As tiers of suppliers become more remote from the principal contractor, the opportunities for corruption become greater with less clarity over everything from conflicts of interest to beneficial ownership and financial transparency.
Supply Chain Management
Does the company require the involvement of its procurement department in the establishment of all new supplier relationships and in the oversight of its supplier base?
Acting responsibly is firmly integrated in our procurement processes. When awarding contracts, our decisions are not only based on economic, technological and process criteria. Sustainability also has a key role in our supplier management. Moreover, we continuously develop our processes. This also means, for example, that we want to further increase transparency regarding the origin of raw materials and so-called conflict minerals to detect risks as early as possible.
We at thyssenkrupp expect all suppliers to meet the highest expectations regarding sustainability, quality, pricing as well as contract and delivery performance. We expect our suppliers to sign our Supplier Code of Conduct before entering in business with thyssenkrupp unless the supplier can prove that he has at least a comparable level of policy and processes in place. This includes suppliers of goods as well as services, e.g. consultants. If the supplier refrains from signing our Supplier Code of Conduct for good reason we check the Code of Conduct of our supplier whether it meets our standards of doing proper business. If we are still in doubt, we ask our supplier to proof what they are doing to guarantee proper business. If we are not finally convinced, we stop doing business.
Does the company conduct a risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers?
Once engaged we review our suppliers’ Compliance with the principles and requirements laid out in the thyssenkrupp Supplier Code of Conduct regularly, asking our suppliers to complete a self-assessment. Furthermore, we reserve the right to consult with each supplier and to either perform a sustainability audit at the supplier’s site or to appoint a qualified third party to perform the audit thyssenkrupp receives a full report on the audit findings.
Any violation of the principles and requirements set out in this thyssenkrupp Supplier Code of Conduct will be regarded as a serious violation of the supplier regarding his contractual obligations towards thyssenkrupp. In the event that the supplier is suspected of violating any of the principles or requirements laid out in the thyssenkrupp Supplier Code of Conduct (e.g. based on negative media reports), thyssenkrupp reserves the right to request from the supplier that all relevant information be disclosed. In the event that a supplier evidently fails to fulfill any of the principles or requirements set out in this thyssenkrupp Supplier Code of Conduct, or refuses to pursue and implement measures for improving his sustainability performance, after having been given a reasonable period of grace, thyssenkrupp reserves the right to immediately terminate any or all contracts with the supplier for cause. Various risk analyses help our Group identify risks early. In addition, we ask our suppliers to provide comprehensive information on pertinent processes and management systems via self-assessments.
Acting responsibly is firmly integrated in our procurement processes. When awarding contracts, our decisions are not only based on economic, technological and process criteria. Sustainability is also playing a key role in our supplier management. Moreover, we continuously develop our processes. This also means, for example, that we want to further increase transparency regarding the origin of raw materials and so-called conflict minerals to detect risks early.
Does the company require all of its contracted suppliers to have adequate standard of anti-bribery and corruption policies and procedures in place?
thyssenkrupp requires all suppliers to have an adequate standard of anti-bribery and corruption policies and procedures in place, we oblige all strategic suppliers to accept our tk Supplier Code of Conduct that consists of such rules as:
The thyssenkrupp Supplier Code of Conduct outlines our understanding of sustainability and Compliance as well the standards to be met by our suppliers. Some of the key topics addressed are:
- Conduct towards employees
- Environmental protection
- Occupational health and safety
- Conduct in the business environment
- Supplier relations
As we are committed to treating employees, customers, suppliers and local residents responsibly and with fairness, we expect our suppliers to share this commitment with us. We expects from our suppliers that all their business activities fully comply with applicable national and international laws and regulations, with the principles of the United Nations Global Compact, and with the requirements and standards laid out in the thyssenkrupp Supplier Code of Conduct.
Does the company ensure that its suppliers require all their sub-contractors to have anti-corruption programmes in place that at a minimum adhere to the standards established by the main contractor?
We insist that all suppliers require all sub-contractors throughout the supply chain to have formal and publicly declared anti-bribery and corruption programs and standards in place by the obligatory signing of our tk Supplier Code of Conduct.
In the Suplier Code of Conduct we state the following
“Supplier relations At thyssenkrupp, we expect our suppliers to communicate the principles laid out herein to their subcontractors and subsuppliers and to take these principles into account when selecting subcontractors and subsuppliers. Our suppliers are expected to encourage their subcontractors and subsuppliers to comply with the minimum standards of this Code of Conduct regarding the protection of human rights, working conditions, anti-corruption and environmental protection when fulfilling their contractual obligations. Further we expect from our suppliers to only source material from legal sources and if requested to provide evidence on the legal source.”
Does the company publish high-level results from ethical incident investigations and disciplinary actions against suppliers?
If there are signs of infringements by customers or suppliers, we investigate every single case thoroughly. In case of proven violations of our policies or even legal violations, action is taken to remedy the violation immediately, such as individual reaction against suppliers (e.g. termination of contract, reorganization, increased Compliance efforts, phase out), request for damage compensation or filing a complaint to public authorities.