International Business
To protect our company’s reputation and ensure cooperation based on trust, HENSOLDT expects its suppliers, business partners, customers and all other relevant stakeholders to follow the same ethical standards and share the same attitude based on compliance and integrity.
Compliance with all necessary directives and procedures, including our Anti-Corruption Policy, the Partner Review Directive, the Export Compliance Policies, the Supplier Code of Conduct and all other compliance regulations and standards for business conduct, aims to ensure successful export business within the parameters of the applicable rules.
Anti-Corruption
In full awareness of its responsibility to maintain compliance and integrity, HENSOLDT has adopted strongest measures to minimise the risks it faces in daily business.
HENSOLDT rejects all forms of corruption – public and private, active and passive – and takes an uncompromising, zero-tolerance approach to such. We have developed an anti-corruption compliance programme that is designed to mitigate the risk of bribery and corruption.
While the HENSOLDT Code of Conduct provide guidance on common ethical and compliance issues in several areas, our Anti-Corruption Policy, which is applicable to all HENSOLDT Group employees, and the specific directives referenced below form the backbone of our anti-corruption compliance programme.
HENSOLDT has given special consideration to third parties, agents and intermediaries in its Anti-Corruption Policy and Gift & Hospitality Directive and drawn up rules for the acceptance of gifts, hospitality, sponsorships and donations.
With a special focus on corruption risks arising from dealings with commercial agents and third parties, we have developed a special, practical system for assessing with due care the risk of non-compliance with anti-corruption guidelines. This is put into effect through HENSOLDT’s Partner Review Directive. The aim is to minimise corruption risks at all times.
The Partner Review Directive forms the basis for all dealings with business partners. It follows a risk-based approach and contains special rules of conduct and duties of care with respect to the specific regional and transactional risks of each scenario.
Deals that are irreconcilable with HENSOLDT’s values are declined. All employees must also adhere to the same set of clearly defined rules regarding gifts and hospitalities.
To ensure compliance with all rules and the implementation of the policies and directives, HENSOLDT has expanded its internal Compliance Team substantially in recent years and provided it with the necessary resources. A structured decision process has been established to ensure that particularly risky transactions are reviewed by the Management Board or in specific cases the Supervisory Board.
Third Parties, Agents and Intermediaries
Important partners in our business
At HENSOLDT, we carry out due diligence to the highest and most professional standards before entering into any contractual relationship with agents.
As we are aware of the specific risks, we screen our agents as well as their beneficial owners when engaging and re-engaging. In particular, we make sure that they have not committed any legal violations in the past and are not connected to any politically exposed persons (PEPs) in a way that could lead to a conflict of interest or influence the business. To this end, our Partner Review Directive sets out a clear policy on the use of agents.
A key anti-corruption risk results from dealings with sales agents and other third parties who provide business development or sales and marketing support services to us or on our behalf or are otherwise involved in such activities. We have devoted substantial attention and resources to addressing this specific risk.
Our contracts contain strong compliance clauses, obligations and commitments that enable us to also terminate a contract immediately in case of any misconduct.
In addition, when entering into a contractual relationship, a key condition is stipulating remuneration that lies within a reasonable range. Therefore, we take extensive steps that allow us to validate the appropriateness of an agent’s or strategic advisor’s remuneration. To name just a few examples, we always consider price levels in the respective country, obtain benchmarks with regard to comparable companies and collect information from local chambers of commerce.
All these measures ensure that our incentive schemes for agents are designed to promote ethical behaviour and discourage corrupt practices.
In this regard, our compliance policies are not tick-the-box or off-the-shelf policies, but have been developed specifically for our businesses. When business proposals presented to us involve, in our judgement, compliance risks that are inconsistent with our values and risk tolerance, we are not afraid to forego those business opportunities.
Gifts & Hospitalities
Our principles in relation to gifts & hospitalities ensure that the giving and receiving of gifts and hospitalities is managed ethically and consistently throughout our company, in compliance with the law and within the bounds of social acceptability.
When it comes to accepting and granting gifts, we are required to comply with the laws and regulations of our country as well as the local laws and regulations of those countries in which we do business. In addition, our internal policies must be followed. Offering, providing or accepting gifts, meals, entertainment or sponsored travel may create a conflict of interest for HENSOLDT and pose a risk of corruption. Therefore, the intended granting or accepting of gifts or hospitalities has to be recorded and evaluated. HENSOLDT Group employees who are in a position to exchange gifts or hospitalities with third parties must analyse each situation carefully to ensure that the proposed gift or hospitality, whether given or received, is ethical and legal and complies with our own strict standards.
HENSOLDT has defined a catalogue in its internal Gifts & Hospitality Directive that clearly sets out general rules that must always be met before offering, providing or accepting any gifts or hospitalities. Additionally, there is a list of the types of gifts and hospitalities that are always prohibited, which helps to clearly evaluate whether a gift or hospitality is permitted. In case of any doubts, employees and managers at HENSOLDT are always encouraged to contact the Compliance Department.
Sponsorship & Donations
Our sponsorship and donation projects must strictly comply with our Standards of Business Conduct as well as with all applicable national laws and regulations. Furter, all employees must comply with the specifications and approval processes set out in our Sponsorship, Donations and Membership Directive. This document clearly describes the procedures for the allocation and acceptance of donations and contributions.
The business partner approval process also sets out how recipients of donations and sponsorship efforts are to be evaluated prior to a transaction in order to avoid conflicts of interest.
All activities and projects must be conducted in an open and transparent manner, leaving no doubt as to the legitimacy and appropriateness of the arrangements or the motives or consequences for the parties.
Approvals cannot be given if, for example
Contributions are requested by individuals for personal gain or interest
Antitrust & Competition Law
Protect diverse and free competition
HENSOLDT is subject to a wide range of competition and anti-trust 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 departments have implemented mandatory policies and guidelines; in addition, they advise and train the employees to ensure compliance with all antitrust and competition regulations.
Anti-Money Laundering
HENSOLDT is focused on combating money laundering.
As such offences frequently follow crimes of bribery or fraud, combating money laundering and terrorism financing is a critical component of HENSOLDT Group’s compliance programme and is significant for the success of our comprehensive anti-corruption strategy.
In this context, HENSOLDT Group meets the applicable legal requirements through measures that include conducting risk analysis, comprehensive due diligence and the prohibition of cash transfers.
Export Control
Integrity on all relevant export related issues
HENSOLDT has established Group wide valid policies to ensure full compliance with the applicable laws and regulations laid down by the relevant authorities in the field of export controls. These Policies also ensure timely identification and fulfilment of requirements prescribed by applicable national, EU and international legislation, in particular regarding the export and import of goods (defence, dual use and commercial products) technology and services, subject to export restrictions and obligations related to embargoes, sanctions and other trade restrictions.
HENSOLDT’s international business is subject to numerous export restrictions and controls. To comply with government export control requirements, Group-level Export Compliance issues generally applicable policies, to be implemented by all legal entities.