Ethics & integrity
We act with integrity in our working and business relationships. The key basis for this is a Group-wide Code of Conduct that provides all of us with binding guidelines for our behavior in the company, toward our business partners, our customers, and in society. For us, compliance means adhering to the law and our internal regulations, such as our Code of Conduct. In doing so, we pursue a zero-tolerance approach to violations should they occur.
For the success of our company and for our collaboration with our stakeholders, compliance is essential. MTU conducts its business as a fair employer, business partner and customer, and advocates transparent competition where all parties are on an equal footing. Integrity and responsible conduct are core values of our corporate culture and are embedded in the MTU Code of Conduct, which is binding for all employees, managers and members of the Executive Board. These Group-wide compliance rules include topics that are important to us, including key compliance issues such as corruption prevention or antitrust law.
Key topics of the Code of Conduct
Each employee must be familiar with and observe the legal requirements relating to their role, the terms of their employment contract and company regulations. Managers have a particular responsibility to uphold these requirements and regulations and to act as role models. We also expect our business partners to fully comply with all applicable laws. A separate Code of Conduct applies for suppliers. → Code of Code of Conduct for Suppliers
The MTU Principles (“We shape the future of aviation”) are an integral part of our corporate culture; they help us act in a consistent and reliable manner. As a signatory to the UN Global Compact (UNGC), we have committed ourselves to preventing corruption within our company → Principle 10 of the UNGC. In the interests of maintaining sustainable corporate leadership, we take our lead from the German Corporate Governance Code and international compliance standards, such as the Good Practice Guidance on Internal Controls, Ethics, and Compliance issued by the Organization for Economic Cooperation and Development (OECD). Our commitment to fighting corruption extends beyond the company as well; besides our status as a UNGC signatory, we are also a member of the AeroSpace and Defence Industries Association of Europe and the TRACE International anti-corruption initiative.
One focus of our compliance activities is the prevention of corruption. MTU condemns corruption of any kind as well as all other forms of white-collar crime. Our long-term success is founded on compliance with legal requirements and our own internal guidelines, which strengthens trust in MTU. In addition to the Group-wide Code of Conduct, our internal regulations concern the prevention of corruption and apply especially to customer events, donations, sponsoring and the approval process for sales consultants.
Our contribution to the SDGs
“Peace, justice and strong institutions” is SDG 16 of the UN Sustainable Development Goals (SDGs) for its 2030 Agenda. It calls for a significant decrease in all forms of corruption and bribery. With a comprehensive compliance system in place, we are actively taking steps to combat corruption and bribery, minimize the risk thereof and support fair competition. We expect our suppliers to uphold the same standards as we do. In this way, we as a company are able to contribute to sustainable development in line with SDG 16 and, with integral and transparent business practices, provide an open and progressive environment that benefits society as a whole.
Embedding compliance in the organization
MTU has a compliance system for the entire company. As the final decision-making authority, the CEO is responsible for the company’s business ethics and anti-corruption policy. The core functions responsible for ensuring ethical and correct conduct are a Compliance Board and a Compliance Officer. Both the Compliance Board, whose members are top managers from various departments, and the Compliance Officer hold Group-wide responsibility. The Compliance Officer’s duties include conducting preventive measures, investigating incidents of white-collar crime, and collaborating closely with the Compliance Board in further developing the compliance system. The Compliance Board holds regular and ad hoc meetings at the request of the Compliance Officer. The Compliance Officer provides quarterly updates to the Executive Board and the Supervisory Board’s Audit Committee, which for its part informs the plenary meetings of the Supervisory Board. The Supervisory Board’s Audit Committee oversees the Executive Board’s compliance activities.
In addition, the managing directors of the sites must ensure that all compliance-relevant provisions and regulations are adhered to within their areas of responsibility, and they must see to it that compliance is appropriately embedded in the local organization.
MTU’s compliance organization
Responsible international trade
Another key compliance topic for us is observance of international trade law, also known as trade compliance. MTU has its own organizational unit dedicated to ensuring trade compliance and has also instituted requirements for thorough audits. The regulations apply to all the company’s divisions, affiliates and employees worldwide. Customs and export control laws govern which products, services and technical data we are permitted to sell or provide and to where, to whom and for what purpose. Compliance with the applicable international trade regulations is a binding requirement of the Code of Conduct. → Export control law is outlined in the non-financial statement in the Annual Report (p. 118–119)
The central international trade department is responsible for implementing regulations with process standards that are uniform throughout the company. These processes include the review of all documents, software and parts prior to shipping to make sure they are in line with export control regulations or existing authorization requirements. The international trade department has been granted cross-divisional authority to issue certain directions, which extends to the right to stop deliveries. The department head reports directly to the Chief Operating Officer in his capacity as the person in charge of MTU exports.
Data protection and IT security
In our business activities, we take care to provide comprehensive data protection. In times like these and given the increasing levels of digitalization in the world of work, such protection is becoming more and more important. We have established an appropriate management system and expect all employees to comply with data protection regulations, A claim that is underpinned by our Code of Conduct. We have appointed data protection officers or coordinators in all of our Group companies, who are instructed in all relevant regulations. The aim is to achieve uniform data protection and data security standards for the handling of personal data throughout the Group that meet the requirements both of the EU General Data Protection Regulation (GDPR) and of the national legislation applicable at each location. The Executive Board is briefed on data protection once a month.
We also intensively discuss the topic of IT security, as this is a fundamental prerequisite for our business success. MTU has an IT security management system in place and implements appropriate protective measures on a technical and organizational level to ensure its IT systems are stable and secure. This also includes an internal body of rules and regulations that we have established in line with the international ISO 27001 standard.
Our compliance management system works
We want to prevent compliance violations and ensure that business decisions are made with integrity. We do not tolerate any kind of conduct that violates laws or regulations. We respond to reports immediately and appropriately, and take disciplinary action in the event of detected violations. In such cases, MTU applies a principle of zero tolerance. In the reporting year, we did not identify or confirm any suspected instances of corruption. We also did not receive any formal complaints regarding corruption. No significant fines were levied against MTU for breaches of applicable laws, And it faced no legal action stemming from corruption or due to antitrust or anticompetitive practices. In 2019 as in previous years, we had no reportable violations regarding data protection. Similarly, there were no substantial violations of the principles underpinning the Code of Conduct.
Global reporting system
We have set up a global whistleblower system that allows employees and external stakeholders to report instances of unlawful conduct to the Compliance Officer. Tips and reports can also be submitted anonymously via a web-based electronic reporting system. If the report is found to be credible, the Compliance Officer initiates the investigative steps necessary. The ways we have established for reporting non-compliance are communicated to employees through internal media channels and explained to external stakeholders in writing or on our website. In the reporting year, an internal communication campaign informed all employees and managers at all sites across the Group about iTrust, the new reporting procedure. The reporting system is available in various languages. → iTrust
We treat the identity of the whistleblower and the information they impart as strictly confidential—even if the suspicion turns out to be unfounded. This is ensured by means of an internal regulation. We wish to make it clear that whistleblowers acting in good faith shall not be penalized or disadvantaged by the company in any way. In addition, employees can confide in their superiors, the legal department or HR.
In the reporting year, we trained more than 500 employees across all hierarchical levels on compliance matters at our sites.
Training employees on compliance
To ensure a functional compliance culture, MTU puts a high priority on preventing possible forms of misconduct and raising awareness of compliance issues among employees. When new employees are taken on, we inform them about the Code of Conduct and require them to sign a declaration to uphold it. We also present and discuss the Code of Conduct at the introductory event for new employees at all our locations. We regularly train our employees and managers at all hierarchical levels on the Code of Conduct, corruption prevention and the compliance management system. This applies in particular to new hires. In addition, we hold compliance training as needed for employees from selected areas, such as sales. In the reporting year, we trained more than 500 employees across all MTU sites on compliance matters in both e-learning and classroom sessions. In addition, we continuously provide information about and raise awareness of special compliance issues, such as data protection, in a way suitable for each target group. The Compliance Officer and the legal department can also advise our employees and managers as needed.
Limiting risks of non-compliance
We have put various control mechanisms in place to ensure compliance throughout the company and to minimize risk. In the reporting year, we evaluated all fully consolidated sites for corruption risks; no substantial risk was found. The Compliance Officer additionally inspects all sales support consulting contracts for possible corruption risks before they are placed or renewed, 2019 included, and found no indications of corruption. Potential consultants are also subject to an assessment by an independent provider of due diligence services. The corporate audit department conducts regular compliance audits in which it checks business processes and procedures for conformity to legal requirements and adherence to internal guidelines.
We aim to continuously improve our compliance system and always ensure that our Group regulations are up to date. To that end, once a year we evaluate whether changes or amendments are necessary. In doing so, we draw on a wide range of input, including concerns raised by our employees. Here is what we have resolved to do: We are further developing our reporting system for all Group locations and also aim to rework the Code of Conduct and the corresponding e-learning course. Furthermore, in 2020 we plan to implement a new training concept in the area of international trade law.
In addition, we will completely overhaul the MTU Group’s data protection guidelines. As a global company, we require a uniform level of data protection with a standard in place that applies across the Group worldwide.