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External Reviews: Transparency international

External Reviews

Conflicts of interest are a major risk in defence, where a small number of companies compete for high value, opaque and relatively infrequent contracts with a small number of customers.

Conflict of Interest

Does the company have a policy defining conflicts of interest – actual, potential and perceived - that applies to all employees and board members?

At thyssenkrupp, business decisions are made exclusively in the best interests of the Company. Any conflicts of interest with personal matters or other business or non-business activities, including those of relatives or other related parties should be avoided. Should such conflicts nevertheless occur, they must be resolved in accordance with the law and Group policies. Conflicts must be dealt with openly and transparently.

Our Group Regulation Corruption Prevention provides detailed explanations concerning “Conflicts of interest”, which applies to all employees and board members:

Conflicts of interest may arise from any personal interests, which may exist in connection or conflict with the performance of the work for thyssenkrupp, e.g.:

  • Personal relation to or any other close relationship with business partners of thyssenkrupp in cases in which the employee places orders, gives approvals or the like with respect to such business partners.
  • Secondary employment at other companies or self-employment that infringes on the interest of thyssenkrupp.
  • Share ownership in competitors or business partners of thyssenkrupp that enables the exertion of business influence.
  • Placing of private orders for products and services with distributors, suppliers or clients of thyssenkrupp, especially if the employee exercises or is capable of exercising a direct or indirect influence on the business relationship of the respective business partner with thyssenkrupp.
  • The hiring of persons related to employees of thyssenkrupp if the respective thyssenkrupp employee is able to influence the hiring decision.
  • Direct reporting lines between thyssenkrupp employees being closely related to each other.

Employees must therefore declare any conflicts of interest to their superiors and the responsible Compliance Officer or Regional Compliance Officer in writing.

Without the prior written approval of their superiors, employees who are related to or maintain any other close relationship with business partners are not entitled to place orders, give approvals or the like to such business partners.

In cases where a conflict of interest may arise, employees of thyssenkrupp may only place private orders for products and services with distributors, suppliers or clients if the market price is paid and the payment is documented.

In the reporting year, there were no consulting or other service agreements between Supervisory Board members and the Company. Information on conflicts of interest and how they were dealt with is provided in the section “Report by the Supervisory Board”. Details of the other directorships held by Executive Board and Supervisory Board members on statutory supervisory boards or comparable German and non-German control bodies of business enterprises are provided in the sections of the same name under “Additional information”. Details of related party transactions are given in Note 22 to the consolidated financial statements.

Important related documents and links:
Group Regulation Corruption Prevention
Avoiding conflicts of interest

Are there procedures in place to identify, declare and manage conflicts of interest, which are overseen by a body or individual ultimately accountable for the appropriate management and handling of conflict of interest cases?

Our Group Regulation Corruption Prevention states that employees must declare any conflicts of interest to their superiors and the responsible Compliance Officer or Regional Compliance Officer in writing.

Without the prior written approval of their superiors, employees who are related to or maintain any other close relationship with business partners are not entitled to place orders, give approvals or the like to such business partners.

In cases where a conflict of interest may arise, employees of thyssenkupp may only place private orders for products and services with distributors, suppliers or clients if the market price is paid and the payment is documented.

Important related documents and links:
see 3.2 Group Regulation Corruption Prevention

Does the company have a policy and procedure regulating the appointment of directors,employees or consultants from the public sector?

The Business Unit Marine Systems does not employ serving politicitans as directors, employees or consultants. In order to reduce legal risks, potential conflicts of interest and to avoid reputational damage, thyssenkrupp Marine Systems has a specific policy, “Employment of public officials”, in place that defines the process regarding the employment of public officials and former public officials. The policy distinguishes between different risk groups and includes scenarios for potential conflicts of interest. These risk groups reflect inter alia the (former) public sector position of the applicant, and the time passed since the applicant left this position.

The policy foresees the mandatory alignment with the Compliance function. It further provides that where a potential conflict of interest has been identified, the authority for which the official has worked/is working shall be informed before hiring the (former) public official.

If former public officials for whom potential conflicts of interest have been identified are subsequently hired a conflict of interest review takes place potentially resulting in the imposition of clear restrictions on their functional responsibility.

Important related documents and links:
BU MS Regulation Anstellung von Amtsträgern

BU MS Regulation
Amtsträger

Does the company report details of the contracted services of serving politicians to the company?

In the BU Marine Systems we do not contract serving politicians.

In our Code of Conduct we state:

“We regard ourselves as an active corporate citizen and demonstrate our commitment in a variety of ways. Donations and other forms of corporate citizenship are carried out solely in the interests of the company. We make no financial contributions, in particular donations or sponsorships, to political parties in our home country or abroad, organizations related or similar to parties, individual office incumbents or candidates for political offices.

Political lobbying

Our political lobbying is centralized, open and transparent. We comply with the legal requirements on lobbying and avoid at all costs unfairly influencing government policy and legislation. We have voluntarily joined the European Union Transparency Register and comply with the European Union Code of Conduct.”

Important related documents and links:

-> tk Code of Conduct

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