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Closed-door meetings between procurement officials and defence companies can be legitimate and sometimes necessary, but they also create opportunities for bribery, influence-peddling and the development of relationships which could lead to potential or actual conflicts of interest.
Customer Engagement
Does the company have clearly defined policy and or procedure covering political contributions?
In our Group Regulation on Corporate Citizenship Activities, Memberships and Ticket Purchases we underline, that "financial contributions in particular donations and sponsorships to political parties in Germany and abroad, organizations related or similar to political parties, individual office incumbents or candidates for political offices are not permissible. In the case of other contributions granted to this group of individuals by companies in connection with their business activities, reference is made to the applicable laws and relevant Group Compliance policies. Furthermore, group companies are not permitted to hold memberships in political parties or organizations related or similar to political parties. "
Important related documents and links:
Group Regulation on Corporate Citizenship Activities, Memberships and Ticket Purchases:
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Does the company publish details of all political contributions made by the company and its subsidiaries, or a statement that it has made no such contribution?
thyssenkrupp prohibits any financial contributions, in particular donations and sponsorships, to political parties in Germany and abroad, organizations related or similar to political parties, individual office incumbents or candidates for political offices.
Our office for governmental affairs in Brussels is registered at the common European Union Transparency Register.
In the light of this, we already demonstrate a high level of transparency. At the moment, we participate in discussions to establish a register related to lobbying activities in Germany. Apart from data protection requirements, we face the significant problem in the field of defence technology (note: not only for defence) that we have to show consideration towards to increased security interests of involved clients as well as of involved natural persons.
Important related documents and links:
European Union Transparency Register
Does the company have a clearly defined policy and/or procedure covering charitable donations and sponsorships whether made directly or indirectly, and does it publish details of all such donations made by the company and its subsidiaries?
The Group Regulation on Corporate Citizenship Activities, Memberships and Ticket Purchases regulates that activities and contributions in connection with Corporate Citizenship shall be directed at the following areas: Science and exchange of knowledge, Research and development, Technology, Art and culture, Education, Sport, Faith-communities, Social welfare, Environment.
At thyssenkrupp, we operate an IT supported group-wide uniform process (Global Engagement Tool) for the internal approval and documentation of – inter alia - donations/sponsoring, memberships and ticketing. With this Global Engagement Tool we thoroughly document all the mentioned activities and contributions in connection with corporate citizenship and are able to give reports to external and internal requests on thyssenkrupp’s group-wide activities.
Please see below for a screenshot of the Global Engagement Tool:
Important related documents and links:
Code of Conduct
Does the company have a policy and/or procedure covering responsible lobbying?
thyssenkrupp internally defines lobbying as any activity of direct or indirect communication with public officials, political decision makers or representatives with the aim to articulate our views towards political decision makers.
As indirect lobbying activities, we consider activities with partners like associations, external advisors and measures related to public relations.
As direct lobbying activities, we consider communication activities of Group representatives with political stakeholders.
For employees, managers, and the board, the thyssenkrupp Code of Conduct provides framework guidance on political lobbying:
Political lobbying
"Our political lobbying is centralized, open and transparent. We comply with the legal requirements on lobbying and avoid at all costs unfairly influencing government policy and legislation. We have voluntarily joined the European Union Transparency Register and comply with the European Union Code of Conduct.”
External lobbyists are contractually obliged to comply with the lobbying rules in the thyssenkrupp Code of Conduct and are bound to the same high compliance standards which we as thyssenkrupp are following ourselves.
thyssenkrupp has a group-wide process which deals with so-called communications advisers, which are defined as persons who (in the context of communications) consult, support and deliver strategic and communicational content and advice to COM and/or businesses. This also covers lobbyists:
Important related documents and links:
Code of Conduct
European Union Transparency Register
European Union Code of Conduct
Does the company publish details of the aims and topics of its public policy development and lobbying activities it carries out?
We have joined the European Union Transparency Register for many years where we disclose our activities and comply with the -> tk Code of Conduct and the -> European Union Code of Conduct.
Our representative offices are based in Brussels and Berlin.
Important related documents and links:
European Union Transparency Register
European Union Code of Conduct
Code of Conduct
Our political contacts, especially in the defence sector, are under the full scrutiny of the parliament, the German Bundestag, e.g. http://dip21.bundestag.de/dip21/btd/19/162/1916291.pdf.
Does the company publish full details of its and global lobbying expenditure?
Our representative offices with permanent employees are based in Brussels and Berlin. Accordingly, the majority of our lobbying expenditure is incurred here.
The expenditure disclosed on the website of the European Union Transparency Register (https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=456211534646-58) mainly covers the costs of our Brussels office and includes certain membership fees regarding associations mentioned there as well.
The costs of our Berlin office were in the range of 350,000 – 400,000 € in the financial year 2018/2019.
Does the company have a policy and/ or procedure on gifts and hospitality to ensure they are bona fide to prevent undue influence or other corruption?
Our Group wide gift policy says that invitations and gifts must not be misused to influence decisions of business partners, customers or public officials. Invitations and gifts may therefore only be accepted or granted if occasion and scope are reasonable, i.e. of low value and of local customary business practice. In order to avoid the suspicion of attempting to influence business decisions, strict standards are to be applied when considering the value and local customs. The acceptance of invitations to sporting, cultural or similar events which are not directly connected in time and place with an employee’s work obligations and/or which include related persons require prior approval of the superior.
We use innovative formats to sensitize our employees for the topic of gifts and invitations. In 2018, for example, this was achieved through a lottery where received gifts that were above our indicative thresholds of reasonableness were raffled off to employees.
Important related documents and links:
https://www.waz.de/wirtschaft/wirtschaft-in-nrw/so-geht-thyssenkrupp-mit-zweifelhaften-geschenken-um-id215957705.html
See 3.6 Group Regulation Corruption Prevention
Guidance Note on dealing with invitations, gifts and private discounts, page 10:
At thyssenkrupp, we operate an IT supported group-wide uniform process (Global Engagement Tool) for the internal approval and documentation of – inter alia - donations/sponsoring, memberships and ticketing. With this Global Engagement Tool we thoroughly document all activities and contributions in connection with corporate citizenship and are able to give reports to external and internal requests on thyssenkrupp’s group-wide activities.
Please see below for a screenshot of the Global Engagement Tool:
With tickets purchases oftentimes constituting the basis of higher value invitations, we are therefore addressing a major part of thyssenkrupp’s higher value invitations in this tool. According to certain thresholds, ticket purchases have to be reviewed by the compliance function.