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Compliance program
In its mission statement, code of conduct and compliance commitment, thyssenkrupp has given a clear commitment that it will comply with internal and external laws and regulations. This obligation applies to all companies, managers and employees.
Specific areas of risk are covered by the compliance program, for which the Legal & Compliance group function is responsible. This is based on three elements: “inform and advise”, “identify” and “report and act”.
This program is closely interlinked with risk management and with our internal control system. In this way we ensure that compliance is an integral component of every single business process. The key areas of the program are anticorruption, antitrust law, data compliance, anti-money laundering, and trade compliance.
In addition, the Compliance function acts as groupwide advisor, coordinator and consolidator to the organizational units that are directly responsible for the so-called further compliance topics such as occupational safety, use of contractors, equal treatment, information security, supplier compliance and environmental protection. Substantive responsibility in these areas remains with the competent corporate group functions or the relevant segment. This ensures that in all areas of the company compliance is understood in accordance with the thyssenkrupp mission statement, an intensive exchange of knowledge takes place between the Compliance function and those responsible for content, and the resultant synergies in organization, processes and methods are utilized. It also means that the Compliance function works with the responsible contact persons in the functions to adapt the reporting system and responsibilities for the respective topics.
The three pillars of our compliance program
Our compliance officers trained, informed and advised employees around the world on applicable statutory requirements and internal groupwide policies and also advised on concrete individual cases. In the reporting period, more than 5,000 participants received awareness-raising training, partly at face-to-face sessions and partly in remote formats reflecting the new forms of collaboration. The training courses cover all the core topics in the thyssenkrupp compliance program. We are currently running the fifth round of our compliance e-learning program on corruption prevention and antitrust law. By the end of the past fiscal year, after adjustment for employees leaving the company, more than 23,200 courses (including e-learning formats) had been completed on compliance in procurement and on data protection. The Compliance@thyssenkrupp e-learning course covers basic information on compliance at thyssenkrupp and is sent to all employees who have an email address. Unlike the other courses mentioned here, participation is voluntary. More than 7,100 employees completed the module in the fiscal year.
In the reporting year our compliance officers once again conducted proactive and event-driven compliance audits and investigations on the core topics. The aim of these is to regularly examine critical business operations based on a risk-oriented, structured audit process. Key elements in the identification of compliance risks are the whistleblower system and direct contact to supervisors or the Compliance function which provide employees and external persons with channels for reporting possible violations of laws or policies and regulations. A central hotline and a central email address are available for this. Whistleblowers can choose to report potential violations of laws or regulations without disclosing their identity.
As well as regular reports to the Supervisory Board and Audit Committee, our intensive compliance reporting covers all levels of our group: the Executive Board of thyssenkrupp AG, the segment boards, management of group companies, those responsible in the regions and project managers with market responsibility. In the event of proven violations, our “zero tolerance” policy applies: where necessary, sanctions are systematically imposed on those concerned.