The Rheinmetall Group investigates any concerns about breaches by employees or external parties in the spirit of good corporate governance irrespective of the level of hierarchy and organizational as-assignment of the concerned individuals or entities, and ensures that these concerns about breaches of the rules are properly processed (“zero tolerance”).
In accordance with the Rheinmetall Code of Conduct, violations of internal rules must be generally reported to the Compliance Organization. In an effort to protect whistleblowers, the Compliance Organization has created different ways how hints from around the world can be given to the Compliance Organization on an anonymous basis:
- Ombudsman - Dr. Buchert as Ombudsman is a lawyer and thus enjoys the legal privilege. In this respect, the communication of the whistleblower with him enjoys a high degree of legal protection. He can be contacted by whistleblowers in several languages and immediately informs Rheinmetall AG's central compliance organization about incoming information so that it can react in a timely manner.
- Direct contact with the Compliance Organization - Corporate Compliance as the central compliance organization of the Rheinmetall Group can be contacted directly in several ways (post/telephone/e-mail). This ensures that the information on demand of the whistleblower can be communicated to an independent body within the group in addition to the local companies.
- New: Before 2019 multiple isolated whistleblowing solutions were operated independently by various individual Rheinmetall companies. Meanwhile a central whistleblowing system is introduced which, in a standardized manner, brings together all the information, i.e. ranging from basic to highly critical nature, worldwide and transmits it to the Corporate Compliance organization for their referral. Subsequently, the Corporate Compliance Organization ensures that the information is properly dealt with, kept confidential on a strict need-to-know-basis and followed up correctly by the relevant stakeholders to be involved. Whistleblowers and other parties involved in an investigation are always treated fairly and receive relevant feedback on the outcome of the investigation.
Information about whistleblower incidents or contents of an internal investigation is regularly considered company confidential and will therefore not be disclosed on our website. However in certain cases it may be opportune to report certain incidents to the public. This will be decided on a case-by-case basis by the senior management. More important than openly presenting detailed information on our investigations, Rheinmetall Group ensures a globally standardized communication channel for investigation matters – offered to internal and external parties.
The Group Works Council and Corporate Compliance have concluded a Collective Bargaining Agreement on the Compliance Management System in 2018 which also clearly emphasizes the company’s uncompromising commitment to ensure non-retaliation of whistleblowers.
Every incoming notice must always be made known to the Compliance Organization. This records the notification centrally and forwards it to a multi-member body. This body is interdisciplinary and decides independently on how to deal with the hint. If necessary, a department is tasked with examining this information, which then informs the panel of the results of the investigation. Finally, the panel makes recommendations for a possible response to the report to those responsible for making a decision on their response to the study outcome. The test result and the resulting reaction are ultimately recorded centrally.
Quality of investigations
The Rheinmetall Group attaches great importance to a thorough investigation of any indications of violations of its internal rules. For this reason, the following measures have been established within the Rheinmetall Group in order to regularly ensure a high qualitative standard of these investigations in accordance with our defined processes:
- Through continuous reporting in a central database, the appropriate progress in each case is transparently presented to the Corporate Compliance department.
- Furthermore, each case is concluded in the form of a final report, which must be confirmed by a specialist control committee before finalization. In this respect, a direct control of the content takes place at this point.
- The investigation process itself requires the completion of each investigation in the form of several essential documents that must be prepared and centrally archived in order to make a minimum claim on each case for proper completion.
The Incident Management process updated regularly or on an event-driven basis as can be seen in the following excerpt of the internal policy.
Management level attention
Of course, we recognize a great interest in reporting incidents with a potentially high risk to senior management. On their side, too, there is naturally a desire to prevent damage to the company and to play a part in preventing it.
According to the defined process, major incidents, e.g. those involving the responsibility of a member of the Management Board, are reported immediately to the Chairman of the Management Board and also to the Supervisory Board.
The heads of the Corporate Legal and Compliance departments are involved in every assessment of major incidents. Within the scope of this assessment, the specialist expertise means that particularly critical issues are brought to the attention of the Management Board or the Supervisory Board.
The involvement of authorities due to criminally relevant facts is also decided on a case-by-case basis by a supervisory body together with the company's managers. To this end, the heads of the Corporate Legal and Compliance departments are regularly engaged in a close professional exchange.
Not every mere indication of a breach of the rules is reported to an authority. Particularly for the protection of our employees, we only approach authorities in such cases where the facts of the case prove a sufficiently probable suspicion.