Sustainability report 2021/22

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 are responsible for adhering to ethical and moral standards within our company and understand this to be much more than just a legal obligation. We are convinced that success can only be generated on the basis of cordial, respectful and considerate cooperation with one another. 

The Executive Management Board must act as a guiding light here by showing exemplary conduct, demanding this of and encouraging it in others. Its own mission is thus to sustainably commit to KHS’ compliance program and Compliance Department. When it comes to compliance, the Board sets a good example together with the company’s executive managers. Here, every executive manager is required to act as a role model. 

We have installed a system of compliance management that is applicable worldwide. At our central headquarters in Dortmund our compliance desk 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, the prevention of money laundering and criminal acts in general and data protection. In addition, each KHS Group company outside Germany 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 KHS code of conduct constitutes the central commitment in this respect. 

The KHS code of conduct

KHS’ code of conduct 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 in particular regulations on fair competition, the avoidance of corruption and conflicts of interests, transparent reporting and the duty to observe secrecy. 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.

Intergroup whistleblower system

A central independent entity for internal reporting has been created through Salzgitter AG to record as comprehensively as possible any violations of our code of conduct, legal requirements or company guidelines. Notifications can be submitted to the external ombudsperson’s office that are then forwarded to our compliance desk for checking and processing.

In order to prohibit all forms of corruption and unfair competition, we have implemented a strict four-eyes principle: payments or contractual obligations can only be made by at least two authorized employees of our company. We have those responsible in the relevant departments sign an annual compliance declaration and a voluntary agreement 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.

Moreover, our compliance guidelines are drawn up and adherence to legal provisions in the contract review process is assured by specialist contract lawyers. In our technical fields of activity we ensure that legal requirements are complied with through regular and constant observation of legal regulations and provisions. 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 workforce is always notified of the latest information and kept up to date.

Another important concern for KHS is the protection of personal data. In order to monitor and ensure the protection of such, 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 handle any violations of data privacy.

Information on further company principles relevant to compliance, such as our supplier code of conduct or the Modern Slavery Act, etc., can be found here.