companies with different compliance complexity levels. A total of six documents resulted from the project, all of which can be downloaded at the project website Compliance Obligations.

    Project Head
    Prof. Dr. Stephan Grüninger
    RAuN Dr. Roland Steinmeyer
    Prof. Dr. habil. Josef Wieland

    Staff Members
    RA Maximilian Jantz
    Dr. Christine Butscher, maiden name: Schweikert

    Project Time Frame
    1. November 2011 - 31. December 2013

    Federal Ministry for Education and Research (BMBF)
    Sponsor ID: 17044X11

    Compliance communication in German companies

    60 Chief Compliance Officers were surveyed by Prof. Stephan Grüninger and the Communication Agency, Martin et Karczinski.

    The Konstanz Institute for Corporate Governance published a study on the topic of compliance in collaboration with Martin et Karczinski, the Munich agency for Corporate Identity und Corporate Design. Based on a thorough analysis, the publication, entitled “Communication Potential in German Company’s Compliance Systems”, provides answers to how even large companies can gain credibility externally and persuasiveness internally by dealing with compliance issues. Chief compliance Officers and Compliance Officers from 64 companies, most of which are listed on the stock exchange, are quoted in the article.
    In the face of ongoing scandals and the associated loss of image and trust, integrity management is an important key for managing the future. The 144 page article on ›Communication Potential‹ with remarks from compliance officers at Adidas, Siemens and German Telekom is as exciting as a detective novel. The authors were able to isolate the success factors for functioning compliance. These include high-quality training programs, attended by members of upper management as well as staff members in sensitive positions. The second success factor is the attribution of compliance to the line responsibility of managers ('tone from the top'). The third success factor is the core of any functioning compliance system: communication. Dr. Stephan Grüninger from the Konstanz Institute for Corporate Governance summarizes it thus: “Integrity management only works in the interaction between different communication tools and channels.” The study shows that compliance is communicated via the brand and has the potential to promote the identification of employees in companies,” adds Daniel Karczinski (Martin et Karczinski). “This result supports our regular compliance work, for example with AUDI”.

    The study „Communication in Compliance Systems in German Companies” is available now. Please send an email to or The price is Euro 38.90 Euro plus VAT.

    Compliance management in medium-sized companies

    The Center for Business Compliance & Integrity (CBCI) examines the current status of medium-sized companies with regard to compliance in its study "Compliance in medium-sized companies". It is determined in which respect the topic of compliance is relevant for medium-sized companies and in which direction it will develop in the future. In addition, the areas in which the implementation of compliance is particularly challenging are identified, as well as approaches and measures with which these challenges can be met.

    For this purpose, both a quantitative survey by means of an online questionnaire and a qualitative survey by means of telephone interviews with representatives of medium-sized companies were conducted. In addition, an evaluation of other studies in this field was carried out in order to establish - if possible - a comparability of the respective results.

    The result shows that there are a number of topics in the area of compliance that are relevant for medium-sized companies. For almost all companies, the first issue is compliance with legal requirements and internal standards of conduct and guidelines. However, it is remarkable that for every third company surveyed, knowledge of the relevant compliance regulations and knowledge of the requirements for a compliance management system is a major problem. In addition to the classic goal of compliance work, the prevention of bribery and corruptibility, for 65 % of those surveyed, labor and social standards are also important compliance issues. An increasing focus on topics beyond mere "legal compliance", i.e. adherence to the law, also shows the great importance of the values and corporate culture, which is part of compliance work for 78 % of those surveyed. There are many instruments for implementing compliance that were rated as very useful by those surveyed (including training courses and the discussion of specific cases). Nevertheless, these are often not implemented in many of the companies. The results show that the topic of compliance is no longer unknown to small and medium-sized companies, but that it does, in part, present challenges that have yet to be overcome. Since the study is also intended to address companies that are less familiar with compliance, the interview partners will conclude by making recommendations regarding the first steps in dealing with compliance in their own companies.

    The study results can be downloaded in PDF format.

    Prof. Dr. Stephan Grüninger presented the study "Compliance in medium-sized businesses" in a web seminar of the cooperation partner COMFORMIS. The recording of the webinar is available as video. Project manager
    Prof. Dr. habil. Josef Wieland


    Prof. Dr. Stephan Grüninger

    Project Collaborators
    Andreas Heck


    Dr. Christine Butscher

    Project duration 1 January 2010 to 31 December 2011

    Ministry of Science, Research and Art Baden-Württemberg