Leadership does not just rest with the CEO middle management bear the principal burden in terms of setting the tone and culture of the organisation for frontline staff. Effective and ethical supervision at every level of a company is crucial if staff are to have the confidence and support to make ethical decisions, even if it affects the company’s bottom line.
Leadership and Organisational Culture
In our daily Compliance business, it is one of the most important things to instill thyssenkrupp with a broad-based and established value culture in which reliability, honesty, credibility and integrity are the cornerstones of our actions. This value culture must be jointly supported and actively lived by all employees – and in particular by our managers. A written code of values is a key component of such a value culture. At thyssenkrupp, our value culture is embedded in our Group mission statement which unequivocally states that Compliance is a must.
Through our Compliance Commitment, the Executive Board takes a firm stance rejecting Compliance violations of all kinds, specifically targeting anti-bribery and anti-corruption. This unequivocal commitment is supported by our Code of Conduct and various Group policies, in particular in the areas of anti-corruption and antitrust law.
Our Group Regulation Corruption Prevention defines the prohibition of corruption and bribery for all companies, employees, managers and executive board members of thyssenkrupp, the whole thyssenkrupp Group and third parties.
Important related documents and links:
Compliance Commitment
Code of Conduct
Group Regulation Corruption Prevention
a) All employees, including staff and leadership of subsidiaries and other controlled entities,
b) All board members, including non-executive directors
Our written codes, which consist of comprehensive anti-bribery and corruption policies, apply to all employees as well as the Members of the Board, regardless of their seniority.
Specific references to the prohibition of bribery, payments to public officials, commercial bribery and facilitation payments can be found in our Group Regulation Corruption Prevention.
Important related documents and links:
Compliance Commitment
Code of Conduct
Group Regulation Corruption Prevention
Corporate Governance has been systematically strengthened at thyssenkrupp in recent years. Our Chief Compliance Officer Dr. Sebastian Lochen, who is responsible for the operational implementation and further development of the Compliance programme, reports to the Group General Counsel who directly reports to the Executive Board member responsible for Legal & Compliance, Oliver Burkhard. Mr. Burkhard oversees the whole Compliance programme and therefore the company’s anti-bribery and corruption programme. He reports regularly to the Supervisory Board and Audit Committee on all relevant Compliance and ethical issues. In their described capacity, the Executive Board as a whole and more specifically the Executive Board member responsible for Legal & Compliance as well as the Supervisory Board and its Audit Committee also review the results of internal and external audits as well as the measures taken on at least a quarterly basis. As an example, we provide the Quarterly Compliance Report (for secrecy reasons we only show the agenda, audit results covered by the section “Identify”). thyssenkrupp Compliance Report Q1 2019/20:
Important related documents and links:
Compliance Organization
Audit reports
Our Chief Compliance Officer, who is responsible for the operational implementation and further development of the Compliance programme, reports to the Group General Counsel who reports directly to the Executive Board member responsible for Legal & Compliance, Oliver Burkhard. There is regular reporting on Compliance topics at every Board meeting, at quarterly intervals also with a specific Compliance report. These quarterly reports give detailed insight into Compliance activities, and internal as well as external audit results and are formally reviewed and acknowledged by the Board. The Chief Compliance Officer – depending on the topics – participates in Board Meetings as well as on behalf of the Executive board in Audit Committee Meetings of the Supervisory Board.
Important related documents and links:
Compliance Organization
Audit reports