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Ownership
PUBLIC
Defence revenue, USD
Unknown
Defence revenue, %
Unknown
Country
GERMANY
Internal information
YES
Based on public information, there is no readily available evidence that the company’s Chairman demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. There are numerous examples where the Chairman has delivered speeches and participated in interviews where the ethics and anti-corruption agenda of the company is mentioned. However, these have all been delivered in relation to corruption allegations. TI is looking for a personal commitment from the Chairman, rather than a response to allegations, which would be expected from any company leader.
Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure. This engagement could take the form of speaking at training events or chairing a review of anti-corruption programmes.
Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including openness, transparency and integrity. The company provides a brief explanation of what they mean by such values and why they matter to the organisation.
Based on public information, there is readily available evidence that the company has joined the UN Global Compact.
Based on public information, there is evidence that the company has appointed Executive Board member Dr Kaufmann, with overall corporate responsibility for its ethics and anti-corruption agenda. The Chief Compliance Officer and Head of Legal Affairs report to Dr Kaufmann, who heads the Legal Affairs and Compliance directorate. However, there is no readily available evidence detailing specifically what Dr Kaufmann’s responsibility entails. The company therefore scores 1.
Based on public information, there is readily available evidence that the company has appointed Chief Compliance Officer Dr Christoph Klahold, with responsibility for implementing its ethics and anti-corruption agenda. The Chief Compliance Officer heads the central compliance division, coordinates the company’s compliance activities and reports to Executive Board member Dr Kaufmann.
Based on public information, there is evidence that the company commissioned two external reviews of the compliance programme in 2011 and 2013.
Based on public information, there is limited evidence of a formal written plan that guides the Board review of the ethics and anti-corruption agenda. Each quarter, a compliance report is created for the Board and the Audit Committee and it gives information on the status of the Compliance Audit. There is some evidence that when issues are identified compliance activities are intensified. The company therefore scores 1. To score higher on this question the company would need to provide further information on the formal plan that guides the review and further evidence that improvement plans are implemented.
Based on public information, there is evidence that the company has a process to review and update company policies in the event of actual or alleged instances of corruption. However, it is unclear if this is a standard, formal process or is ad-hoc and based on a particular case. The company therefore scores 1. To score higher the company would need to provide evidence of such a formal process.
Based on public information there is readily available evidence that the company has an anti-corruption risk assessment procedure implemented enterprise-wide. Corruption risks are identified and mitigation plans developed by the group companies, with the support of the Corporate Function Compliance. The Compliance Risk Profile is a main tool for setting priorities under the Compliance Programme.
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 readily available evidence that the company conducts due diligence that minimises corruption risk when selecting agents. To score higher the company would need to provide evidence it refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship. The company therefore scores 1.
Based on public information, there is evidence that the company has formal procedures and contractual rights for the behaviour, monitoring, control, and audit of agents with respect to countering corruption. However, it is not clear that the company has the right to terminate a contract if corrupt activities are discovered and there is insufficient evidence to suggest that the Supplier Code of Conduct applies to agents. The company therefore scores 1.
Based on public information, there is evidence that the company communicates to suppliers through policy and contractual terms, its ethics and anti-corruption agenda. The company expects suppliers to comply with national and international laws and regulations, as well as the Supplier Code of Conduct. The company has the right to terminate a contract if a supplier is found to have breached the Supplier Code of Conduct.
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 evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. This includes the giving and receiving of bribes, facilitation payments, gifts and hospitality, and conflicts of interest.
Based on public information, there is evidence that the company has a zero tolerance corruption policy.
Based on public information, there is evidence that the company’s Code of Conduct and Supplier Code of Conduct are easily available to employees, Board members and third parties. Both documents are available on the company website in multiple languages.
Based on public information, there is evidence that the Code of Conduct and Supplier Code of Conduct are written in accessible, comprehensible language.
Based on public information, there is evidence that the Code of Conduct applies to all employees and Board members.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest. However, it is minimal and does not provide extensive guidance. The company therefore scores 1. To score higher the company would need to provide evidence that a conflict of interest is clearly defined and that examples of potential conflicts of interest are provided for employees. TI notes that members of the Supervisory Board have a separate policy.
Based on public information, there is evidence that the company has a policy that regulates the giving and receiving of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. The company instructs employees to only offer or accept gifts if appropriate, and completely prohibits cash gifts and all gifts exchanged before a deal is signed. Gifts to and from business partners are limited to approximately €50 and gifts to public officials must be low-value typical promotional gifts.
Based on public information, there is evidence that the company has a policy that regulates the giving and receiving of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. Employees are instructed to only offer or accept hospitality if it is appropriate and are completely prohibited from exchanging hospitality before a deal is signed. Invitations to and from business partners are limited to approximately €100 and invitations to public officials are limited to €35.
Based on public information, there is readily available evidence that the company has a policy that explicitly prohibits facilitation payments. However, the policy is limited in scope. The company therefore scores 1. To score higher the company would need to provide evidence of guidance on how the policy is to be implemented in practice.
Based on public information, there is evidence that the company prohibits political contributions in order to prevent corruption or other undue influence.
Based on public information, there is some evidence that the company has a lobbying policy, in order to prevent undue influence or other corrupt intent. There is also evidence that the company discloses some of the issues on which it lobbies. However, the Code of Conduct provides insufficient information to understand the company’s lobbying policy. The company therefore scores 1. To score higher the company would need to provide evidence of the policy mechanisms and guidelines, such as employees requiring authorisation from individuals with legal expertise before they commence lobbying activities.
Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent. A Global Engagement Tool is planned for the financial year 2013/14 but there is a lack of information available concerning its specific application to charitable contributions. The company does not publically declare the recipients of charitable contributions.
Based on public information, there is evidence that employees have access to written guidance that helps explain the company’s ethics and anti-corruption agenda. However, it is unclear in what format this guidance facilitates explanation. The company therefores scores 1. To score higher the company would need to provide evidence of guidance that contains examples in the form of scenarios or case studies.
Based on public information, there is evidence that the company has a training programme on its ethics and compliance systems, which includes anti-corruption.
Based on public information, there is evidence that the company provides anti-corruption training in all countries where it operates or has sites. The group-wide compliance e-learning programme covers anti-corruption and is available in nine different languages.
Based on public information, there is evidence that Board members take part in classroom training, which includes anti-corruption and antitrust matters. The company therefore scores 1. To score higher the company would need to provide evidence that this training occurs at least every 3 years.
Based on public information, there is readily available evidence that the company provides supplementary ethics and anti-corruption training for employees facing different levels of risk. Employees selected for additional training may include sales and purchasing staff or senior executives.
Based on public information, there is no readily available evidence that the company has a clear and formal process for employees to declare conflicts of interest. To score on this question the company would need to provide evidence that employees declare conflicts of interest in writing to a manager or to an independent department.
Based on public information, there is evidence that the company clearly states that it will apply disciplinary procedures to employees and Board members found to have violated the company’s policies, directives and agreements.
Based on public information, there is evidence that the company has multiple, wel-publicised channels that are accessible and confidential, to report instances of suspected corrupt activity. Both the company whistleblowing system and the Ombudsman allow anonoymous reporting, with the latter also being independent from the company.
Based on public information, there is evidence that all employees in all geographies have access to the Ombudsman and the company whistleblowing system.
Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms, to assure itself that whistleblowing is not deterred and that whistleblowers are treated supportively.
Based on public information, there is 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. These resources include a range of compliance officers and compliance managers.
Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. Evidence suggests that disciplinary measures are applied to employees who breach this policy.
Based on public information, there is evidence that the company has published in the last two years, a statement from the Executive Board supporting the company’s strong stance against corruption. The company has also published in the last two years one strong statement from the Executive Board that promotes the company’s ethics and anti-corruption agenda, under which it is clear that anti-corruption is a significant component.