Compliance report 2013

Ferrostaal advocates integrity

Social responsibility with respect to employees, customers and business partners, investors and the general public, has always been and continues to be of great importance to Ferrostaal. Ferrostaal employees shall at all times and in all places abide by the law, internal company guidelines, respect basic ethical values and act in a sustainable manner. Observation of these principles is essential to the Company's success and they are echoed in the new Code of Conduct "Success through integrity - our guiding principles for doing business".

The early identification and minimisation of compliance risks in our operative business forms the basis for a successful compliance management system. An individual compliance risk assessment was carried out for each business division and the results were taken into account during the optimisation of the policies and procedures. All compliance guidelines were revised during the course of the financial year and the new policies, including "Business partner compliance audits" and "Behaviour when conducting business transactions", were communicated by the management.

In addition to the area of anti-corruption/antitrust, the organisations and programmes in the areas of privacy, export control and security were adapted to the new organisational structures at Ferrostaal, and are now even more tightly integrated into the business processes, making all compliance services available on a business or location-specific basis. Every business division has an appointed representative for each area. This representative is charged with advising on additional compliance-related issues and training activities on the basis of the Code of Conduct, in addition to performing mandatory compliance audits, such as approving major projects, business partners and donations.

All compliance officers and compliance managers, both domestic and overseas, provide expert reports to the Head of the Corporate Compliance Department, who in turn reports to Ferrostaal GmbH's Executive Board and Advisory Committee. The Business Partner Compliance Tool and related resources, which are used to perform mandatory audits on business partners, have also been optimised. A new computer-based tool has been developed for Compliance Service Point inquiries, which directs employee queries – for example, queries concerning gifts – to the Compliance Office.

The year 2013 saw an increasing number of requests for compliance declarations being received by both the business divisions and corporate units of the Ferrostaal Group from customers, reinsurers, banks and other partners. During the reporting period, the Ombudsman and the Compliance Office received notification of potential compliance violations and followed up on them. In the end, no evidence of criminal offences came to light.