As well as the management and constant development of the compliance program, our Compliance function has the important role of acting as a strategic business partner to provide our group functions and businesses with advice on relevant strategic decisions at an early stage. This requires a needs-based and appropriately staffed organization with clearly allocated roles and responsibilities, effective and efficient steering, and in particular a task allocation which is structurally in line with the requirements of the thyssenkrupp group of companies.
thyssenkrupp employs more than 80 full-time compliance employees worldwide, of whom around 30 also have other legal tasks. They are supported by a network of around 250 compliance managers, who are generally top executives of a group company and ensure that the compliance program is implemented at operating level in their area of responsibility. Additionally, on September 30, 2021 there were over 160 data protection officers and data protection coordinators. Together they play a key role in permanently embedding compliance in the thyssenkrupp group of companies and are available to employees seeking advice.
The General Counsel of the thyssenkrupp Group is also the Chief Compliance Officer and is responsible for managing the compliance program and the global compliance organization.
Our activities: Cross-cutting within the segments and in the regions
At thyssenkrupp AG four compliance departments have been installed:
The Department Awareness & Prevention is responsible for the strategic development of the Compliance Program for the core areas of corruption prevention, antitrust law, data protection, anti-money laundering and trade compliance as well as the monitoring of so-called other compliance topics. In addition to knowledge-sharing and standardizing advice on core compliance issues, our tasks also include developing Group-wide guidelines and providing training concepts.
The Operations & Projects department carries out projects for the further development of the compliance program and standardizable processes, and oversees the internal compliance reporting system.
The Investigation department takes care of routine compliance audits and investigations into suspected infringements. Any information concerning infringements of the thyssenkrupp compliance program is addressed and investigated on the basis of defined processes and procedures.
The Segments & Regions department strengthens our compliance advice activities in high-risk regions through regional compliance officers who, acting at local level and with knowledge of local laws and culture, advise selected foreign thyssenkrupp companies and carry out training programs on compliance-related issues.
In the segments, compliance advice and classroom trainings are provided by centrally responsible compliance officers, who report directly to the Chief Compliance Officer.
To allow us to take into account local legal or cultural requirements, Regional Compliance Officers have been appointed for nine regions. Some of these regions include several countries. The Regional Compliance Officers advise our employees on a local level.
At the Group companies Compliance Managers are selected from among the top managers. As part of their corporate responsibility in forming a first line, they are responsible for the implementation of the compliance policies. Based on defined roles and responsibilities, they are part of the compliance team and communicate closely with the full-time Compliance Officers.