More compliance topics
The key for trust
We are committed to the right to privacy and protection of personal data, and our Data Protection Policy provides a consistent level of protection of personal data.
At HENSOLDT, data protection means more than just complying with legal requirements: it is also an expression of our ethical and mindful dealings with employees and business partners. Our Data Protection Policy (complies with the EU General Data Protection Regulation (GDPR).
Employees are supported in this by our own Data Protection Officers, who serve as the main points of contact for all IT and data protection issues.
M&A and joint ventures
Ethics and integrity in economic growth
We make sure that we only invest in companies of integrity.
Mergers and acquisitions, strategic alliances and joint ventures are a central element of HENSOLDT’s ongoing internationalisation and growth strategy.
In accordance with Group-wide guidelines, potential target companies are subjected to a careful analysis of opportunities and risks through standardised processes such as extensive due diligence procedures and are assessed on the basis of strategic, commercial, operational, financial as well as compliance aspects.
We devote substantial attention and resources to addressing the specific compliance risks, including the diligent evaluation of anti-corruption risks in M&A transactions.
Once a transaction has been completed, the enforcement of our strict compliance rules is closely monitored by us. We take an active role in preventing bribery and corruption in all of our joint ventures.
Offset & industrial participation
As the German federal government does not impose any offset requirements to foreign defence contractor, HENSOLDT is not beneficiary of any offset related business. However, where governments impose offset requirements on foreign contractors in HENSOLDT export markets, HENSOLDT applies a strict and transparent process to comply with these offset obligations.
HENSOLDT Group customers all over the world, in particular public customers, are increasingly demanding offset from HENSOLDT Group or reciprocal trade to compensate their (national) outflows generated due to procurement of HENSOLDT Group products and services, commonly referred to as offset, industrial participation, localization or industrial collaboration etc. Offset et.al. is any agreement, commitment or obligation, whether general or specific in nature, to hire or contribute goods, technology, services or funds to any person, company, or government entity in connection with HENSOLDT Group securing business in a given country.
HENSOLDT Group is committed to ensuring that it meets offset obligations and undertakes offset activities in full compliance with all applicable laws, including anti-corruption laws, the HENSOLDT Group Anti-Corruption Policy and Standards of Business Conduct, as well as HENSOLDT Offset Compliance Directive, Business Approval Directive and Partner Review Directive.
HENSOLDT Offset Department
The HENSOLDT offset department is centrally organized and responsible for all offset related topics worldwide, of the entire HENSOLDT Group and over the entire lifecycle of each project. The offset department is single point of contact to all Offset Authorities and single interface for the negotiation and agreement of offset obligations and related terms and conditions with HENSOLDT customers. The offset department continuously monitors all offset related activities (incl. on-going campaigns, expected obligations and signed obligations) and financial KPIs, reports the status and progress of HENSOLDT offset matters to the HENSOLDT Executive Committee on a regular basis and all compliance relevant offset matters to the compliance department on a monthly basis. The offset department prepares the offset related third party and obligation approval requests to the compliance department, the offset related technology transfer approval requests, as well as the offset related export control requests.
Overall, the offset department is responsible for the implementation of an effective offset and industrial participation policy to ensure that offset business is carefully managed in a structured, strategic and consistent way across projects, decisions involving stakeholders across functions, sites and management levels are made and ensure that strategic, commercial, technology, and compliance elements are taken into account throughout the project lifecycle. The offset department works closely together with the business development and sales function, procurement, production, engineering, program management, legal, compliance and export control etc.
Through appropriate contractual clauses HENSOLDT ensure that its suppliers including offset partners adhere to the appropriate standards regarding anti-bribery, corruption-prevention, and compliance.
All members of the offset department receive anti-bribery and corruption prevention training, as well as special internal compliance process training.
HENSOLDT Offset Due Diligence
HENSOLDT has in place the offset compliance directive that applies to all Offset Obligations undertaken by HENSOLDT Holding GmbH, its subsidiaries, and its affiliates (“HENSOLDT Group”).
HENSOLDT Group must not incur any offset obligations or engage in any offset-related activities unless such obligations and activities have been subject to appropriate due diligence and internal HENSOLDT Group approvals. Any third parties, involved in obtaining, performing, or discharging HENSOLDT Group’s Offset Obligations must be subject to appropriate due diligence and approval in accordance with the Partner Review Directive.
The HENSOLDT Group does not contract any offset agents or brokers or use any other offset intermediaries.
The offset obligation and third party due diligences according to the Offset Compliance Directive and Partner Review Directive involve a detailed review of the offset obligation and potential partner including but not limited to the mode of discharge, involvement of any intermediaries, requirements or veto rights in regards to third parties, known corruption or serious misconduct involving the offset process, as well as, the business interest and justification, involved parties, relationships with governments and public officials, potential partner qualifications, selection process, compensation, compliance issues, conflict of interest, shareholders and ultimate ownership.
The Offset Department must consult with the Compliance Department before any existing Offset Obligation is amended. In case of significant changes to the offset obligation or third parties the due diligence must be refreshed.
The Compliance Department and the General Counsel monitor the discharge of any approved Offset Obligations on an on-going basis, including the development of offset plans and compliance with any conditions imposed in relation to approved Offset Obligations.
Offset Information on the period FY 2021
Information on HENSOLDT offset projects performed in FY 2021.
HENSOLDT has been implementing 17 indirect offset projects in FY 2021.
If you seek more information on offset and industrial participation, please contact our HENSOLDT Group Offset & Industrial Participation department:
Henrik von Loevenich
Head of Industrial Participation and Offset
+49 89 51518 1803