The term “compliance” denotes the observance of laws, regulations and internal policies. Every employee of MTU Aero Engines AG and its subsidiaries is obliged to meet the compliance requirements. The specialist functions ensure compliance with the laws and internal policies. Within the company, for instance, Corporate Quality ensures compliance with the requirements imposed by the aviation authorities, and Health and Safety Engineering/Environment ensures compliance with environmental protection standards and occupational health and safety provisions.
To see to it that compliance is strictly followed, MTU’s Executive Board has defined a series of measures to minimize the risks of white-collar crime:
- Adoption of a mandatory Code of Conduct that is valid throughout the MTU Group
- Appointment of a Compliance Officer.
- Institution of an Ombudsman to deal with cases of suspected wrongful conduct.
- Establishment of a Compliance Board.
- Permanent employee security clearing screenings.
- Training, for instance in anti-trust legislation or in MTU’s Code of Conduct, etc., which is held at regular intervals.
MTU’s Compliance Officer is responsible for assuring conformance to statutory requirements – the focus being on preventing white-collar crime – and an ethical conduct of business activities. The Compliance Officer is obliged to fully investigate all reported suspected violations and cases of non-compliant conduct. All business areas are screened at regular intervals to identify potential instances of corruption. Moreover, the Compliance Officer regularly reports to MTU’s Executive Board and the Supervisory Board’s Audit Committee on its activities.
The Compliance Officer assesses any and all new and renewable contracts with customer support & sales consultants for potential risks of corruption and, in addition, obtains conducts third party due diligence screenings through an independent organization. The Compliance Officer approves the finalization of the contract only after this review has brought a positive result.
Above and beyond being committed to meeting its obligations to comply with the laws, regulations and company policies, MTU is committed to ethically responsible and sustainable conduct and business practices. The Compliance Board as another central organization for the prevention of, and investigation into, compliance-related offenses supports the Compliance Officer in discharging the duties associated with this role in the area of business crime.
The Compliance Board is made up of the senior vice presidents for controlling, human resources and legal affairs. It convenes four times a year on the invitation of the Compliance Officer; in addition, ad-hoc meetings are held if and as required. At the meetings, the Compliance Officer informs the members of the Compliance Board about all compliance-related incidents and reports submitted to the Ombudsman.
The primary function of the Compliance Board is to assist the Compliance Officer with advice and guidance, but upon the Compliance Officer’s request, the Compliance Board may also make decisions on a case-by-case basis. This will primarily be the case whenever serious matters or violations are involved that may have an impact on the company’s image in the public eye.
To ensure that unlawful acts of relevance to compliance can be reported, MTU has instituted an Ombudsman; through the Ombudsman, not only MTU employees, but also individuals not on MTU’s payroll may report known, suspected or alleged non-compliances.