Corporate Integrity
Compliance and Anti-Corruption
Our Approach: Strict Tolerance
They may be minute, but for technical and physical reasons the products from HENSOLDT always have tolerances. When it comes to compliance and anti-corruption, our attitude is diametrically opposed: Here, the company has a strict tolerance policy in respect of established guidelines and management systems.
HENSOLDT’s business is not only based on the four principles of cooperation, excellence, responsibility, and innovation. These four pillars themselves stand on the unshakable foundation of a comprehensive ethics and compliance program. As the basis for all business activities and a core element of our Group culture, it protects our senior management and employees, the company, and its reputation, as well as HENSOLDT’s customers, through an uncompromising strict tolerance approach. The aim is to ensure legally and ethically correct action on all levels of our business and systematically prevent violations of laws and regulations. In 2021, the HENSOLDT compliance programme still focuses on the same six core areas.
The HENSOLDT Compliance Programme
1. Anti-Corruption
HENSOLDT has analysed the risk of corruption in the defence segment, which receives particular public scrutiny, as high. HENSOLDT rejects all forms of corruption, regardless of whether public or private, active or passive, through an uncompromising strict tolerance policy. With a special focus on corruption risks arising from dealings with commercial agents and third parties, we have developed a special system for assessing the risk of non-compliance with anti-corruption guidelines practically and with due care. This is achieved through HENSOLDT’s anti-corruption guidelines along with internal audits. The aim is to minimize corruption risks at all times. Deals that are irreconcilable with HENSOLDT’s values and our strict risk tolerance are declined – even where this means foregoing (new) business opportunities. Extremely strict prerequisites apply for contingency-fee agreements; they are monitored strictly and avoided wherever possible. The same applies for every form of compensation agreement. All employees must also adhere to identical, clearly defined rules regarding gifts and invitations.
The Partner Review Directive (“PRD”) forms the basis for all dealings with business partners and contains special rules of conduct and duties of care with respect to the specific regional and transaction-related risks of a case. The PRD is regarded as the successor to the previous Counterparty Due Diligence (“CDD”) and was instituted in June 2021.
As part of the partner review process, the Compliance department conducts a risk assessment of the planned transaction, which forms the basis for the decision, to be taken by the business units responsible up to executive management, whether or not the transaction will be pursued. To ensure adherence with all compliance requirements and regulations, including the PRD, HENSOLDT has expanded its internal Compliance Team substantially in recent years and provided it with the necessary resources.
2. Data Protection
At HENSOLDT, data protection means more than just complying with legal requirements: it is also an expression of morally above-board and extremely mindful dealings with employees and business partners. Our own, globally valid Data Protection Directive, which complies with the EU General Data Protection Regulation (GDPR), requires all employees to protect data and information systems against attacks. Employees are supported in this by our own Data Protection Officers as the main points of contact for all issues relating to IT and data protection.
3. Export Compliance
HENSOLDT’s international business is subject to numerous sales and export restrictions and controls. To comply with government approval requirements and moratoriums, Group Export Compliance disseminates the generally applicable regulations, monitors the individual transactions from the perspective of export control and risks of economic sanctions on the Group level, and forwards individual applications for export permits to the responsible authorities. Compliance with all necessary directives and procedures, including an anti-boycott guideline, an anti-corruption directive, the PRD, and all other compliance regulations and standards for business conduct, aims to ensure successful export business within the parameters of the respectively valid rules.
4. Antitrust and Competition Law
HENSOLDT is subject to a wide variety of competition and monopoly statutes that protect diverse and free competition and are overseen by national and supranational authorities. Compliance with these laws is the task and duty of all HENSOLDT employees and forms the basis for every business transaction. The Compliance and Legal units have published mandatory requirements and guidelines; they advise and train all employees to ensure compliance with all monopoly and competition regulations.
5. Involvement of Our Supply Chain
HENSOLDT also expects and actively demands of all business partners that they comply with the global HENSOLDT standards. To this end, a new Supplier Code of Conduct came into effect in 2021 among other measures. For more information, please refer to the “Responsible Procurement”.
6. Focus on the Human Element
HENSOLDT consistently places the focus of all its compliance activities on its employees, as comprehensive integrity can only be achieved if each individual does their part. The aim is to ensure the long-term success of the company, in line with the motto “Only honest business is sustainable business.”
Our Foundation: the HENSOLDT Code of Conduct
The same Code of Conduct applies to all employees of HENSOLDT companies, regardless of their location, position in the enterprise, or division. It sets out their general rights and obligations and defines mandatory basic rules for internal cooperation. As one of its main tenets, the HENSOLDT Code of Conduct challenges all employees to communicate openly. In addition to reporting potentially suspicious activities directly to their supervisors, employees also have the option of reporting them via the HENSOLDT OpenLine, a platform that permits anonymous reporting 24 hours a day. No serious cases were reported in the year under review. The results of the notifications are reported to the Management Board and the Executive Committee.
All employees regularly receive information and mandatory training as to the content and requirements of the Code of Conduct and other compliance regulations. The Compliance department carries out regular training sessions, both face to face and virtually (sometimes via digital platforms). As the partner review process was modified in the year under review, this was a key topic of compliance training. In the year under review, the Compliance department also introduced a general communication platform, the “Q&A Sessions.” Alongside questions about the modified partner review process, the biweekly Q&A Sessions were also used to present and discuss the various compliance-related topics in terms of their practical relevance. One key aspect is to strengthen the individual responsibility of each employee and heighten their awareness so that they can better recognize risks. Executives are involved in all facets of our compliance programme and are called on to actively communicate the significance of the programme to their subordinates. This also encompasses the communication of updates to the compliance programme, such as those that took place in 2021, for example, with the PRD.
Human Rights
Our Approach: Day-to-Day Practice
HENSOLDT places a high priority on complying with our international obligations to protect human rights. As a generally applicable policy, the Code of Conduct asserts HENSOLDT’s commitment to upholding human rights – both within and outside the company. The values and practices to which HENSOLDT is committed correspond to internationally recognized standards as set out in charters, declarations, and guidelines, including the Universal Declaration of Human Rights, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the OECD Guidelines for Multinational Enterprises, and the ILO Declaration on Fundamental Principles and Rights at Work.
Outlook
As a reflection of the importance of the topic, HENSOLDT has also taken the decision to develop its own approach to a human rights program. Responsibilities and processes are set out and organized in a human rights policy.1, 2
In addition, the Supplier Code of Conduct, in accordance with the principles of the International Forum on Business Ethical Conduct (“IFBEC”), and the PRD are intended to ensure that international standards are met in dealings with business partners. IntegrityNext, a cloud-based digital platform for reviewing and managing suppliers, is already in use (see Responsible Procurement).
1 The UK Modern Slavery Act Statement of HENSOLDT AG can be found under Sustainability | HENSOLDT
2 The HENSOLDT Human Rights Policy can be found at Sustainability | HENSOLDT
Digitalization, Data, and Security
Our Approach: Keeping Data Secure
Data and IT infrastructure play an ever-increasing, and in many sectors decisive, role in HENSOLDT’s numerous digitalization measures. Data leaks are prevented, and the risk of attacks minimized, through our global governance of digitalization and IT, as well as through a robust IT architecture. At the same time, sustainability is a central component of the digitalization strategy and makes a substantial contribution to minimizing HENSOLDT’s environmental footprint.
Within a framework of legal obligations, national and international guidelines, and conventions, data security has a high priority. Within the context of a comprehensive data protection management approach, numerous actions contribute to the continual monitoring and documentation of compliance with the defined data protection principles.
Significant Measures and Results of Data Protection Management in 2021
HENSOLDT’s data protection policies and measures are based on legal requirements and in line with the European General Data Protection Regulation, forming the basis for the company’s high standard of global data protection.
New Business Models – New Risks
Through advancing digitalization and networking, new business models and digitalization concepts are constantly emerging at HENSOLDT. Data enables new products, product applications, and innovative services as well as changed modes of working. Remote maintenance and services are increasingly becoming the rule, Industry 4.0 is transforming manufacturing, artificial intelligence has reached the tipping point, and mobile working has now become the norm for many employees. At the same time, opportunities for enhancing efficiency and improving the use of resources are opening up along the entire value creation and production chain.
To minimize the resulting potential risks, the Data Protection Management team, which reports to Legal, is continuously developing the HENSOLDT Data Protection Management programme in compliance with all regulatory requirements and our own integrity standards using a risk-based approach. Under the Management Board’s oversight, the team is developing and deploying processes and systems intended to ensure that our information processing is effective and efficient, secure yet powerful. These include the protection objectives and classes as well as HENSOLDT’s documentation management. In this way, we are safeguarding the data of all employees and customers as well as those of our other stakeholders.
Our aim is to ensure the protection of data meets the high level of international standards and to prevent or defeat any intrusions.
Digitalization and Sustainability
Digital technologies present new opportunities for sustainable living and business. Under the leadership of the Chief Information Officer, HENSOLDT is constantly working to promote digital sustainability initiatives.
These initiatives include the optimization of remote working during the pandemic, which is now incorporated within day-to-day operations, as well as new solutions for remote maintenance and customer service and for customer training and presentations. They not only enhance customer service and customer care, but also significantly reduce travel and thereby contribute to lowering CO2 emissions.
With the 2021 revision of the IT and digitalization strategy “GRIP”, HENSOLDT has paved the way in terms of embedding ESG in company-wide digitalization initiatives. The digitalization of business processes not only helps HENSOLDT to minimize its environmental footprint, but also boosts employee satisfaction, efficiency, and productivity. The introduction of Robotic Process Automation (“RPA”) bots, for instance, relieves our employees of monotonous and repetitive tasks. The focus on secure processes and a global IT architecture, which enables seamless cooperation in highly sensitive areas, supports all employees in the conservation of resources and the risk-free handling of complex projects.
In 2021, the company also switched to the eco-friendly and sustainable search engine Ecosia, with the IM Cyber Security department giving the green light following an extensive test phase. Now employees plant trees every time they enter a search query – a small step that makes a large contribution to sustainability.
To keep employees aware of issues around IT system security, the cyber security awareness campaign launched in 2020 was continued in 2021.
As part of a new regular series, key digitalization-related topics such as “remote maintenance with augmented reality” and “digital accident management” are presented.
In addition to reducing its ecological footprint, HENSOLDT also places a high priority on the responsible use of core technologies such as artificial intelligence (AI). Today, AI technologies are in use at HENSOLDT across all divisions. This means that HENSOLDT must ensure that ethical principles are complied with in both the development and the application of AI.
Secure, protected information technology together in conjunction with the responsible behaviour of all employees form the basis for a HENSOLDT future that is both digital and sustainable. The principle of “keeping data secure” creates scope for added value – to the benefit of our employees, our customers, the company, and the environment.
HENSOLDT also relies on the possibilities of digitalization in training and further education. In 2021, HENSOLDT's customer service in Immenstaad supported a customer training course with virtual reality for the first time. During the training on the maintenance of a system for the Eurofighter, the participants were able to learn the maintenance procedures virtually with the help of VR glasses before they were subsequently trained in practice on the device.