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
Does the company have a publicly stated anti-bribery and corruption commitment, which is authorised at the senior level?
In our daily Compliance business, it is one of the most important things to instill thyssenkrupp with a broad-based and established value culture in which reliability, honesty, credibility and integrity are the cornerstones of our actions. 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.
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-corruption and antitrust law.
Our Group Regulation Corruption Prevention defines the prohibition of corruption and bribery for all companies, employees, managers and executive board members of thyssenkrupp, the whole thyssenkrupp Group and third parties.
Does the company have a comprehensive anti-bribery and corruption policy that explicitly applies to both of the following:
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 consist of comprehensive anti-bribery and corruption policies, apply to all employees as well as the Members of the Board, regardless of their seniority.
Specific references to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments can be found in our Group Regulation Corruption Prevention.
Does the board or a dedicated board committee provide oversight of the company´s anti-bribery and corruption programme?
Corporate Governance has been systematically strengthened at thyssenkrupp in recent years. By creating a dedicated Executive Board department for Compliance and Legal (in charge since 2014), the Supervisory Board sent a clear signal both within the company and to the external world, that thyssenkrupp stands for fair and straight business. Our Chief Compliance Officer Dr. Sebastian Lochen, who is responsible for the operational implementation and further development of the Compliance programme, reports directly to the Executive Board member responsible for Legal & Compliance, Dr. Donatus Kaufmann. Mr. Kaufmann 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.
Is responsibility for implementing and managing the company´s anti-bribery and corruption programme ultimately assigned to a senior executive, and does he or she have a direct reporting line to the board or board committee providing oversight of the company´s programme?
Our Chief Compliance Officer, who is responsible for the operational implementation and further development of the Compliance programme, reports directly to the Executive Board member responsible for Legal & Compliance, Dr. Donatus Kaufmann. 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.