Compliance Management System – Our core processes

Paul McNulty, former US Deputy Attorney General, is succinct when he describes the importance of an effective compliance management system:

"If you think compliance is expensive, try non-compliance!"

At Ferrostaal, the focus is upon preventing misconduct and encouraging integrity within the Company. Measures are implemented in the business processes to prevent systematic violations of compliance requirements (prevention). Another integral part of the compliance management system are measures designed to identify individual misconduct (recognition) and appropriate behaviour as well as commensurate sanctions for cases in which individual misconduct has been discovered, followed by a process of remediation or improvement (response).

Crucial to the effectiveness of the compliance management system at Ferrostaal is its interwovenness in the operational processes of the Company. Compliance forms an integral and systematic part of relevant business processes. The contents and requirements of our compliance directives are reflected in processes such as the selection of business partners, execution of major projects, in processes such as the presentation and acceptance of gifts, invitations, donations and sponsorship, in requirements for adequate data protection, and in requirements for corporate and employee safety and the relevant provisions applicable to export control.

The following processes are cornerstones of the compliance management system:

• FORUM, Ferrostaal Organisation Richtlinien und Mehr (Ferrostaal Organisation Directives and More), an internally developed IT tool that contains all of the relevant Ferrostaal directives applicable to its employees,
• Business Partner Compliance Tool, an internationally recognized IT system for integrity checking, approving and documenting of business partners,
• Compliance Service Point, an internally developed IT system through which employees submit requests to the Compliance Office, e.g. for review and approval of requests for gifts, invitations, donations and sponsoring,
• Compliance Communication, compliance not limited to a training topic. Compliance is an integral part of management meetings, of operational consultations, of the Ferrostaal Intranet or of Update, the Ferrostaal employee newsletter,
• "Whistle-blower" system, as an external, independent ombudsman, the attorney Dr. Rainer Buchert is available to employees and external individuals who wish to submit relevant information.