Our Compliance Programme

Demonstrating Integrity

Compliance matters to all of us. HENSOLDT stands for integrity and for compliance with the rules and values on which we base proper corporate governance. Our Compliance Programme seeks to ensure that our business practices conform to applicable laws, regulations and ethical business principles, as well as developing a culture of integrity.

Our behaviour and daily decisions have an impact on the integrity and reputation of the whole HENSOLDT Group. Our “Standards of Business Conduct” constitute the cornerstone of our commitment to integrity. They describe minimum standards that are binding for each of HENSOLDT Group employee worldwide. We owe it to ourselves and all stakeholders to adhere to the highest professional standards.

We consider our duty to combat all forms of corruption, public or private. Our policies and rules govern all contractual arrangements entered into by our company, in relation to any business or project partners or any associated third parties. Determined to ensure the highest standards of responsibility throughout our supplier base, we also require that suppliers commit to the same code of conduct.

We have developed and implemented a comprehensive Compliance program that we have designed with specific regard to our individual risk profile taking into account, for example, our industry, our product portfolio, our international sales into countries with increased corruption risks, and the background of our customers.

We have also established a whistleblower system which gives an opportunity in particular but not only to employees to personally or anonymously report violations (“HENSOLDT OpenLine”), and we are committed to investigate any suspicions of non-compliance and to take appropriate remedial action.

A single case of corruption could put a company’s future at risk.
We do everything to assess and mitigate the risk of corruption, so that our company will not suffer severe harm
Solms Wittig

General Counsel, HENSOLDT

Our Compliance program addresses, amongst others, the areas of anti-corruption, antitrust, data protection, sanctions and export compliance. We have implemented dedicated Compliance guidelines and procedures concerning all these topics, with our Standards of Business Conduct being the cornerstone of our Compliance regulations.

Within our comprehensive Compliance program, one of our focus areas is the prevention of corruption. One of the key anti-corruption risks results from dealings with sales agents and other third parties providing 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 address this specific risk, including  the adoption of an overarching company policy that strictly limits and controls the use of “success fee” sales agent relationships, the careful evaluation of anti-corruption risk in M&A transactions and offset arrangements, training of relevant personnel, and the communication of our approach to anti-corruption Compliance to key business partners. Our Compliance policies are not, in this regard, “tick-the-box” or off-the-shelf policies, but have been developed specifically for our businesses. When business proposals are presented to us that involve, in our judgment, compliance risks that are inconsistent with our values and risk tolerance, we are not afraid of turning away those business opportunities (zero tolerance policy).

As part of our comprehensive Compliance program, we have implemented monitoring and control activities designed to ensure that our Compliance standards and requirements are fulfilled in day-to-day operations. At the same time, we also regularly conduct a risk analysis to refresh our risk assessments and to identify areas where we could improve our Compliance mechanisms.

Our principles on gifts and hospitalities ensure that giving or receiving of gifts and hospitality is managed ethically and consistently throughout our company, under the conditions of compliance with law, business purpose and social acceptability. Our sponsoring and donation projects must strictly comply with our standards of business conduct, as well as with all applicable national laws and regulations.

Each of the nations in which we do business has controls on the export and transfer of its goods and its technologies that are considered to be important to its national security and foreign policies. As a global enterprise, it is our responsibility, as well as in our business interest, to respect and to comply with each of this controls. Our policies, processes and Export Control organisation ensure compliance with the relevant export control laws and regulations.

We are committed to the right to privacy and protection of personal data and our data protection policy provides a consistent level of protection for our employees.