MTU Aero Engines AG

Based on public information, there is evidence that the company published a statement from the CEO supporting the ethics agenda of the company as an introduction to the Code of Conduct and also on the Compliance section of the company website. TI notes that corruption is mentioned specifically in the statement on the company website.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

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.

Based on public information, there is evidence that the company publishes various statements on the values and principles of business conduct, including transparency and integrity. However, this falls short of the range of values sought by the question and is assessed to lack detailed explanation. The company therefore scores 1.

Based on public information, there is evidence that the company is part of the UN Global Compact and ASD.

Based on public information, there is evidence that the company has appointed the Compliance Board with responsibility for its ethics and anti-corruption agenda. It is responsible for identifying risks, recommending improvements and coordinating measures in response to incidents of non-compliance.

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 oversee the ethics and compliance agenda

Based on public information, there is evidence that the Compliance Board identifies and evaluates reputational risks, signs of possible corruption and incidents and recommends additional compliance rules to the Executive Board. However, the work of the Compliance Board appears to be more ongoing monitoring than a heavyweight review of the ethics and anti-corruption agenda. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a formal written plan in place for review and update of the anti-corruption agenda. There is a mention of a Compliance Board tackling issues of corruption but details on whether it reviews and suggests improvements are not available.

Based on public information, there is limited evidence that the company has a formal process for review and update of its anti-corruption policies. The Compliance Board appears to perform these functions to some degree in the company. However, the formality of the review process is not clear. The company therefore scores 1. TI notes that the company provided internal information for the 2012 CI which was openly published in the survey report with the company’s permission. However, the public assessment score remains 1 as this part of the survey is seeking to understand company transparency.

Based on public information, there is evidence that the company does have a formal compliance and ethics risk assessment procedure.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. However, there is insufficient evidence of clear requirements on the circumstances under which such a procedure should be applied. The company therefore scores 1.

Based on public information, there is some evidence that consultants appointed to the company are reviewed by TRACE for the company. However, it is not clear that due diligence is refreshed after 3 years or when there is a significant change in the business relationship. The company therefore scores 1.

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 evidence that the company expects suppliers to commit to the company’s standards. However, there is no evidence of contractual terms, or the consequences of breaches. The company therefore scores 1. TI notes that the company provided internal information for the 2012 CI which was openly published in the survey report with the company’s permission. However, the public assessment score remains 1 as this part of the survey is seeking to understand company transparency.

The company has informed TI that it does not engage in offset contracting.

The company has informed TI that it does not engage in offset contracting.

Based on public information, there is evidence that the company has a policy prohibiting corruption in its various forms and it goes into sufficient detail about each of these types of corruption.

Based on public information, there is evidence that the company has a policy of zero tolerance for corruption.

Based on public information, there is evidence that the company’s anti-corruption policy contained in its Code of Conduct, the company website and Code of Conduct for suppliers is easily accessible. TI notes that the Code of Conduct is available in English and German.

Based on public information, there is evidence that the company’s anti-corruption policy contained in its Code of Conduct, the company website and Code of Conduct for suppliers are easily understandable.

Based on public information, there is evidence that the company’s anti-corruption policy, contained in the Code of Conduct, explicitly applies to all employees and members of the Board.

Based on public information, there is limited evidence that the company has a policy on conflicts of interest. The policy does mention instances related to conflict of interest scenarios but is not explicit and clear in its definitions and application of the same. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy includes indicative limits to achieve this. However, it is not clear whether these limits apply to public officials as well as to suppliers, customers and other business partners. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy includes indicative limits to achieve this. However, there is no evidence that these regulations apply to dealings with public officials. The company therefore scores 1.

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 limited evidence that the company regulates political contributions. It is noted that such contributions have to be reported to the Board of Management; however, the effect of this provision to prevent corruption cannot be ascertained.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities.

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 has a training programme that explicitly covers anti-corruption.

Based on public information, there is evidence that the company provides compliance training (including anti-corruption training) to all employees. These courses are repeated on a regular basis.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board. It is noted that members of the Supervisory Board do receive some training; however, its emphasis on anti-corruption cannot be ascertained.

Based on public information, there is limited evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. It is mentioned that special training is provided for employees in ‘positions of trust’; however, further detail about these positions is unavailable hence the score is withheld to 1.

Based on public information, there is no readily available evidence that the company has a formal process by which employees declare conflicts of interest. TI notes the disclosure process of members of the Board of Management.

Based on public information, there is evidence that the company will appropriately penalize employees and Board members if violation of the Code of Conduct occurs.

Based on public information, there is evidence that employees are able to report concerns or instances of suspected corrupt activity to the ombudsman. However, evidence does not suggest that employees are able to report anonymously or to an independent channel. Therefore the company scores 1.

Based on public information, there is evidence that across geographies all employees are able to report to the ombudsman using the global whistleblowing system. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies all employees have access to more than one whistleblowing channel.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively.

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 insufficient evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The available information just mentions that the employees can report instances of corruption ‘in confidence’. There is no clear commitment of non-retaliation or protection for the employee in case of reporting an instance of corruption.