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Controls also need to be accessible and tailored to all employees, across all divisions and areas of operation. Training forms a central part of this support system promoting an understanding of bribery and improper business conduct in order to develop employees’ capacity to identify, avoid and resist corrupt approaches.
Support to Employees
Regular risk-based training, including elearning programmes as well as classroom and remote training formats, is an integral part of our Compliance programme. We provide basic training on our anti-bribery and corruption programme to employees across different segments and regions in all appropriate languages.
Our employees are informed about our Compliance requirements, potential risks, and possible sanctions. The requirements are based on the relevant laws as well as our Group wide policies. They also have the aim to implement international standards. They cover for example rules for dealing with competitors, business partners or sales agents, responding to invitations and gifts as well as the prohibition of facilitation payments.
For verification, see our Annual Report in 21/22, page 112: “Our compliance officers trained, informed and advised employees around the world on applicable statutory requirements and internal groupwide policies, classroom trainings and also advised on concrete individual cases. In the reporting period, more than 5,300 participants attended awareness-raising training sessions, many of which were held remotely as a result of the new forms of collaboration and in some cases because of the Covid pandemic. The training courses cover all the core topics in the thyssenkrupp compliance program. Furthermore, we have launched the fifth round of our compliance e-learning program on corruption prevention and antitrust law.”
Important related documents and links:
Annual Report 21/22 (page 112)
a) Employees in high-risk positions,
b) Middle management,
c) Board members
Regular risk-based training is an integral part of our Compliance programme. We provide continuously differentiated, target group oriented face-to-face classroom and remote trainings which are especially aimed to create the adequate Compliance awareness with employees in high-risk positions, middle management as well as board members. Our Regional and Business Compliance Officers also conduct so-called face-to-face Compliance onboarding interviews with employees in the above-mentioned categories who are particularly exposed to Compliance risks. On top of that, target-group specific trainings are developed for high-risk positions, e.g. a special eLearning course designed for employees in procurement positions.
Important related documents and links:
Compliance e-learning Program, Overview of e-learning courses and Catalog of mandatory participants, p. 2, 5:
Important related documents and links:
Our Compliance function has its own "Operations and Processes" Department, whose tasks include monitoring the effectiveness of our Compliance work by continuously measuring different KPIs such as participant and fulfillment rates. The results are reported to the thyssenkrupp Executive Board at least on a quarterly basis and are used to continuously update our programme.
Our Group wide incentives are calculated on both the achievements of financial targets as well as individual performance based targets. At management events, our Executive Board repeatedly addresses its clear claim that values and performance are two sides of the same coin.
Targets have to be realistic in order to set the right incentives. Unrealistic targets encourage employees to go illegal ways. Therefore, Compliance is an integral part of the strategic and operational planning process to ensure a Group-wide realistic target setting.
The yearly operational planning process is opened with a letter pointing out that it is crucial that all suppositions are based on realistically attainable goals. An appendix further contains an overview of the process of Compliance involvement and Compliance measures along the planning process.
See an extract of the appendix of the letter below:
Operational Planning 2022/23
Page 3:
In its Compliance Commitment, the Executive Board of thyssenkrupp AG unmistakably states:
“We would rather purposely forgo a business opportunity than act against the law”.
This underlines our commitment to fair competition in our Code of Conduct:
“For us, bribes and cartel agreements are not a means of winning business. thyssenkrupp stands for fair and straight business. We would rather sacrifice a contract than win it by breaking the rules.”
All employees are requested to cooperate actively in their areas of responsibility in implementing the thyssenkrupp Compliance programme.
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Bona fide reports help counteract violations at an early stage and limit the damage for our company, our employees and our business partners. We have therefore set up several channels for contacting us – anonymously if required – to report infringements.
This system for reporting information is open to all thyssenkrupp employees as well as third parties such as customers, suppliers and others.
thyssenkrupp and the Group Function Legal & Compliance safeguard the interests of the whistleblower not only through this secure Whistleblowing System, but also by providing assurances that all information received by the Group Function Legal & Compliance at thyssenkrupp AG will be treated in confidence, and that all means at our disposal will be used to protect whistleblowers acting in good faith from any disadvantages as a result of their disclosures. thyssenkrupp strictly prohibits and does not tolerate any kind of retaliation (e.g. adverse action, disciplinary measures, threats, intimidation) for reporting a violation in good faith or otherwise cooperating in an investigation of a violation.
During its investigations, thyssenkrupp will also strive to protect the legitimate interests of other persons affected by a disclosure. Casting suspicion on another person can have serious consequences for that person. It is essential that the Whistleblowing System is used responsibly.
Important related documents and links:
Bona fide reports help counteract violations at an early stage and limit the damage for our company, our employees and our business partners. We provide multiple whistleblowing and advice channels – most importantly our internet-based Whistleblowing System - for use by employees as well as external parties, which allow for confidential and anonymous reporting:
Potential channels for advice and whistleblowing:
- Compliance Officers or Compliance Manager
- Supervisor
- Internet-based Whistleblowing System (worldwide available in 34 languages)
Important related documents and links: