Sustainability report 2019/20

Compliance: sustainable voluntary commitment 

Codes of conduct, reporting systems and data protection

One of the most important guiding principles of our company is that we live by our values and set an example in doing so. We accept responsibility towards our workforce, customers and suppliers and to society and the environment, which is why adhering to ethical and moral standards is much more than just a legal obligation for us. We are convinced that success can only be sustained on the basis of cordial, respectful and considerate cooperation.

This is why the Executive Management Board itself endeavors to set an example with its correct conduct and to demand it of and encourage it in others, too. The Board is responsible for sustainable voluntary commitment: this is the body that actively practices compliance and sets a good example together with the company’s executive managers. Every executive manager is required to act as a role model.

This is why we have installed a system of compliance management that is applicable worldwide. At our central headquarters in Dortmund a compliance officer is responsible for supervising adherence to the appropriate values and codes for the entire KHS Group. Annual surveys and risk analyses are carried out in areas that are particularly relevant to compliance: anti-corruption, antitrust law, prevention of money laundering and criminal acts in general and data protection. Each company outside Germany also has an appointed coordinator who is assigned to deal with such issues when and if required in cooperation with the compliance desk in Dortmund. The valid codices at KHS are:

the KHS code of conduct

It was introduced in 2012 and is compatible with the code of conduct adopted by our parent company Salzgitter AG. Both are based on the United Nations Global Compact. The code centers on a shared system of values and principles designed to act as a guide to the manner in which all of our personnel must conduct themselves. It includes regulations on fair competition, the avoidance of corruption and conflicts of interests, transparent reporting, the duty to observe secrecy and various other points. All employees are instructed on the use of the guidelines by their executive managers or our Compliance Department and are encouraged to make queries at any time. 

Code of conduct for on-site installation

By way of supplement to our general code of conduct, our code of conduct for on-site installation introduced in 2018 defines specific rules that must be observed when on assignment at customer sites. 

A central independent entity for internal reporting has been created through our parent company Salzgitter AG to record as comprehensively as possible any violations of our code of conduct, legal requirements or company guidelines. Notifications can also be submitted to the external ombudsperson’s office that are then forwarded to our compliance desk. At the moment we are about to launch our own worldwide notification system for internal and external stakeholders (as of March 2021). 

In order to prohibit all forms of corruption and unfair competition, we have implemented a strict four-eyes principle: payments or contractual obligations cannot be triggered by one employee alone. We have people in relevant departments submit an annual compliance declaration and a voluntary commitment in relation to conflicts of interest. Various transactions at our subsidiaries outside Germany must be approved by KHS GmbH as the parent company in order to avoid corruption.

Compliance with legal provisions in the contract review process is also monitored by specialist contract lawyers. In our technical fields of activity we ensure that legal requirements are complied with through regular and constant observation of the legal situation. Any changes to standards or specifications are then communicated throughout the entire company group. A wide range of basic and compulsory further training courses in the particularly vulnerable sections of our company make sure that our employees are always up to date with the latest information.

Another important concern for KHS is the protection of personal data. To this end, we have assigned a central data protection officer and set up an international data protection organization in the sense of the GDPR. We also obligate our subsidiaries outside the EU to exercise a high level of data protection. We have introduced a worldwide reporting system to process any violations of data privacy.