Compliance organization

The Chief Compliance Officer, Dr. Sebastian Lochen, reports to the Group General Counsel who reports directly to the Executive Board member of thyssenkrupp AG responsible for Legal & Compliance, Oliver Burkhard.

Alongside more than 75 full-time Compliance staff members there are over 350 Compliance Managers worldwide. These are top executives of the individual Group companies (generally the CFO or Managing Director) who as part of the top leadership level are responsible for ensuring the right tone from the top. They represent compliance in the company and are our spokespeople in the operating units worldwide. And of course they work closely together with the Compliance Officers, who disseminate our key messages and support the compliance managers by acting as strategic business partners and providing a “helping hand.”

The Compliance Officers and Regional Compliance Officers advise, inform, and educate employees around the world about the relevant laws and internal policies. They have access to a network of over 350 Compliance Managers, (generally) managing directors of Group companies, who ensure the compliance program is implemented at operating level in their areas of responsibility.

Our activities: Cross-cutting within the business areas and in the regions

At thyssenkrupp AG four compliance departments have been installed:

• The Department Awareness & Prevention is responsible for the strategic development of the Compliance Program for the core areas of corruption prevention, antitrust law, data protection and money laundering prevention as well as the monitoring of so-called other compliance topics. In addition to knowledge-sharing and standardizing advice on core compliance issues, our tasks also include developing Group-wide guidelines and providing training concepts.

• The Operations & Projects department carries out projects for the further development of the compliance program and standardizable processes, and oversees the internal compliance reporting system.

• The Investigation department takes care of routine compliance audits and investigations into suspected infringements. Any information concerning infringements of the thyssenkrupp compliance program is addressed and investigated on the basis of defined processes and procedures.

• The Segments & Regions department strengthens our compliance advice activities in high-risk regions through regional compliance officers who, acting at local level and with knowledge of local laws and culture, advise selected foreign thyssenkrupp companies and carry out training programs on compliance-related issues.

In the business areas, compliance advice and classroom training are provided by centrally responsible compliance officers, who report directly to the Chief Compliance Officer.

To allow us to take into account local legal or cultural requirements, Regional Compliance Officers have been appointed for eleven regions. Some of these regions include several countries. The Regional Compliance Officers ensure close cooperation between the compliance departments of the operating companies and Group headquarters.

At the Group companies Compliance Managers are selected from among the top managers. As part of their corporate responsibility in forming a first line of defense, they are responsible for the implementation of the compliance policies. Based on defined roles and responsibilities, they are part of the compliance team and communicate closely with the full-time Compliance Officers.