Chief Compliance Officer Dr. Thomas Kremer and Compliance Officer Dr. Joerg Horney

Compliance Program

Compliance, in the sense of measures to ensure adherence to statutory provisions and internal company policies, is a key management duty at ThyssenKrupp. The company's Groupwide compliance activities focus on antitrust law and anticorruption policies.

The ThyssenKrupp Compliance Program was introduced directly after the merger of Thyssen and Krupp in 1999. It has been regularly reviewed and revised as necessary ever since.

In April 2007 the Executive Board of ThyssenKrupp AG unequivocally reiterated its rejection of antitrust violations and corruption and to this end issued the ThyssenKrupp Compliance Commitment: Antitrust violations and corruption are not tolerated in the ThyssenKrupp Group (zero tolerance). The ThyssenKrupp Compliance Commitment is supplemented by various Group policy statements and publications which explain the underlying statutory provisions in more detail and make them more specific for the Group and its employees.

The segments are responsible for implementing the Compliance Program. Their legal and compliance departments hold regular training sessions to inform employees about the relevant statutory provisions and internal policies and are available to answer individual questions. Classroom training sessions are supplemented by a Groupwide interactive e-learning program, which around 20,000 Group employees have taken part in to date.

The Compliance Program and its implementation are reviewed by the competent ThyssenKrupp Compliance Officer in consultation with Corporate Internal Auditing. Insofar as there is any evidence of infringements of the ThyssenKrupp Compliance Program, this is looked into and investigated. ThyssenKrupp employees can report concerns about possible violations to their supervisor or legal/compliance department. In addition, the so called Whistleblower Hotline is available for reporting compliance infringements, with the identity of the informant, remaining confidential on request.