Compliance Framework

Anti Money Laundering Policy

The AML policy summarizes all measures implemented to prevent money laundering and terrorist financing in the Rheinmetall Group (e.g. by carrying out risk analyses; largely avoiding or monitoring any cash transfers) and defines responsibilities and contact persons.

Anti-Trust Policy

Antitrust law protects free and fair competition, preventing competitive distortions that harm customers and other market participants. Rheinmetall acknowledges without reservation the right to free and fair competition and will not tolerate any viola-tions of antitrust law. We have therefore implemented directives, procedures and binding instructions to employees aimed at ensuring full adherence to applicable competition law.

Business Partner Policy

The objective of the Business Partner Policy is to support employees with regular interfaces to business partners by prescribing general precautionary measures for the diligent selection, verification, engagement and risk-conscious monitoring of business partners.

In addition binding minimum standards for an audit and monitoring procedure are specified for certain categories of business partners. As a result, Compliance risks in connection with the use of business partners are to be avoided as far as possible.

CMS Manual

Rheinmetall AG has introduced a risk-based Compliance Management System (hereinafter also referred to as "CMS") for the professional and appropriate implementation of Compliance measures within the Rheinmetall Group and described it in a CMS manual. The manual is structurally based on the IDW PS 980 framework. This manual is intended to give all Rheinmetall Group employees an overview of the most important principles of Compliance in their day-to-day work.

The transparent presentation of the overall context of the various Compliance topics by means of references to Compliance guidelines, information, advice and training serves as a solid foundation for Compliance-adherent work throughout the Rheinmetall Group and is intended to give everyone access to these topics.

Code of Conduct

The Code of Conduct with its in a clearly structured, universally comprehensible and unequivocal wording represents the central guiding principle with regards to ethical and compliant conduct within the Rheinmetall Group. Its adherence bears the most significant importance for all global business ventures when dealing with each other internally, but also with regards to our customers, business partners, shareholders and the general public.

The Code of Conduct is composed of references to external laws, regulations and soft-law standards as well as internal requirements like company values, behavioral patterns or certain procedural requirements. Furthermore, it provides guidance to all internal and external stakeholders how the Rheinmetall Compliance Management System works and how to interact with the Compliance functions in case of infringements of the applicable rules.

Data Protection Manual

As a company-wide guideline, the Data Protection Manual is intended to help anchor a data protection system firmly in the operational organizations and to provide guidance on the relevant data protection principles that must be observed throughout the Rheinmetall Group worldwide. The overall objective is to achieve an appropriate level of data protection across the Group.

Dawn Raid Policy

The so-called Dawn Raid Policy is a guideline how to behave when dealing with searches by public authorities (so-called "dawn raids") in Rheinmetall's operating area. It is intended to assist in dealing as efficiently as possible with the authorities, such as the trade inspectorate, customs, technical inspectors, the economic control service, etc., in order to be able to guarantee the operational continuity at all times.

Transparency in dealing with authorities is important to the Compliance Organization. In addition, however, the company's own employees should also be supported in their day-to-day dealings with the authorities and protected from unintentional procedural errors.

Donations and Sponsorship Policy

Both the Gifts Poliy and the Donations & Sponsorship Policy are important instruments for the prevention of corruption. By imposing value limits and procedural and approval routines, Rheinmetall creates the necessary sensitivity among its employees to the use of funds for third parties in the business, regulatory and political context.

Accepting and granting advantages, bribery and bribery are acts that Rheinmetall considers to be "no goes". For this reason, every effort is made to ensure transparent and honest business relations. To this end, Rheinmetall goes to great lengths to comprehensively review potential and existing partners and to review the sustainability of internal financial flows.

In addition to an in-depth review of business partners, the instruments for this include the constant comparison of blacklisting lists, anti-terrorism lists, the provision of information on corruption risks in individual countries, the regulation of grants, donations and sponsorship. These measures are accompanied by constant awareness improvement measures and training of employees on the said topics.

Incident Management Policy

The subject of the "Incident Management Policy" is a Group-wide regulation for the equal treatment of indications of non-compliance within the Rheinmetall Group.

In concrete terms, it defines the handling of received indications of rule violations. Starting with the recording and coordination of the processing of notes, closing with the communication of test results to those responsible and their reaction. As a result, the regular risks for employees and the companies of the Rheinmetall Group are largely minimized through standardized and independent examining.

Offset Guideline

The Offset Guideline provides support in strategic and operative business activities in the Defence secotr by defining targets, strategies, responsibilities as well as general processes / structures in form of a manual for all operational organizations to properly deal with Offset and Industrialization requirements.

Risk Prevention Policy

The systematic prevention of Compliance risks is one of the key tasks of any Compliance organization.

For this purpose, the Risk Prevention Policy describes the existing, recurring analysis measures for recording concrete and systematic Compliance risks, in addition to the security measures already integrated into ongoing operational processes (e.g. training, business partner review process, etc.). In addition, the regular support of other departments in identifying and mitigating existing Compliance risks by the Compliance function is explained in more detail, too.

Framework Policy Compliance-Trainings

Training employees on Compliance-relevant topics is an integral part of a comprehensive Compliance Management System. This policy regulates the methodical approach for the systematic training of Compliance content in order to familiarize a large number of employees or specific target groups with the Group's Compliance management system and to deepen specialist content for specific user groups.

Framework Policy Compliance contractual Reviews

As part of business partner reviews, the Compliance Organization is involved in contract design to determine the extent to which Compliance-relevant aspects are taken into account.

The audit focuses on the prevention of money laundering and corruption. Particular attention is paid to the background check on the business partner, the assessment of the underlying business model, the level of remuneration and the obligation to provide evidence of performance taking into account tax law aspects.

Social Media Policy

The Social Media Guideline is intended to serve as a guide for employees in their dealings with the new media. Those who register with a social network will soon find that it is difficult to separate professional and private life.

Every employee is also a valuable ambassador for our company and its products in his or her private life. In external communications, even if they express themselves privately, they are often perceived in their role as employees of our company. Thus, a private statement can quickly become an official statement of the company. We want to help our employees to protect themselves from such dangers. This is why you will find important guidelines and helpful tips in this guideline that will show you how to move safely in the social network.

Social Responsibility Framework

The Global Framework Agreement represents a commitment of the Rheinmetall Group to its social responsibility. It contains group-wide principles for the international observance of human rights (including equal opportunities, non-discrimination, protection against harassment, strict prohibition of forced and child labor under the relevant ILO conventions), fair working conditions (including remuneration, working time, occupational health and safety) and rights of employee representatives.

Rheinmetall AG discussed and agreed the contents of the agreement in advance with the European Works Council and also included the international trade union confederation IndustriALL Global Union and the German IG Metall. The Global Framework Agreement signed on 12/10/2018 contains more comprehensive rules than the previous 2003 document.

Gifts Policy

Rheinmetall AG's guidelines on gifts and benefits govern the handling of gifts, hospitality and invitations to events and constitute an important means of preventing corruption. Particular attention is paid to the way in which the Defence sector in particular deals with public officials and other government officials, as the risk of an unintentional violation on the part of Rheinmetall is regarded as particularly high.