Krauss-Maffei Wegmann GmbH & Co. KG

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer specifically supporting the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, external-facing commitment to the ethics and anti-corruption agenda of the company, for example through public speeches or involvement in industry anti-corruption initiatives.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, for example through direct involvement with the staff on ethics issues, speaking at training, etc.

Based on public information, there is no readily available evidence of such a statement. TI notes that the Chief Executive Officer makes reference to company values in a statement on the website; however, no further information was found apart from this brief reference.

Based on public information, there is no readily available evidence that the company is a part of a national or international business ethics initiative.

Based on public information, there is no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board.

Based on public information, there is no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence of a formal, clear, written plan on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is some evidence that the company has an anti-corruption policy. However, TI notes that only limited information is provided about this policy publicly in a statement by the CEO on the company website.

Based on public information, there is no readily available evidence that the company has zero tolerance for corruption. The Board of Directors has zero tolerance for criminal activity and infringements of the approved values. However, this is insufficient to score on this question.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties.

Based on public information, there is evidence of that this policy applies to employees and implicitly that it also applies to the Board. However, TI assesses that the wording is not explicit enough to score higher here. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest.

Based on public information, there is no readily available evidence that the company ha a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy includes a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company provides anti-corruption training.

Based on public information, there is some evidence that anti-corruption training is provided to company employees. However, it is not clear whether training is available across all geographies. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that the company has one whistleblowing channel for employees to report concerns or instances of suspected corrupt activity. Employees are instructed to directly contact the company’s Executive Board. However, no further details are provided. The company therefore scores 1.

Based on public information, there is no readily available evidence that across geographies, all employees have access to whistleblowing channels. There is insufficient evidence to determine if all employees are able to report to the company’s Executive Board, as no details are provided.

Based on public information, there is no readily available evidence of a process for supporting whistleblowers.

Based on public information, there is no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. However, there is no readily available evidence that employees who breach this commitment will be disciplined. The company therefore scores 1.