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Leadership does not just rest with the CEO middle management bear the principal burden in terms of setting the tone and culture of the organisation for frontline staff. Effective and ethical supervision at every level of a company is crucial if staff are to have the confidence and support to make ethical decisions, even if it affects the company’s bottom line.
Leadership and Organisational Culture
In our daily Compliance business, it is one of the most important things to instill a broad-based value culture in which reliability, honesty, credibility and integrity are the cornerstones of our actions within thyssenkrupp. This value culture must be jointly supported and actively lived by all employees – and in particular by our managers. A written code of values is a key component of such a value culture. At thyssenkrupp, our value culture is embedded in our Group mission statement which unequivocally states that Compliance is a must. Our mission statement is also the foundation for our Code of Conduct.
Through our Compliance Commitment, the Executive Board takes a firm stance rejecting Compliance violations of all kinds, specifically targeting anti-bribery and anti-corruption. This unequivocal commitment is supported by our Code of Conduct and various Group policies, in particular in the areas of anti-bribery and anti-corruption.
Our Group Regulation Corruption Prevention prohibits corruption and bribery for all companies, employees, managers and executive board members of thyssenkrupp, the whole thyssenkrupp Group and third parties. The Group Regulation Compliance in dealings with Business Partners defines requirements, including an identity and compliance check of the Business Partner as well as a corresponding Due Diligence check for the engagement of certain business partners.
Important related documents and links:
Group Regulation Compliance in dealings with Business Partners
a) All employees, including staff and leadership of subsidiaries and other controlled entities,
b) All board members, including non-executive directors
Our written codes, which include comprehensive anti-bribery and corruption policies, apply to all employees and managers as well as board members and directors, regardless of their seniority.
Specific references to the prohibition of bribery and corruption, payments to public officials, commercial bribery (gifts, invitations and delegation trips) and facilitation payments can be found in our Group Regulation Corruption Prevention.
Important related documents and links:
Group Regulation Compliance in dealings with Business Partners
Our Chief Compliance Officer Dr. Sebastian Lochen, who is responsible for the operational implementation and further development of the Compliance programme, reports to the Executive Board member responsible for Legal & Compliance, Oliver Burkhard. Mr. Burkhard oversees the whole Compliance programme and therefore the company´s anti-bribery and corruption programme. He reports regularly to the Supervisory Board and Audit Committee on all relevant Compliance and ethical issues.
In their described capacity, the Executive Board as a whole and more specifically the Executive Board member responsible for Legal & Compliance as well as the Supervisory Board and its Audit Committee also review the results of internal and external audits as well as the measures taken at least on a quarterly basis. As an example, we provide the Quarterly Compliance Report (for secrecy reasons we only show the agenda, audit results are covered by the section “Identify”):
Important related documents and links:
Our Chief Compliance Officer, who is responsible for the operational implementation and further development of the Compliance programme, reports to the Executive Board member responsible for Legal & Compliance, Oliver Burkhard. There is regular reporting on Compliance topics at every Board meeting, at quarterly intervals also with a specific Compliance report. These quarterly reports give detailed insight into Compliance activities, cases etc. and are formally acknowledged by the Board. The Chief Compliance Officer – depending on the topics – participates in Board Meetings as well as Audit Committee Meetings of the Supervisory Board.
On group company level, Compliance Managers, generally the group company’s Chief Financial Officers, are responsible for implementing the thyssenkrupp Compliance programme, inter alia on anti-bribery and anti-corruption.
Important related documents and links: