Compliance
Compliance for us means more than just following rules and regulations. Compliance is a matter of mindset: reliability, honesty, trustworthiness and integrity are part of our DNA. We would rather sacrifice a contract than win it by breaking the rules.
What we represent
For us, compliance is a central element of good corporate governance. It means much more than compliance with rules and regulations. It is a matter of mindset. It applies to each of us at thyssenkrupp, every day, in every place.
Values such as integrity, honesty, trustworthiness and fairness are not empty words for us, but permeate our corporate DNA. This is the standard we apply in developing our strategic compliance activities, creating a culture of values that must be collectively supported and consistently carried out by all employees - especially our managers. A written code of values forms the basis of our decisions.
At thyssenkrupp, this culture of values is embedded in the Company Mission. With our commitment to compliance, the Board of Directors takes a firm stance in rejecting compliance violations of any kind. This unequivocal commitment is supported by a code of conduct and various Group policies, particularly in the areas of anti-corruption and antitrust law.
thyssenkrupp means compliant and honest business
It is important to us that our corporate philosophy is present at all levels of the Group in the interest of "good corporate governance." We are trying to make sure that there are no systemic weaknesses or deficits in Compliance or anywhere else.
At the same time, we want to foster entrepreneurial courage within a clearly defined framework. While it is part of our philosophy to take calculable entrepreneurial risks and to make and accept mistakes, we will not take risks with compliance.
Intentional breaking of laws and internal rules is not acceptable both legally and in our understanding of Compliance.
We have three rules:
We investigate all reports of legal violations and explain the facts;
Any violations found are immediately stopped;
All violations found are systematically and appropriately sanctioned based on a zero tolerance policy.
People make mistakes. If an employee who has inadvertently violated the law admits his mistake and tries very hard to correct it, deserves a second chance - if the circumstances of a particular individual case allow it. This, too, is a matter of a culture of values and honesty in our dealings with each other.
thyssenkrupp stands for compliant and honest business - this is a standard that we definitely live up to. We would rather lose a contract than win it by breaking the rules.
whistleblowing@thyssenkrupp Materials Poland
At thyssenkrupp Materials Poland integrity, compliance with the law and internal regulations are of highest priority. To ensure that these values are upheld and potential risks arising from violations are avoided or minimized, it is crucial that misconduct is identified, clarified, and remedied at an early stage. Every indication of a potential misconduct is treated seriously and leads to an investigation following an objective and transparent process without any bias. thyssenkrupp Materials Poland therefore makes available to whistleblowers in compliance and under protection of the Polish Whistleblowing Act, an internal information system that enables whistleblowers to submit reports.
The Polish Whistleblower Protection Act transposed the Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019, on the protection of persons who report breaches of EU laws, as well as serious criminal and administrative offenses under Polish law.
Since 25 September 2024, entities with more than 50 employees need to implement the according measures, especially the activation of a reporting channel and establishment of investigation procedures that guarantee, among others, the confidentiality of the report and the protection of the whistleblower against disclosing its identity and any retaliation resulting from the report.
A detailed description of thyssenkrupp Materials Poland Investigation Principles and Rights and Duties of Whistleblower can be found as attachment of this page.
1. Who can inform about a violation?
The whistleblower is the natural person who submits the report or makes a public disclosure of information on violations acquired in the context of his or her work. Reporting can be done through multiple channels by:
staff with an employment relationship
elf-employed workers
freelancers and consultants, suppliers, customers
volunteers and trainees
shareholders or owners of company shares persons with administrative, management, supervisory or representative functions
any person working for or under the supervision and direction of contractors, subcontractors and suppliers.
2. What can be reported?
Violations of internal regulations and/or applicable laws listed in the Polish Whistleblower Protection Act, violations of human rights and environmental-related breaches of duty or risks as well as breaches of European law can be reported through a variety of channels. Even indications or suspicions of violations can be reported and will be treated seriously. Therefore, in this document “violations” will refer to both actual and potential violations.
3. Who is responsible for dealing with reports?
thyssenkrupp AG has established Compliance Investigations Department (CO/L&C-INV) with its autonomous and specifically trained personnel as “Reporting Administrator” to support thyssenkrupp Materials Poland with the tasks of receiving reports and conducting investigations. The respective Compliance Investigation Officers are impartial, independent, are not bound by instructions with regard to investigations and sworn to secrecy. Incoming reports, that can also be submitted anonymously, are treated confidentially and whistleblowers are protected by all appropriate means against any disadvantages resulting from a report.
Whistleblowers may submit a report through various channels described below. The Reporting Administrator together with the tk Group Function Internal Auditing (“CO/AUD”) and the Compliance Manager, will agree on adequate investigation procedures and propose adequate measures to thyssenkrupp Materials Poland, if necessary.
4. How can I submit a report?
An open communication culture is an essential component of well-functioning compliance. Employees must be able to address potential violations openly, anonymously and, above all, at an early stage.
For this purpose, thyssenkrupp Materials Poland makes a number of internal whistleblowing channels available which are set out below:
4.1 thyssenkrupp Electronic Whistleblowing System (BKMS)
The Compliance Whistleblowing System of thyssenkrupp can directly be accessed under: Home - BKMS System
(The link will take you to the Compliance Whistleblowing System in English. You can select another language on the landing page, e.g. English, to submit your report in the Compliance Whistleblowing System.)
In addition to the Compliance Whistleblowing System, violations regarding the International Framework Agreement (thyssenkrupp internal HR violations) can also be reported to representatives on the International Committee and the Labor Relations department at thyssenkrupp AG under https://www.bkms-system.net/frameworkagreement
4.2 Telephone Hotline
thyssenkrupp contact via the following telephone number selecting Polish language (automated telephone dialog):
Phone: +48 22 152 3361
Access PIN: 4541
4.3 Contacts within thyssenkrupp Headquarters
thyssenkrupp Headquarters can be reached via the following contact details:
thyssenkrupp AG,
Compliance, Department Investigations
thyssenkrupp Allee 1,
45143 Essen, Germany
whistleblowing@thyssenkrupp.com
4.4 Contacts within thyssenkrupp Materials Poland
Compliance Manager, +48 56 611 95 92, tkMPL-sygnalista@thyssenkrupp-materials.com.
If you work for thyssenkrupp, you can also contact your Compliance Manager responsible for your company directly. A detailed list of contacts is available on the intranet.
Please note: If a face-to-face meeting is requested, it will be organized within 7 days. If the report is submitted orally, with prior consent of the whistleblower, the report is documented in a secure, durable and accessible format, or by a transcript of the conversation. The whistleblower may be given the opportunity to verify, rectify and confirm the minutes of the meeting by signing them.
More information on the submission of reports to thyssenkrupp can be found here: Submitting a report (thyssenkrupp.com)
4.5 External Reporting Channels
We encourage whistleblowers to use our internal reporting channels. Whistleblowers also have the option to submit their report to an external reporting channel, submitting a report to the Commissioner for Human Rights (Ombudsman) in Poland: https://bip.brpo.gov.pl/en/en/content/how-refer-your-matter-commissioner-human-rights.
5. Data Protection
While carrying out internal investigations, it will be ensured that the applicable data protection laws are complied with. Detailed information on the subject can be found here: Data Protection Information
Annexes to download:
Annex 1 Investigation Principles
Annex 2 Rights and Duties of a Whistleblower
Compliance Commitment
thyssenkrupp stands for technological competence, innovation, customer orientation and motivated, responsible employees. These factors are the basis for our high reputation and the Group's long-term economic success in global competition.
"Corruption and antitrust violations threaten these success factors and will not be tolerated (zero tolerance). For us, bribes and cartel agreements are not the way to win business. We would rather walk away from a deal and fail to achieve internal goals than go against the law. All employees are asked to actively cooperate in their areas of responsibility in implementing the thyssenkrupp Compliance Program."
Regarding corruption and antitrust violations, the Board of Directors of thyssenkrupp AG has issued the following thyssenkrupp Compliance Commitment, which clearly expresses their position on compliance with relevant Group laws and policies.Zarząd thyssenkrupp AG wydał następujące Zobowiązanie Compliance thyssenkrupp*
Through its Compliance program, thyssenkrupp has taken extensive measures to ensure compliance with corruption and antitrust laws and Group policies based on them. Violations will not be tolerated and will result in sanctions against those involved. All members of the Board of Directors and managing directors, all senior managers and other employees must be aware of the extraordinary risks that corruption and antitrust violations may mean for thyssenkrupp, as well as for them personally.
*Originally established by the Board of Directors of thyssenkrupp AG on April 16, 2007.
Code of Practice
Respect, cooperation and social responsibility are the cornerstones of sustainable business success.
At thyssenkrupp, this philosophy has a long history. The German social security system is based in part on models introduced by our company 160 years ago. Equal opportunity and fair pay in accordance with local standards are a matter of course for us. At a minimum, we offer salaries and benefits in accordance with national and local statutory and industry standards, including pension and health benefits.
In addition, thyssenkrupp recognizes the UN Global Compact and is committed to the UN Universal Declaration of Human Rights and the International Labor Organization (ILO) Core Labor Standards.
The main rules and regulations governing our operations, as well as the standards we set in our dealings with business partners and stakeholders, are summarized in the thyssenkrupp Code of Conduct. For employees, managers and the Board of Directors, it provides framework guidance on the following issues:
Legal compliance
Avoidance of conflicts of interest
Fair competition
Prevention of money laundering
Equal treatment and non-discrimination
Human and labor rights
Cooperation with employee representatives
Occupational health and safety
Environmental and climate sustainability
Donations
Political lobbying
Public behavior and communication
Reporting
Confidential company information/insider information
Data protection and information security
Protection of company property
