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Compliance program

The Compliance program of thyssenkrupp Elevator comprises the three elements Inform & Advise, Identify and Report & Act. It is closely interlinked with risk management and with our internal control system. In this way we ensure that Compliance is an integral component of every single business process.

The Compliance program is focused on antitrust law and corruption prevention. Since 2014, measures relating to money laundering and, more recently, export control have additionally been integrated and established as part of the Compliance program. In relation to other topic areas – such as occupational safety and environmental protection – the Compliance team has taken on the role of advisor, coordinator, and consolidator. Substantive responsibility in these areas remains with the competent corporate functions and business units; the Compliance team provides support and advice and ensures uniform reporting to the Executive Board.

Setup and elements of the compliance program

The three pillars of our compliance program

Inform & Advise

Central components of this pillar are the prevention trainings carried out by the Compliance Officers on our core topcis. Our employees are regularly informed about Compliance requirements, risks, and possible sanctions. The requirements are based on applicable law and our group-wide policies and also reflect international standards.

In connection with our Compliance advice activities, we support important business transactions, for instance in connection with major projects and M&A transactions, or the engagement of intermediaries. For any Compliance-related questions arising in their day-to-day, the employees may contact their Compliance Officers directly or address their questions to our central advisory hotline. The Compliance Officers also advise the operating units on integrating compliance into their business processes.

Identify

Here the focus is on regularly reviewing critical business operations based on a risk-oriented, structured audit process. In close alignment with our internal control system, there is a regular assessment of the degree of implementation of the Compliance program at the group companies. Further, there is a targeted risk assessment process in place. The Compliance team, hand in hand with our operative business, regularly assesses the abstract and specific Compliance risks at specific companies, mainly in the areas of antitrust law and corruption prevention. These risks are subsequently discussed with the operational teams at workshops, in which measures are developed to address and reduce the risks identified.

An additional element in the identification of Compliance risks and violations is our whistleblowing system. Alongside the options of directly contacting a supervisor or the Compliance department, this provides employees with a further channel for reporting possible infringements of laws or policies without revealing their identity.

Report & Act

The third pillar of our Compliance program implies intensive Compliance reporting in all dimensions of our organizational matrix. Compliance violations are sanctioned consistently and appropriately, if necessary.