Skip Navigation

External Reviews: Transparency international

External Reviews

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

Does the company provide training on its anti-bribery and corruption programme to all employees across all divisions and geographies and in all appropriate languages?

Regular risk-based training is an integral part of our Compliance programme. We provide basic training on our anti-bribery and corruption programme to employees across different divisions and geographies 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 and business partners, responding to invitations and gifts as well as the prohibition of facilitation payments.

For verification, see our audited Annual Report in 17/18: “Our Compliance Officers trained and advised employees around the world on applicable statutory requirements, internal Group wide policies, and also looked at concrete individual cases. In the reporting year around 5,500 employees worldwide attended classroom courses, mainly on antitrust law and corruption prevention. In addition, we continued the fourth cycle of the eLearning programme on corruption prevention and antitrust law launched in November 2015. A total of more than 112,000 courses, net of disposals, were completed by the end of the fiscal year.”

Important related documents and links:
Annual Report 16/17
Annual Report 17/18

Does the company provide tailored training on its anti-bribery and corruption programme for at least the following categories of employees:
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 trainings and Compliance Principles Workshops which are especially aimed to create the adequate Compliance awareness with employees in high-risk positions, middle management as well as board members. The Compliance function also conducts so-called face-to-face Compliance onboarding interviews with employees in the above-mentioned categories who are specifically 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 eLearning Programme Guidelines, p. 8, 11:

Page 8:

eLearning Programme Guidelines, p. 8

Page 11:

eLearning Programme Guidelines, p. 11

Does the company measure and review the effectiveness of its anti-bribery and corruption communications and training programme?

Our Compliance function has its own "Projects, Reporting & 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 Board at least on a quarterly basis and are used to continuously update our programme.

We measure and review the effectiveness and continuous participation of our anti-bribery and corruption communications and training programme systematically, e.g. by staff surveys or workshops.

For example, at the end of each training course, an evaluation is carried out with the participants. Compliance is also part of a regular, Group wide employee survey. The Compliance Department achieved an outstanding result in the last Group wide employee survey in 2016, even improving vis-à-vis the already positive result of the 2014 survey, as shown in the graph below:

Favorable Score

Does the company ensure that its employee incentive schemes are designed in such a way that they promote ethical behavior and discourage corrupt practices?

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 planning process, which usually starts in November, is opened with a letter signed by the Chief Compliance Officer and the Head of the Strategy Department who point 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 individual stages of planning.

See an extract of the letter below:

Compliance in the Strategic Dialog

Does the company commit to and assure itself that it will support and protect employees who refuse to act unethically, even when it might result in a loss of business?

In its Compliance Commitment, the thyssenkrupp Management Board unmistakably states:

“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. The message of our Compliance Commitment was measured in the Employee Surveys by asking questions regarding Compliance and Integrity.

The message of our Compliance Commitment was measured in the Employee Surveys by asking:

Compliance & Integrity

Does the company have a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents?

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 corporate function 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 Corporate Function 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.

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:
Submitting a report

Does the company provide multiple whistleblowing and advice channels for use by all (e.g. employees and external parties), and do they allow for confidential and, wherever possible, anonymous reporting?

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
  • Telephone hotline (toll-free in 34 languages)
  • External lawyer of trust (Ombudsman)

Important related documents and links:
Submitting a report

To the top